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