The Cook reactivity management procedure cites specific examples of events and lists a mislocated assembly in the SFP as L3. The procedure also states that discretion is allowed to raise or lower the severity and lists repeat offenses and operation beyond licensing bases as potential elevation criteria. So, at Cook, these events would likely be L3, possibly L2 when viewed in aggregate.

Not sure about the PI hit. I assume this was an error in the process controlling move sequence generation or human error? Has the process been corrected? Have you trained the individuals attesting to the configuration compliance? At Cook, our approval checklist requires that three Reactor Engineers and an SRO must agree that a fuel movement sequence is compliant with our Tech Specs.

David Goff
Reactor Engineer
Donald C. Cook Nuclear Plant
269-465-5901 x1465

"Sanders, Gene Jr" <Gene.Sanders@duke-energy.com>
Sent by: pwrrm@retaqs.com

07/09/2009 08:29 AM

Please respond to
PWR Reactivity Management <pwrrm@retaqs.com>

To	"pwrrm@retaqs.com" <pwrrm@retaqs.com>
cc
Subject	[Pwrrm] RM Event Classification and Performance Indicator

Oconee Nuclear Station (Duke Energy) has recently identified in our Problem Identification / Corrective Action program (PIP) where past (>12 months ago) storage configurations in our spent fuel pools were not in full compliance with Tech Specs. These events were encountered during refueling outages and the station was in a noncompliant condition for short periods ranging from a few days to a few weeks before TS compliance was subsequently restored. (It is apparent during these instances that the operators were not aware that a TS noncompliance existed and afterward, the plant was restored to a compliant condition via an "inadvertent compliance" action where a portion of the SFP fuel was reloaded back into the reactor vessel.)

These past occurrences would be characterized as an L4 (or possibly L3) RM event. The questions we request input on are:

1) Should we characterize this current “PIP” as an L4 (or possibly L3) RM event(s) which affects our current RM performance indicator (PI), and if not
2) What justification / interim actions would be deemed required / appropriate to avoid penalizing our RM PI, (i.e., was this type of scenario, discovery of past events, addressed during the development of the PWR RM PI?)

Thanks in advance for your response,

T E (Gene) Sanders
ONS Rx Engineering
864.873.3377
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