ML17326A700

Forwards Response to NRC Re Violations Noted in IE Insp Repts 50-315/80-04 & 50-316/80-03.Corrective Actions:Procedure Changed to Prohibit Use of Hoses for Making Up Water to Spent Fuel Pit & Valves Locked Closed

ML17326A700
Person / Time
Site:	Cook
Issue date:	05/30/1980
From:	Dolan J INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17326A701	List: IR 05000315/1980004 ML17326A700
References
AEP:NRC:00413, AEP:NRC:413, NUDOCS 8007310284
Download: ML17326A700 (6)

Text

INDIANA L MICHIGAN ELECTRIC COMPANY P. O. BOX 18 80 WLIN0 OR E EN ST ATION NEW YORK, N. Y. 10004 Donald C.

Cook Nuclear Plant Units No.

1 and 2

Docket Nos.

50-315 and 50-316 License Nos.

DPR-58 and DPR-74 IE Inspection Reports No. 50-31'5/80-04 and No. 50-316/80-03

Response

to Notice of Violation May 30, 1980 AEP:NRC:00413 Mr. James G. Keppler, Regional Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

The Attachment to this ')etter is our response to the Notice of Violation cited in Appendix A to Mr. R. F. Heishman's letter of May 2, 1980.

On May 23, 1980 our Dr. Castresana obtai.ned an extension to the due date of this submittal until May 30, 1980 from your Mr. Heishman.

Very truly yours, ohn E. Dolan ice President JED:dfs Attachment cc:

R.

C. Callen G. Charnoff RE S.

Hunter R.

M. Jurgensen D. V. Shaller - Bridgman 2

'980

gP e r+

ATTACHMENT TO AEP:NRC:00413 y<o>ation 1

Technical Specification 6.8.1 requires implementation of procedures,.

12-0HP-4021.018.004 "Draining or Adjusting Level in the Spent Fuel. Pit" details the procedure for raising level in the SFP.

'ontrary to the above, this procedure was not used for increasing lev'el in the SFP between March 15, 1980 and March 17, 1980, when the pool was overfilled and cross-contamination of'the demineralized water system occurred.

~Res ense:

During the fuel storage rack modification, demineralized water was being used at the spent fuel pit for two purposes:

1) as a supply of clean water for decontamination of the old racks being removed, and

2) as a source of priming water for a vacuum pump used for cleaning the spent fuel pit floor.

The demineralized water system contamination investigation revealed that the cross contamination of the demineralized water header occurred through.the hose connection used for the vacuum pump priming:

The one end of the hose was found disconnected from the vacuum pump and the free end left hanging submerged in the spent fuel pit. It is believed that the shut off valve at the demineralized water header hose connection had been left open.

This would permit water to flow into the pit whenever the demineralized water booster pump was running.

The booster pump is required to supply water at this elevation.

When the booster pump was shut down, the low header pressure would. permit water to be siphoned from the spent fuel pit into the demineralized water header.

The daily spent fuel pit level readings show a gradual increase in level until the spent fuel pit was found overflowing into the fuel transfer canal.

The level was then lowered in accordance with approved procedures.

During the time leading up to the cross contamination of the demineralized water header and the overflowing of the spent fuel pit, there was no intentional action to raise the level in the spent fuel pit and therefore the citation for failure to use an approved procedure for increasing the level does not seem warranted.

It is felt that the root cause for this entire incident, the increase in spent fuel pit level, the dilution of the boron concentration below the required minimum, and the cross contamination of the demineralized water header, can be attributed to a breakdown in the control of the activities associated with/ the spent fuel rack modification.

Positive steps have been taken, as indicated below, to prevent the re-occurrence of a similar event.

pctions Taken to Prevent Re-Occurence A precaution has been added to Procedure 12-0HP-4021-018.004 to prevent the use of hoses for making up water to the spent fuel pit.

2.

3.

The demineralized water valves in the vicinity of the spent fuel pit have been locked closed with Operations Department padlocks.

This will assure notification of the operators prior to future use of these valves.

Check valves have been installed at the demineralized water outlets in the vicinity of the spent fuel pit to prevent backflow and cross-contamination of the demineralized water system.

s Controls have been imposed on the use of.demineralized water from Laboratories for human consumption purposes.

Violation 2:

Amendment 832 to NRC Operating License Number DPR-58 and

'mendment 8]3 to DPR-74 require a minimum of 2000 ppm Boron concentration in the Spent Fuel Pit during changeout from old racks to new high density fuel storage. racks.

Contrary to the above, on March 17, 1980, the SFP concentration was found to be less than 2000 ppm (1954 ppm).

~Res ense:

The dilution of the spent fuel pit resulted from the un-intentional addition of water to the spent fuel pit as described in Violation 1.

Corrective actions were immediately initiated to increase boron concentration to greater than 2000 ppm upon discovery of the low concentrati on.

s Actions Taken to Prevent Re-Occurence

'he specific requirements of Amendment 832, to NRC Operating License DPR-58 and Amendment 5'13 to DPR-74, requiring a minimum of 2000 ppm boron in the spent fuel pit, no longer exist since the spent fuel storage rack modification 'is now complete.

The prevent)ve actions discussed under Violation 1 apply generically to this condition.

JUN 2

~gap