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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