ML17326A700

Forwards Response to NRC 800502 Ltr 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 E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	KEPPLER J G 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)

See also: IR 05000315/1980004

Text

INDIANA L MICHIGAN ELECTRIC COMPANY P.O.BOX 18 80 WL IN 0 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 pi t fl oor.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