05000244/LER-2010-001, Re Two Fuel Assemblies Identified in Incorrect Spent Fuel Pool Locations Following Database Upgrade

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Re Two Fuel Assemblies Identified in Incorrect Spent Fuel Pool Locations Following Database Upgrade
ML100680124
Person / Time
Site: Ginna 
Issue date: 03/04/2010
From: John Carlin
Constellation Energy Group, EDF Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 10-001-00
Download: ML100680124 (7)


LER-2010-001, Re Two Fuel Assemblies Identified in Incorrect Spent Fuel Pool Locations Following Database Upgrade
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)

10 CFR 50.73(a)(2)(vii), Common Cause Inoperability

10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded

10 CFR 50.73(a)(2)(viii)(A)

10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition

10 CFR 50.73(a)(2)(iii)

10 CFR 50.73(a)(2)(ix)(A)

10 CFR 50.73(a)(2)(iv)(A), System Actuation

10 CFR 50.73(a)(2)(x)

10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor

10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat

10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown

10 CFR 50.73(a)(2)(v), Loss of Safety Function

10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2442010001R00 - NRC Website

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John Carlin Site Vice President CENG a joint venture of constellation

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R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax iohn.carlin(ccenqlic.com March 4, 2010 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:

SUBJECT:

Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 LER 2010-001, Two Fuel Assemblies Identified In Incorrect Spent Fuel Pool Locations Following Database Uparade The attached Licensee Event Report (LER) 2010-001 is submitted under the provisions of NUREG 1022, Event Reporting Guidelines. There are no new commitments contained in this submittal. Should you have any questions regarding the information in this letter, please contact Mr. Thomas Harding at (585) 771-5219.

Attachments: (1) LER 2010-001 cc:

S.J. Collins, NRC D.V. Pickett, NRC Resident Inspector, NRC (Ginna)

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ATTACHMENT 1 LER 2010-001 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2010 (9-2007)

, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME R.E. Ginna Nuclear Power Plant
2. DOCKET NUMBER
3. PAGE 1 05000 244J1 1 OF 5
4. TITLE Two Fuel Assemblies Identified In Incorrect Spent Fuel Pool Locations Following Database Upgrade
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR I

DOCKET NUMBER NUMBER NO.

05000 I I

_I

__FACILITY NAME DOCKET NUMBER 01 07 2010 2010 - 001 -

0 03 05 2010 05000

9. OPERATING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply)

[:l 20.2201 (b)

El 20.2203(a)(3)(i)

El 50.73(a)(2)(i)(C)

[1 50.73(a)(2)(vii)

El 20.2201(d)

El 20.2203(a)(3)(ii)

El 50.73(a)(2)(ii)(A)

El 50.73(a)(2)(viii)(A)

El 20.2203(a)(1)

[I 20.2203(a)(4)

El 50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(A)

[I 20.2203(a)(2)(i) l 50.36(c)(1)(i)(A)

El 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

10. POWER LEVEL El 20.2203(a)(2)(ii)

El 50.36(c)(1)(ii)(A)

El 50.73(a)(2)(iv)(A)

[E 50.73(a)(2)(x)

[I 20.2203(a)(2)(iii)

[I 50.36(c)(2)

[I 50.73(a)(2)(v)(A) 0l 73.7.1(a)(4)

El 20.2203(a)(2)(iv) 0l 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(B)

El 73.71(a)(5) 47%

El 20.2203(a)(2)(v)

El 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER El 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)

[E 50.73(a)(2)(v)(D)

Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (include Area Code)

Thomas Harding, Licensing Director (585) 771-5219MANU-REPORTABLE

CAUSE

COMPONENT MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT FACTURER TO EPIX

CAUSE

TO EPIX A

DB N

A

14. SUPPLEMENTAL REPORT EXPECTED
15. EXPECTED MONTH DAY IYEAR

.SUBMISSION E] YES (If yes, complete 15. EXPECTED SUBMISSION DATE) 0 NO DATE On January 7, 2010, during review of fuel moves in the Spent Fuel Pool (SFP) in preparation for a fuel assembly canister sipping evolution, Reactor Engineering personnel identified that two fuel assemblies were misclassified per Technical Specifications (TS) Limiting Condition for Operations (LCO) 3.7.13 and stored in incorrect locations.

