TS 5.4.1, requires that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in
Regulatory Guide (RG) 1.33.
RG 1.33, Appendix A, Section 3h, requires procedures for startup, operation, and changing modes of operation of spent fuel pool cooling. Contrary to the above, the licensee failed to adequately implement their procedure for pumping down the Unit 3 fuel transfer canal (
FTC), resulting in a loss of Unit 3
SFP inventory into the Unit 3
FTC. The loss of
SFP inventory was identified by the control room operators prior to the low level alarm by observing that an unexpected reduction of
SFP cooling flow had occurred and entered the appropriate abnormal procedure. The finding was determined to be of very low safety significance (Green) because the finding did not result in a loss of
SFP inventory greater than 10 percent of
SFP volume. The licensee entered the finding into their Corrective Action Program as PIPO-09-0344
