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
| 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).
2.
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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6.
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..
'L IV..
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.
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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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