The inspectors identified a non-cited violation (
NCV) of
Technical Specification 6.8.1, Procedures and Programs, because Exelon did not adequately establish and maintain the plant shutdown procedure. Specifically, the procedure was not adequate in that it did not contain precautions concerning rod insertion when reactor power is below the point of adding heat; operational limitations on plant cooldown when power is below the point of adding heat; and contingency actions for re-criticality during shutdown. Exelon entered this issue into their corrective action program as
IR 2412093 and conducted a root cause analysis. This finding is more than minor because it affected the procedure quality attribute of the
Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to
initiating events. Specifically, the plant shutdown procedure did not contain precautions to continuously insert
control rods when reactor power is less than the point of adding heat, did not define operational considerations for limiting reactor cooldown, and did not contain contingency actions for return to criticality during shutdown. The inspectors screened this issue using
IMC 0609.04, Initial Characterization of Findings, Exhibit 2 of
IMC 0609, Appendix A, The
Significance Determination Process for Findings At-Power, and
IMC 0609 Appendix M,
Significance Determination Process Using Qualitative Criteria. Inspectors determined this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon did not ensure that the shutdown procedure contained adequate controls for soft shutdown.