ML20031D625
| ML20031D625 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/02/1981 |
| From: | Blanchard D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20031D553 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8110130556 | |
| Download: ML20031D625 (11) | |
Text
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v TESTIMONY OF DAVID BLANCHARD WITH RESPECT TO O'NEILL CONTENTION IIG (b)
The following is a response to O'Neil' Contention IIG (b):
Fuel has escaped the racks and remained undiscovered for a considerable time. Because the design of the new rack does not specifically address this occurance, the design in deficient.
It is asaumed that the " fuel escape" incident mentioned in this Contention is a reference to a fuel rod which was unexpectedly found at the bottom of the fuel pool in October 1973. This incident was reported to the NRC by letters dated November 20, 1973, and May 9, 1974, which are attached.
(Exhibits 1 & 2) As stated by these letters, the fuel rod was apparently misplaced early in 1972 during General Electric fuel inspection activities.
Fuel inspection by the manufacturers of Big Rock Point fuel occurs on an annual basis, generally during refueling outages. General Electric was the fuel fabricator for most of the fuel in Big Rock at that time. During fuel j
inspections, individual fuel bundles are removed one at a time from the storage racks, placed in fuel inspection elevator at the side of the pool disassembled, and individual fuel rods are handled and examined. General Electric's records indicate that the fuel rod in question was reinserted in a corner location of the fuel assembly after the inspection was complete. It is believed the technician handling the fuel rod inadvertently inserted it down along the outside of the fuel bundle rather than into the desired location in the corner of the fuel bundle. When released from the handling tool, the rod fell to the bottom of the pool. The rod remained there until it was discovered a year and one-half later, lying on the east end of the fuel pool floor under the location where the fuel inspections were performed.
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- i b Therefore, the " fuel escape" incident referred to in this Contention was not a result of the design of the spent fuel racks. Fuel rods and bundles cannot by tnemselves move from storage location within the fuel racks, but require manual action through use of special tools designed for the handling of fuel.
The rod remained undiscovered on the bottom of the pool for 20 months, as all records indicated it had been returned to an appropriate location with a fuel assembly. Storage of the rod in this manner was of no consequence as the concrete walls around the bottom and side of the pool are more than sufficient to shield the radiation from a single fuel rod.
This contention therefore reflects a misunderstanding of how the rod was misplaced on the bottom of the feel pool. As removal of fuel fro:n spent fuel rack locations cannot occur without deliberate manual action, consideration of this incident in the design of the racks is not necessary, and the rack design is not considered to be deficient.
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. w, Nove=ber 20, 1973 Re: Docket To 50-155 Mr. John F. O' Leary, Director License No DPR-6 Directorate of Licensing M Nj' US Atomic Energy Con:21ssion F
Washington, DC 20545 n 0 4-
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Dear Mr. O' Leary:
i On October 23, 1973 during draining of the Big Rock Point Plant pool in preparation for the relining of the pool, a spent fuel rod fue]
was unexpectedly found on the pool floor.
Draining procedures were halted and,ttempts were made to iden-Th'e fuel rod was identified as a tie rod from an "E"
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tify the fuel rod. The radiation levels associated with the fuel rod vere type fuel bundle.
relatively lov (approximately h000 R/h) indicating that the fuel rod was likely to have been in the fuel pool prior to the last refueling outage.
More precise rod identification was not possible because the fuel inspec-tion equipment had been removed previously fro::i the fuel pool, decontami-nated and stored and the fuel pool was partially drained.
Two alternatives existed for storage of the fuel rod while the One was to arrange for the fuel work on the spent fuel was in progress, rod to be shipped to a site that had both inspection facilities for identification and a means for disposal. However, no shipping caska vould be available for a month, which jeopardized the availability of the fuel The second pool for the currently scheduled February refueling outage. altern fuel pool is refilled following relining.
It was determined This alternative was evaluated and selected.
that it involved no unreviewed safety questions or risks to the public or The cask is routinely used to transfer fuel assemblies plant employees.
from the reactor to the spent fuel pool shortly after reactor power opera-tion; therefore, one fuel rod that had not been in the reactor for a pro-Fuel rod heatup in air was longed period could be easily accot::nodated..
judged not to be a problem in that Big Rock Point fuel rods have been BLANCHARD EXHIBIT 1 O'NEILL CONTENTION IIG(b)
Mr. J:hn F. O' Leary 2
Dockst No 50-155, Lic:nca No DPR-6 November 20, 1973 I
n (iV) routinely handled in dry cells about six months after they were re=oved
. rom the core. ' Calculations were performed to confirm this and showed that assuming heat transfer by radiation and free convection in air and the fuel rod had been removed from the reactor in March 1973 the fuel rod maximum temperature would not exceed 255 F in air..As the precise valueu for the heat transfer coefficient are difficult to predict and the cask can be filled with water, a water level is being maintained in the cask. Plant personnel are monitoring the vater level daily. The fuel transfer cask is being stored in its normal location in the containment.
If any abnormal degradacion of the fuel rod were to occur, it vould be detected by continuous air monitoring equip =ent located in the containment.
The effect on veactor operation vould not be significant if this tie rod was missing from one of the remaining "E" type bundles that are presently in the reactor. All of the "E" type fuel is located such that its bundle powers are well below core average bundle powers. Previous evaluations have been performed on the effect of operation of "E" type fuel with several rods missing, including a tie rod (refer to our letter to the Division of Reactor Licensing dated March 27,1972). These evalu-ations showed that the resultant bundle local rod powers changed by less than 20%.
