This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the
Enforcement Policy.Violation:
Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of
Regulatory Guide 1.33, Revision 2. Section 6 of Appendix A to
Regulatory Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant events. The licensee established Emergency Operating Procedure (
EOP)
ES-0.2, Natural Circulation Cooldown, Revision 9, in part, to meet the regulatory requirement. Figure 1 of
ES-0.2 allowed cooldown rates that exceeded the values used in the license basis for radiological consequence analyses and exceeded the values used in the design of the
nitrogen accumulators for atmospheric steam dumps and turbine-driven
auxiliary feedwater system actuations. This issue was discussed in Licensee Event Report 2018-002-00, Inadequate
EOP Guidance for Asymmetric Natural Circulation Cooldown
Contrary to the above, from April 29, 2008 through May 7, 2018, the licensee failed to maintain procedures for combating emergencies and other significant events. Specifically, the licensee failed to maintain
EOPs for natural circulation cooldown. This performance deficiency resulted in atmospheric steam dumps and turbine-driven
auxiliary feedwater systems being rendered inoperable due to depletion of the safety-related actuation
nitrogen.
