AECM-90-0081, Responds to NRC Re Violations Noted in Insp Rept 50-416/90-03.Corrective Actions:Valves Closed,Effectively Isolating Flow of Contaminated Water Into Makeup Water Sys & Demineralized Water Sys Flushed & Cleaned of Contamination

Responds to NRC Re Violations Noted in Insp Rept 50-416/90-03.Corrective Actions:Valves Closed,Effectively Isolating Flow of Contaminated Water Into Makeup Water Sys & Demineralized Water Sys Flushed & Cleaned of Contamination

ML20042F179
Person / Time
Site:	Grand Gulf
Issue date:	04/30/1990
From:	Cottle W SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AECM-90-0081, AECM-90-81, NUDOCS 9005070346
Download: ML20042F179 (4)

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- William T. Cottle vice Presdent N41 car operatons April 30, 1990 e

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-U.S. Nuclear Regulatory Commission Mail Station PI-137 Washington, D.C.

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Attention: Document Control Desk ~

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t-Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 i.

Docket No.-50-416 License.No. NPF 99 Report.No. 50-416/90-03, dated 4/02/90 (MAEC-90/0079)'

AECM-90/0081 System Energy Resources, Inc. hereby submits response to violation-50-416/90-03-01.

Yours truly,1 WTC:cg R a h

Attachment cc:

Mr. D. C. Hintz (w/a)

Mr. T. H. Cloninger (w/a)

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Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr.

H'. O. Christensen (w/a)

Mr. Stewart D. Ebneter (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission

-1 Regien II 101 Marietta St., N.W.,' Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner,. Project _'M&neger (w/a) f Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission l:

Mall Stop 14B20 Washington,.D.C.

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Attach'.ent to AECH-90/0081-G

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l Notice of Violation 90-03-01' l

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Technical Specification 6.8.1.a requires written procedures be established,

.l impleme.nted, and maintained covering the activities recommended in Appendix

- A of Regulatory Guide 1.33, Revision 2, February 1978..

Regulatory-Guide 1.33, Appendix A, recommends procedures forL the startup, operation and shutdown of safety-related BWR systems for the fuel storage pool purification and cooling system and the makeup system (filtration, purification and water. transfer). Additionally, an administrative procedure is recommended for proceduto adherence.

b Administrative Procedure 01-S-06-2, Conduct of Operations, step 6.2.7.d.

requires tne Nuclear Operator B (NOB) to coordinate operations with other-

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s personnel and ensure the control room operator and shift superintendent are

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kept informed of equipment and system status.

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System Operating Instruction 04-1-01-G41-1, Fdel Pool Cooling and~ Cleanup System, Attachment I, manual-valvo lineup checksheet, requires valves G41F216 (Demin water to cask washdown) and G41F217 (Condensate to cask washdown) be closed.

l System Operating Instruction 04-S-01-P21-1, Makeup Water Treatsent System, provided direction for performing system operations.

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System Operating 'Irstruction 04-1-01-P11-1, Condensate Storage and Transfer,

System, provides directions for performing system operations.

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Contrary to the above, the system operating procedures were-inadequate in that on March 1, 1990, an operator opened condensate valve G41F217 while j

o makeup water valve G41F216 was opened. Additionally, the operator.-failed to j

inform the control room of his actionn. This resulted'in the contamination l

of the makeup water system and the unmonitored release of radioactive l

effluent to unrestricted areas.

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Admission Or Dynial Of The Alleged Violation 1

System Energy Resourcea, Inc. admits to the alleged violation.

This-violation had no effect.on the health and safety of the pubile.

4 II.

The Reason For The Violation If Admitted 1

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System Operating Instruction 04-1-01-G41-1, Fuel. Pool Cooling and j

Cleanup System, provided instructions;for refueling cask washdown activities by opening the condensate to cask washdown valve (G41-F217) or the domineralized water to cask washdown valve (G41-F216) to spray down the cask en necessary.

Ilowever, it did not adequately address,

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nor alert operators to the fact that if both valves are opoued simutaneously, cross-contamination of.ha two systems would occur.

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]s Additionally, System Operating Instruction 04-S-01-p21-1,. Makeup Water Treatment System did not provide specific guidelines for use of the

.j system (p21) for plant servicing activities, 1;e., flushing and cleaning operations.

These inadequate procedural controls contributed significantly to this' l

incident.

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The change in system status, as required by procedure 01-S-06-2, Conduct of Operations, was not reported to appropriate control room-personnel due to the failure'of the_ auxiliary building operator to j

t perform an adequate self-verification prior to operating the valves.

Had the operator-performed'an adequate self-verification, he would have i

recognized that the task he was asked to perform was more involved than

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expected and the Control Room should have been contacted'for further

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- instructions before manipulating the valves.

1 III. Corrective Steps-Which Have Been Taken And The Results A,chieved k_

i The following Corrective Actions have been taken in direct response to this incident:

a 1.

Valves G41-F216 and G41-F217 were closed, effectively isolating j

h-the flow of contaminated water into the Makeup Water System i

(p21).

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A Management Task Team was assembl'd to review the event an'd

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establish corrective-actions.

Potential release points were-isolated, sampling points were established, and a discharge estimate was developed. This evaluation concluded that'the maximum possible radioactive content of the release was'less i

than 10CFR20 limits.

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The Demineralized Water System was flushed and cleaned of all r

r traces of contamination.' Samples from appropriate points later showed no signs of contamination.

4.

An extensive effort was launched to identify additional-i locations where similar\\ cross-connections ~between the; y

Domineralized Water Storage System'and the Condensate Water Storage and Transfer System could occur.

These points were l

E identified and caution signs placed on the valves to alert' personnel of,the potential for contaminating a,normally' non-contaminated system if,the respective valvd is opened.

5.

System Operating Instructions (SOI) 04-S-01-p21-1.was changed to',

provide guidolines for documenting installation and removal of sJ hoses to the P21' System when used for plant' servicing. The f

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Shif t Superintendent /Superviaor is' also required to be ' notified a

prior tof installing future hose connections.

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A caution statement was'added to SOI 04-1-01-G41-1,' Fuel pool Cooling and Cleanup System,.to warn operators that opening >

valvos F216 and~F217 at the same time will cause:

i cross-contamination of P11 and p21 systems.

7.

The operator involved in this incident wasLindividually counselled on thisiincident and the importance of performing an adequate self-verification.

Shift Superintendents were directed,1via a memo from the Operations Superintendent. to q

provide documented training of this incident and the standard.

l for.self-verification to all shift personnel..

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The Corrective Steps Which Will Be Taken To Avoid Further Violations i l,

.SERI'is. evaluating the' feasibility of a"DesignDChange'to modifyithe j

Demineralized, Water' System (P21) and thelCondensato and Refueling Water' Storage and Transfer System (P11), cross-connection. points to prevent ~

future contamination of.the P21 system.

1-V.

Date When Full-Ccmpliance Will Be-Achieved!

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SERI will, upon evaluation of1the above change,1take necessary actions to ensure implementation of required changes.:. Modifications will be implemented by Refueling Outage Number Si(RF05) as deemed appropriate.

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