Event Notification Report for November 30, 2007

POTENTIAL LOSS OF ITEM RELIED ON FOR SAFETY (IROFS)

"Reason for Notification: On 11/30/07, during a routine NCS facility walkthrough assessment performed by a qualified NCS Engineer, it was discovered that the SNM mass balance maintained for the Chemical Process Development Laboratory (CPD Lab) had been performed incorrectly. Specifically, although the applicable inventory form and associated mass limit for the lab was in terms of grams of SNM (i.e., grams of UO2), cans of archive pellets brought into the lab had been recorded in terms of grams of 235U (underestimating the total lab mass).

"As a result, the total inventory of the lab was actually at approximately 39 kg UO2 (assuming the 2007 annual nominal plant enrichment of 4.38 wt%). This value exceeds the lab mass limit of 15.9 kg UO2, designated an Item Relied on for Safety (IROFS) in the Laboratory ISA Summary (CHMDEV-101).

"Notification is being made based on the potential for Loss or degradation of IROFS that result in failure to meet the performance requirements of 10CFR70.61, reference Appendix A, Section (b)(2) to Part 70 of 10CFR70.

"Safety Basis: The total inventory of the lab was at approximately 39 kg UO2 (assuming the 2007 annual nominal plant enrichment of 4.38 wt%). This value exceeds the lab mass balance limit of 15.9 kg UO2 (based on the single parameter mass limit for UO2 and water). Although criticality in the lab is judged to be incredible, a mass limit was established for the lab, and a mass balance was initiated to enforce it. This mass balance was designated an IROFS in the Laboratory ISA Summary (CHMDEV-101).

"Criticality in the CPD Lab is judged to be an incredible event because no routine process operations are performed in the lab, and special evolutions (for testing or product development) require explicit Criticality Safety Evaluations. The vast majority of SNM currently in the lab is in the form of mounted archive pellets in small (~1 gallon) metals cans stored on the floor of the lab. These cans are being stored there temporarily until a new grinder can be installed to dispose of them.

"Although the mass limit was exceeded in the lab, no potential for criticality existed, as the SNM was stored in sealed metal cans with limited moderation (provided by plastic mounting material). In addition, per CN-CRI-06-30, it requires more than 27 fully loaded and optimally moderated pellet cans to challenge the CFFF acceptance criterion of 0.98, even with multiple stacked cans and optimal spacing. In reality, there are only 15 pellet cans in the lab, and these are stored in a single planar array with 12 inch surface-to-surface spacing.

"Summary of Activity: The archive pellet cans have been removed from the lab, such that the total mass balance in the lab is now below the mass limit for the lab. The event was documented in the plant Corrective Action Process (CAPs #07-334-C025). A new Criticality Safety Evaluation for the CPD Lab (CSE-18-D) was issued on October 16, 2007, and is scheduled for implementation during December 2007. Although this new CSE still concludes that criticality in the lab is incredible, it established additional controls on maintaining the mass balance and special periodic Assessments of the mass balance by the NCS Function.

"Conclusions: Problem was self identified by Westinghouse personnel during a scheduled NCS Facility Walkthrough Assessment. At no time was the health or safety to any employee or member of the public in jeopardy. No exposure to hazardous material was involved. A causal analysis will be performed.

The licensee will notify the NRC Resident Inspector.

MANUAL HPCI ISOLATION DUE TO STEAM LEAK INCREASE

"At 1052 on 11/30/2007 while in Mode 3 for a maintenance outage, a previously identified steam leak on the packing of valve 3-FCV-073-0006A, HPCI Steam Line Condensate Inboard Drain Valve, increased. The room temperatures were not rising at the time of the increased leakage, alleviating the potential automatic isolation of the system. Upon review of the condition, the Operations staff closed the steam isolation valves and declared HPCI INOPERABLE to minimize the spread of contamination in the area. After HPCI was isolated, inspection of the valve identified a Code Class 2 piping through wall leak on a tee upstream of 3-FCV-073-0006A which contributed to the increased leakage observed prior to isolation of the system.

"This event is reportable as an 8-hour Non-Emergency Notification in accordance with 10CFR50.72 (b)(3)(v)(B) as; 'Any event or condition that at the time of discovery could have prevented the fulfillment of the Safety Function of structures or systems that are needed to: Remove Residual Heat'; and 10CFR50.72(b)(3)(v)(D), 'any event or condition that at the time of discovery could have prevented the fulfillment of the Safety Function of structures or systems that are needed to: mitigate the consequences of an accident.'

"This event also requires a 60 day written report in accordance with 10CFR 50.73(a)(2)(v)(B) and 10CFR 50.73(a)(2)(v)(D)."

The Code Class 2 piping leak was on a tee for the steam trap bypass valve upstream of the HPCI Steam Line Condensate Inboard Drain Valve.

The licensee notified the NRC Resident Inspector.