Technical Specifications 5.4.1.b, Procedures, required, in part, that written procedures shall be established, implemented, and maintained for the emergency operating procedures (
EOPs) required to implement
NUREG-0737, Clarification of
TMI Action Plan Requirements, and Supplement 1 to
NUREG-0737. Contrary to this requirement, as of August 15, 2007, the licensee failed to maintain
EOPs required to implement the requirements of
NUREG-0737 and
NUREG-0737, Supplement 1. The licensee failed to maintain
EOP 19100-C, ECA-0.0 Loss of All
AC Power, version 39, consistent with revised Pressurized Water Reactor Owners Group/Westinghouse Owners Group emergency response guidelines that restricted the
RCS cooldown rate to less than 100 degrees Fahrenheit per hour to prevent thermal shock to the
reactor coolant pump (
RCP) seals following a loss of all alternating current power (
SB) event. The licensee entered this violation into the
CAP as CR 10066747 and revised
EOP 19100-C consistent with the updated guidance. A bounding detailed risk evaluation was performed by an NRC regional senior risk analyst (
SRA) who determined the finding to be of very low risk significance (Green). The dominant result was a grid-related Loss of Offsite Power that then proceeds to an
SBO event and
RCP seal failure due to thermal shock.
