The inspectors identified a
Severity Level IV non-cited violation of
10 CFR 50.59(d)(1) for the licensees failure to document an evaluation which provides the basis for the determination that a change, test, or experiment did not require a license amendment. Specifically, the licensees
10 CFR 50.59 screening failed to provide an evaluation as to why the installation of the
high pressure coolant injection (
HPCI) suction piping, which did not meet
USAS B31.1 Code requirements, did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a Structure, System, or Component (
SSC) important to safety. The licensee entered this issue into the corrective action program and planned to do additional
weld metal tensile and bend tests on a remnant piece of the non- conforming
HPCI pipe. The licensee intended to perform this testing to demonstrate quality levels equivalent to that prescribed by the
USAS B31.1 Code. Because the issue potentially impacted the NRCs ability to perform its regulator
function, this finding was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that this change, which adversely affected equipment importan
to safety, would not have ultimately required NRC approval. The licensee considered the nonconforming replacement pipe operable, based upon satisfactory hydrostatic tests of the installed pipe to demonstrate structural and leakage integrity at the time o
installation. The inspectors completed a significance determination of the underlyin
technical issue using NRCs inspection manual chapter (IMC) 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, dated November 22, 2005, and answered no to the
Mitigating Systems screening questions in the Phase 1 Screening Worksheet. Based upon this Phase 1 screening, the inspectors concluded that the issue was of very low safety significance (Green). In accordance with the
Enforcement Policy, the violation was therefore classified as a
Severity Level IV Violation
