This event is clearly as I understand it meet the definition of a Level 2 event. If you violated TS, then it is reportable which is the basic definition of a Level 2 event. Also, under the current PWROG Guideline, I believe you have an event worded something like "Fuel Assembly in Fuel Pool that violates reactivity constraints" That is a Level 3 event, but again, if you determined it was reportable due to not meeting Tech Specs, that makes it a Level 2.
Also, by the way, under the new RM PI guideline that I just met with INPO yesterday, we have clariifed exactly that, since my determination above does provide a little contradiction between 2 or 3. The Level 2 event that applies here in our new approved PI is:
2-9 Fuel Bundle in the Reactor Core, Spent Fuel Pool, or Dry Cask That Violates Reactivity Constraints
Similarly, Level 3 in the new PI reads:
3-11 Fuel Placement Error in the Spent Fuel Pool or Dry Cask That Does Not Violate Reactivity Constraints
Bottom line, I believe it meets Level 2 under either two versions of the PI. Minimum would be a 3, but if you violated TS, you're in Level 2 space.
Ed McVey
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-----Original Message----- From: pwrrm@retaqs.com [mailto:pwrrm@retaqs.com] On Behalf Of pwrrm-request@retaqs.com Sent: Friday, July 10, 2009 12:00 PM To: pwrrm@retaqs.com Subject: PWRRM Digest, Vol 28, Issue 4
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Today's Topics:
1. RM Event Classification and Performance Indicator (Sanders, Gene Jr)
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Message: 1 Date: Thu, 9 Jul 2009 08:29:25 -0400 From: "Sanders, Gene Jr" Gene.Sanders@duke-energy.com Subject: [Pwrrm] RM Event Classification and Performance Indicator To: "pwrrm@retaqs.com" pwrrm@retaqs.com Message-ID: <22A8474FC8468A439A927EF628FED52B12B821C666@IMCLUSEXCP55.nam.ent.duke-energy .com> Content-Type: text/plain; charset="us-ascii"
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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