Beaver Valley responses below
Anthony (A.R.) Burger
Supervisor, Reactor Engineering
FENOC - Beaver Valley Power Station
Phone: (724) 682-4108
Cell: (724) 601-3224
FAX: (724) 682-4250
Email: aburger@firstenergycorp.com
From:
<edward.mcvey@exeloncorp.com>
To:
<pwrrm@retaqs.com>,
<jeffrey.dunlap@exeloncorp.com>
Date:
06/13/2011 09:37 AM
Subject:
[Pwrrm] SNM
Inventory Practice Benchmark Survey
Sent by:
pwrrm@retaqs.com
SNM Industry Peers,
Please review the SNM
Inventory event summarized below and
respond with answers to the short Benchmark
Survey that follows.
Event Summary
During the Triennial NRC MC&A
Inspection, the inspector identified an error in the Byron 2010 Annual
SNM Inventory. The inventory report misidentified the position of
two normally inaccessible storage locations in the SFP V rack. Inaccessible
locations VA05 & VB05 were mismarked as containing fuel, while VA04
& VB04 which contained fuel were identified as empty. The error
did not impact the inventory result (ie total piece count).
Error Precursors
Repetitive Actions / Monotony
- The SFP inventory consists
of documenting fuel locations in thousands of pool storage cells. The
SFP at Byron is nearly full, and the monotonous task requires repeated
counting of rows and columns in the racks. A loss of focus resulted
in mismarking two locations.
Failed Defenses
Self Check / STAR
- The error originated with the
performer in the field. The error was not detected during the Review
step of STAR or during comparison of the field result with the expected
TracWorks configuration. The large number of assemblies (>2400)
made the task susceptible to recording errors and also made errors difficult
to detect.
Peer Check
- The peer check in the field
failed to detect the error for likely the same reason as STAR. A
peer check of the comparison with TracWorks was not performed because it
was procedurally not required, and the peer was not available following
the field activity.
1. How
does your site document Location/Piece Count inventories of the SFP?
- Do you markup blank maps
or printouts from an Inventory Control program? Response - markup blank
SFP maps
- If using blank maps, do
you mark every SFP location, or just the exceptions? (e.g. Only marking
empty cell locations in a mostly full SFP) Response - We mark all locations
as either having a fuel assembly, debris canisters, surveillance coupon,
empty, etc. This is because we also have a requirement at the site
to maintain non-SNM inventory so all cells are mapped.
2.
What
Human Performance tools do you use to ensure an error free inventory?
- Are both a Performer and
Reviewer (Peer Checker) required for the field activity? Response - We
have two personnel complete mapping.
- Do they perform the task
Concurrently or Independently? Response - Concurrently
- Or is a review only conducted
outside of the RCA? Response - Review completed prior to leaving RCA between
the two individuals.
- Is a copy of the expected
configuration available to the Performer/Reviewer during the field activity?
Response - Expected is available in the field but not used until mapping
is completed for final comparison.
- Or is the inventoried reconciled
with the expected configuration only after the field activity? Response
- In field
- Is the reconciliation also
reviewed (peer checked)? Response - Both personnel compare to expected
map.
Please respond to Jeff Dunlap
(jeffrey.dunlap@exeloncorp.com)
by 7/1/2011. Responses will be collected and a summary will be sent
out to all respondents
Thanks for your help
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