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
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 _______________________________________________ PWRRM mailing list PWRRM@retaqs.com http://www.keffective.com/mailman/listinfo/pwrrm
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Level 3 example "Mislocated fuel assembly in spent fuel pool (that violates reactivity constraints)." would apply. The other example that could be applied under Level 2 is "Entry into reactivity-related technical specification Action Statement and not corrected within TS time requirements.". If your TS action statement is the same as Beaver Valley's the requirement is "immediately", but this is based on discovery, so this would probably not apply.
The event may also be elevated based on "contributing circumstances, such as a repeat of a lower level event... event severity...". Since this was only recently identified, I would not consider this a repeat event per the reactivity management guidelines. My opinion would be a Level 3 reactivity event, with possibly Level 2 based on the severity of the event, i.e. were there several assemblies violating the TS or just 1-2.
As for not penalizing the PI, I don't see how you can avoid it. I would only count this as one event since you did not know you violated the TS until recently.
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
"Sanders, Gene Jr" <Gene.Sanders@duk To e-energy.com> "pwrrm@retaqs.com" Sent by: pwrrm@retaqs.com pwrrm@retaqs.com cc
Subject 07/10/2009 10:46 [Pwrrm] RM Event Classification and AM Performance Indicator
Please respond to PWR Reactivity Management <pwrrm@retaqs.com >
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 _______________________________________________ PWRRM mailing list PWRRM@retaqs.com http://www.keffective.com/mailman/listinfo/pwrrm
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Sanders, Gene Jr