LER-2012-002, Regarding Technical Specification (TS) Prohibited Condition Caused by New Fuel Assemblies Stored in a Configuration Prohibited by the TS |
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10 CFR 50.73(a)(1), Submit an LER, Invalid Actuation
10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
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| 2472012002R00 - NRC Website |
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-Entergy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Yý 10511-0249 Tel (914) 254-6700 John A. Ventosa Site Vice President NL-1 2-046 April 13, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001
SUBJECT:
Licensee Event Report # 2012-002-00, "Technical Specification (TS)
Prohibited Condition Caused by New Fuel Assemblies Stored in a Configuration Prohibited by the TS" Indian Point Unit No. 2 Docket No. 50-247 DPR-26
Dear Sir or Madam:
Pursuant to 10 CFR 50.73(a)(1), Entergy Nuclear Operations Inc. (ENO) hereby provides Licensee Event Report (LER) 2012-002-00. The attached LER identifies an event where there was a Technical Specification (TS) prohibited condition due to new fuel assemblies placed in a configuration in the Spent Fuel Pit not permitted by the TS$ which is reportable under 10 CFR 50.73(a)(2)(i)(B). This condition was recorded in the Entergy Corrective Action Program as Condition Report CR-1P2-2012-01019.
There are no new commitments identified in this letter. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.
Sincerely, cc:
Mr. William Dean, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point 2 Mrs. Bridget Frymire, New York State Public Service Commission LEREvents@inpo.org
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Abstract
On February 17,
- 2012, a Fuel Transfer Form preparer. using Technical Specification (TS) 3.7.13 (Spent Fuel Pit Storage) as a reference, recognized an error in the Transfer Form (2-TF-2012-004) that had allowed 11 fresh fuel assemblies (FA) to be moved into the Spent Fuel Pool (SFP) on January 23 thru 24,
- 2012, in Region 1-1 locations in a face-adjacent location to spent FAs.
This configuration was not permitted by TS 3.7.13, which requires empty cells in between the Region 1-1 checkerboard locations of fresh fuel.
The direct cause was that Reactor Engineering (RE) move sheets issued in January 2012 were incorrect.
The root cause was weak/ineffective use of Human Performance (HP) tools during preparation and verification of the move sheets.
Both the preparer and verifier did not review TS 3.7.13 in its entirety.
The error was a result of poor self and peer check/review, overconfidence during performance of the task and weak supervisory oversight due to failure to perform a pre-job brief.
Corrective actions included preparation of a new Transfer Form, disciplinary action which'suspended qualifications of the preparer and verifier, performance of a Level 1 HP error review and stand-down to reinforce expectations for TS compliance, and performance of a HP Engineering Department clock reset.
Training will be developed to reinforce expectations of TS compliance and independent verification and self checking.
The event had no significant effect on public health and safety.
(it more space is required, use additional copies of (if more space is required, use additional copies of (if more space is required, use additional copies of NRC Form 366A). (17)
Past Similar Events A review was performed of the past three years of Licensee Event Reports (LERs) for events reporting a TS violation due to weak/ineffective use of Human Performance tools.
No LERs were identified for actions associated with the SFP or new fuel movements.
The following LERs were identified with causes due to inadequate use of Human performance tools: LER-2010-005, and LER-2012-001.
LER-2010-005 reported a TS prohibited condition due to discovery of a normally open Control Room Ventilation System inlet damper closed. The apparent cause was Human Performance tools were not applied to ensure work activities did not affect other equipment in the area.
Corrective action was coaching and a brief on lessons learned and management expectations on use of human performance tools.
LER-2012-00l reported a TS prohibited condition as a result of a Fuel Oil Storage Tank below the TS required level due to a lack of questioning attitude and understanding by the operations watch station field personnel.
Corrective action included coachingon management's expectations on use of Human Performance tools and lessons learned.
The coaching actions on use of human performance tools would not have prevented this event as the personnel were different (RE).
Safety Significance
This event had no significant effect on the health and safety of the public. The mis-position of FAs did not create a criticality risk due to the minimum.TS required boron concentration of the SFP.
The SFP criticality analysis (NET-173-01) took credit for a limited amount of boron in the SFP water (768 ppm) and allowed for the effects of fuel mis-positioning.
The limiting boron concentration in this case (1495 ppm) was exceeded by the minimum TS required boron concentration (2000 ppm) and was far exceeded by the*
actual boron concentration (2300 ppm).
A radiation monitor is located in the Fuel Storage Building. The monitor provides continuous indication of the radiation level with high radiation alarm given both locally and in the Control Room.
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