An apparent violation of
10 CFR 50, Appendix R, Sections III.L.2.b and III.L.3 was identified, in that, for a severe fire in areas requiring the manning of the Standby Shutdown Facility (SSF) and activation of the SSF makeup pump, the licensees
safe shutdown strategy and related response procedures delayed the manning of the SSF until there was a loss of function of high pressure injection and component cooling or
feedwater. In some scenarios, this would delay transfer of control to the SSF, thereby challenging the operability of the installed SSF makeup pump. This could result in pressurizer level failing to be maintained within the indicating range. The licensee has revised the affected procedures and is evaluating the need for additional corrective action. This finding is greater than minor because it was associated with protection against external factors and procedure quality cornerstone attributes. It affected the objective of the
Mitigating Systems cornerstone to ensure the availability, reliability and capability of systems that respond to
initiating events. This degraded condition increased plant risk because, if a severe fire occurred in areas requiring the manning of the SSF and activation of the SSF makeup pump, the licensee\\\'s procedures may not preclude loss of
reactor coolant beyond the capability of the SSF makeup pump. (Section 4OA5.01)