Event investigation identified that both assemblies, utilizing the 2001 methodology, had been placed in their correct storage location when last positioned in 2001. In 2005, the fuel database was migrated, updated and minor assembly burnup adjustments were made utilizing specific weights for each fuel assembly, resulting in a small (< 1%) change in the burnup of several early regions of fuel assemblies. At the time of the change, this was considered insignificant and was not evaluated against TS 3.7.13 figures.

The upgraded database shifted the assemblies' burnups from slightly above the fuel classification line, to slightly below.

The two fuel assemblies were relocated to assure compliance with LCO 3.7.13 on January 8, 2010. An additional corrective action includes completion of fuel burnup validation and reconciliation calculations.

Based on the multiple conservatisms in the criticality analysis, the minor change in the calculated burnup, and the considerable margin in the soluble boron concentration in the spent fuelrpool, there was no nuclear safety consequence caused by this event.

NRC FORM 366 (9-2007)U.S. NUCLEAR REGULATORY COMMISSION (9-2007)

LICENSEE EVENT REPORT (LER)

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE I

ISEQUENTIAL REV R.E. Ginna Nuclear Power Plant YEAR NUMBER NO.

05000244 2010

--001 00 2

of 5

1.

DESCRIPTION OF EVENT

A.

PRE-EVENT PLANT CONDITIONS:

The reactor was in Operational Mode 1 at 47% power, 2235 psig and 558 degrees F. Power ascension was in progress following a plant trip due to loss of turbine electro-hydraulic fluid pressure on 12/30/2009.

B.

EVENT:

Two fuel assemblies, D05 and D17 were found to be misclassified per TS LCO 3.7.13 and stored in disallowed configurations within the SFP. The assemblies were previously classified correctly prior to a large pool reconfiguration in 2001 to support revised TS storage requirements. These classifications were performed with data from the Nuclear Fuel Accounting Code (NFAC), the in-house code used at Ginna since original plant startup to process data and report burnup and isotopic data for individual fuel assemblies.

In response to NRC Bulletin 2005-01, "Material Control and Accounting at Reactors and Wet Spent Fuel Storage Facilities", Ginna retrieved and reconciled documentation for all prior fuel received. Changes in reporting for the Nuclear Materials Management and Safeguards System (NMMSS) required Ginna to retire the NFAC system and use a spreadsheet for calculations.

NFAC data for each assembly was recorded as Mega-Watt Days (MWD) generated, Metric Tons Uranium (MTU), and resulting burnup in MWD/MTU. Assembly MTU values in NFAC were historically entered as region average (i.e., the total MTU in all assemblies for the region divided by the number of assemblies) for the first few fuel batches.

After retirement of NFAC, Reactor Engineering personnel elected to use MWD generated by each assembly and assembly specific weights, since this information was available. This was a onetime reconciliation to support NMMSS reporting. At this time reactor engineering personnel recognized there were minor changes (<1%) in the assemblies' burnups with some increasing while others decreased. Surveillance Requirement 3.7.13 was not performed for each assembly in the SFP using the new data at this time since it was not foreseen that such a small change would result in a change in the fuel category. However, this change resulted in a shift from slightly above the fuel classification line, to slightly below as shown in TS LCO 3.7.13. This was identified on January 7, 2010 when Reactor Engineering personnel were performing verifications in support of Independent Spent Fuel Storage Installation (ISFSI) fuel sipping activities. Immediate actions were initiated to move the fuel assemblies to the correct locations.

Fuel assemblies D05 and D17 were placed in the proper locations and TS LCO 3.7.13 was exited on January 8, 2010.U.S. NUCLEAR REGULATORY COMMISSION (9-2007)

LICENSEE EVENT REPORT (LER)

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE SEQUENTIAL REV R.E. Ginna Nuclear Power Plant YEAR NUMBER NO.

