A self-revealing
NCV of
TS 5.4.1, Procedures, was identified in that procedures for securing
Residual Heat Removal System (
RHS) were not adequately maintained and did not contain relevant operating restrictions resulting in the inadvertent lifting of the A
RHS pump suction relief[2RHS-RV721A] during normal operation, excessive identified leakage of
reactor coolant to the Pressurizer Relief Tank, and a declaration of an Unusual Event. The inspectors determined that the finding was not similar to the examples for minor deficiencies contained in
IMC 0612, Appendix E, Examples of Minor Issues. The finding was more than minor because if left uncorrected could have the potential to
lead to a more significant safety concern. Traditional enforcement does not apply because the issue did not have an actual safety consequence or the potential for impacting NRCs regulatory function, and was not the result of any willful violation of NRC requirements. The inspectors performed a Phase 1
SOP evaluation in accordance with
IMC 0609, Appendix G. There were no conditions indicating a loss of control as listed in Table 1 .Losses of ControL Attachment 1, Checklist 1
PWR Hot Shutdown Operation: Time to Core Boiling <2 Hours guidelines were used to evaluate the event. All mitigating capabilities were available, therefore a Phase 2 quantitative assessment was not required. The issue screens to Green (very low safety significance). Because this finding is of very low safety significance and has been entered into
FENOCs corrective action program (CR 09-68214), the violation is being treated as a non-cited violation. The cause of this finding is related to the cross-cutting area of human performance, resources, in that procedures for
RHS system shutdown were not complete and up to date.
H.2(b)