The inspectors identified a finding of very low safety significance (Green) and an associated
Severity Level IV NCV of
10 CFR 50.59,Changes, Tests, and Experiments, when licensee personnel failed to obtain a license amendment prior to implementing a proposed change to the plant that resulted in a more than minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety previously evaluated in the
Updated Final Safety Analysis Report (
UFSAR). Specifically, the licensee performed a modification to the facility that permitted the Unit 1 and Unit 2 A
Auxiliary Feedwater (
AF) trains to be shared between units and the
10 CFR 50.59 evaluation that was performed reached the erroneous conclusion that prior NRC approval was not required. The licensee issued a Standing Order to modify the Emergency Operating Procedure which governed the use of the modification and planned to submit a License Amendment Request (
LAR) to the NRC for this design change. The issue was entered into the licensees corrective action program as
IR 1257908. The violation was determined to be more than minor because the inspectors determined that the change required prior NRC approval. Violations of
10 CFR 50.59 are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated through the
SDP to determine the severity of the violation. In this case, the inspectors determined the finding could be evaluated using the
SDP in accordance with
IMC 0609,
Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the
Mitigating Systems Cornerstone. Specifically, the inspectors answered Yes to Question 1 of the
Mitigating Systems Cornerstone column of the Phase 1 worksheet because the inspectors concluded that this was a change confirmed not to result in the loss of operability. Based upon this Phase 1 screening, the inspectors concluded that the issue was of very low safety significance (Green). In accordance with Section 6.1.d.2 of the
NRC Enforcement Policy, this violation is categorized as
Severity Level IV because the resulting changes were evaluated by the
SDP as having very low safety significance. This finding had a cross-cutting aspect in the Operating Experience component of the Problem Identification and Resolution (
PI&R) cross-cutting area [P.2.(b)] because the licensee failed to make adequate use of known industry operating experience in the screening of a modification prior to installation.