05000244 2010

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C.

INOPERABLE STRUCTURES, COMPONENTS OR SYSTEMS THAT CONTRIBUTED TO THE EVENT:

None D.

DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES

2001 2005 01/07/2010 1814 SFP Reconfiguration performed Database change for calculating fuel burnup Reactor Engineering personnel identified error and immediately initiated compensatory validation of other fuel assemblies Fuel moves complete - LCO 3.7.13 satisfied 01/08/2010 1545 E.

OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED

None F.

METHOD OF DISCOVERY

Reactor Engineering personnel were preparing for fuel sipping activities in support of the ISFSI project.

G.

MAJOR OPERATOR ACTION:

Operations personnel entered LCO 3.7.13 action to move the non-complying fuel assemblies to acceptable storage locations.

H.

SAFETY SYSTEM RESPONSES:

No safety systems actuated or were required to respond to this event.

I11.

CAUSE OF EVENT

This event falls under NUREG-1022 Cause Code A, Personnel Error.

This event was entered into the site corrective action program (CR-2010-000194). The cause of the event was due to the Reactor Engineer not recognizing the potential to impact LCO 3.7.13 classification changes when the database changes were made in 2005 to incorporate "best available" data. While the engineer understood the TS requirements, there was no specific action that would have prompted the performance of the surveillance activity following the database upgrade.U.S. NUCLEAR REGULATORY COMMISSION (9-2007)

LICENSEE EVENT REPORT (LER)

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE SEQUENTIAL I

REV R.E. Ginna Nuclear Power Plant YEAR I

NUMBER NO.

05000244 2010

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III

ANALYSIS OF THE EVENT

This event is reportable in accordance with 10 CFR50.73, Licensee Events Report System under item (a)(2)(i)(B) based on a condition prohibited by Technical Specifications An assessment was performed considering both the safety consequences and implications of this event with the following conclusions:

Soluble boron credit methodology was originally employed to establish a target Keff value of 0.98051 for the spent fuel pool at zero soluble boron. The allowance for biases and uncertainties is determined to be 0.01592 providing an upper limit on Keff of 0.99643. The changes identified in fuel weight were within the inherent uncertainties of the calculation. Based on current calculations and acceptance criteria, total boron concentration required to meet Keff of <= 0.95 is 975 ppm, including all uncertainties. Ginna Technical Specifications require >2300ppm in the spent fuel pool. Therefore at no time would Keff have increased to greater than 0.95 since the 2001 reconfiguration. If the SFP were flooded-with unborated water, there is no realistic probability that Keff would have increased to

>0.99643.

Based on the above considerations, the nuclear safety consequences of this event are very low.

This event does not have any impact on NRC performance indicators.

IV

CORRECTIVE ACTIONS

A.

ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:

Fuel assemblies D05 and D17 were relocated in compliance with LCO 3.7.13.

B.

ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE Note: There are no regulatory commitments in this Licensee Event Report LonQ Term Corrective Actions:

Reactor Engineering personnel will complete fuel burnup validation and reconciliation calculations. This will document Surveillance Requirement (SR) 3.7.13 for current fuel configuration in the SFP. Additional corrective actions associated with the human performance weaknesses are documented in the site Apparent Cause Evaluation.U.S. NUCLEAR REGULATORY COMMISSION (9-2007)

LICENSEE EVENT REPORT (LER)

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE R.E. Ginna Nuclear Power Plant YEAR NUMBER NO.

105000244 2010

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V.

ADDITIONAL INFORMATION

A.

FAILED COMPONENT None B.

PREVIOUS LERS ON SIMILAR EVENTS A review of Ginna events over the past five years identified the following similar events:

LER 2004-002 Consolidated Rod Storage Canister Placed in Incorrect Storage Location C.

THE ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO IN THIS LER:

IEEE 803 FUNCTION IDENTIFIER IEEE 805 SYSTEM INDENTIFICATION COMPONENT D05 D17 N/A N/A DB DB D.

SPECIAL COMMENTS None