The fuel rod vill be returned to storage in the spent fuel pool (C.
vhen relining of the spent fuel pool is completed. At this__ time, it vill be identified and fuel disassembly and handlinst and accoun:, ability pro-4 Mures reviewed and modifi_ed as necessary to preclude recurrence or a similar event.
Yours very truly, Ralph B. Sewell (Signed)
RBS/=ap Ralph B. Sewell Nuclear Licensing Administrator CC: JGKeppler, USAEC 1
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'N-BOARD QUESTION 2 A.
THE BOARD QUESTION l
Did the facts learned from the loss-of-feedwater event at Oyster Creek on May 2, 1979, suggest any measures, other than those included in Amendment 30 to the Big Rock Point Technical Specificatious which would be im-portant in-preventing a severe loss-of-feedwater acci-1 dent?
Could an accident which might occur from this cause threaten the Licensee's ability to maintain the l
spent fuel pool in a safe condition?
i B.
MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO-BE HEARD.
1.
The sequence of events which occurred at Oyster Creek on May 2, 1979 were those described in the Affidavit of David P. Blanchard with respect to Board Question 2 at pp. 4-5 2.
The Technical Specification changes implemented at Big Rock Point Plant in amendment No. 30 to facility operating license DPR-6 to prevent oc-currence of an Oyster Creek type incident at Big Rock Point were the same as those which were im-plemented at Oyster Creek to prevent reoccurrence-of that incident at Oyster Creek.
(Affidavit of David P. Blanchard With Respect to Board Question 2 at p.7).
3.
Unlike the situation at Oyster Creek, Big Rock Point reactor vessel water level instrumentation provides direct indication of water level directly above the core whether or not the recirculation AU-
. loop valves are closed.
(Affidavit of David P.
Blanchard With Respect to Board Question 2 at p.8).
4.
If the reactor operator is provided accurate in-dication of the water level above the core, he can take a number of actions, which will provide sufficient cooling to the core to prevent fuel damage.
These actions include restarting the feedwater pumps or the CRD pumps to add water to J
the reactor vessel, opening the recirculation loops to provide steam drum water to the vessel, or manually activating the Reactor Depressuriza-tion System to provide core spray cooling.
(Affi-j Cavit of David P. Blanchard With Respect to Board i
Question 2 at 0.9).
5.
Unlike Oyster Creek, the Big Rock Point Control Rod Drive system provides sufficient makeup water to the reactor vessel to keep the core covered during an Oyster Creek type event.
(Affidavit of David P. Blanchard With Respect to Board Ques-I tion 2 at p.8).
6.
The proposed increase in the amount of spent fuel stored in the spent fuel pool has no effect on the probability of a sequence of events similar L)
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to that experienced at Oyster Creek occurring at Big Rock Point.
(Affidavit of David P.
Blanchard with Respect to Board Question 2 at p.8).
7.
The Big Rock Point spent fuel pool, with the proposed increased amount of stored spent fuel, can be maintained in a safe condition even if an Oyster Creek type incident leads to reactor core damage.
(Affidavit of David P. Blanchard With Respect to Board Question 2 at pp. S-ll; Affi-davit-of David P. Blanchard With Respect to Christa-Maria Contention 8 and O'Neill Contention IIIE-2).
C.
DISCUSSION The affidavit of David Blanchard demonstrates that the measures'taken in Amendment 30 to the Big Rock Point Technical Specifications were the same (accounting for dif-forences in plant design) as those taken at Oyster Creek to prevent reoccurrence of the May 2, 1979 lose of feedwater event.
Mr. Blanchard also demonstrates that there are t
two important differences in' design between Big Rock Point and Oyster Creek which would further' reduce the likelihood of an Oyster Creek type sequence occurring at Big Rock Point.
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s These are first, that the Big Rock Point reactor vessel level instrumentation, unlike that at Oyster Creek, pro-vides an indication of water level directly above the core whether or not the recirculation loop valves are closed.
Thus, the reactor operator at Big Rock Point, unlike his counterpart at Oyster Creek on May 2, 1979, would receive accurate information concerning the amount of water above the core.
A second major difference between Big Rock Point and Oyster Creek is that at Big Rock Point the control rod drive pumps automatically provide sufficient makeup water to prevent uncovering the core in an Oyster Creek type se-quence.
Finally, the affidavit of David Blanchard with respect to Board Question 2 establishes that the proposed increase in spent fuel capacity at Big Rock Point has no effect on the likelihood of an Oyster Creek Type sequence occurring at Big Rock Point.
Moreover, considered together with his affidavit responding to Christa-Maria Contention 8 and O'Neill Contention IIIE-2, Mr. Blanchard's affidavit with respect to Board Question 2 demonstrates that a reactor accident due to an Oyster Creek type event would not threaten Licensee's ability to maintain the spent fuel pool in a safe condition.
Accordingly, no disputed issues of material fact remain to be heard and Licensee is entitled to summary dis-
,n position of Board Question 2.
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UNITED STATES OF A! ERICA NUCLEAR REGULATORY COMMISSION s.,
yn BEFORE THE ATOMIC SAFETY AND LICENSING: BOARD g
In the Matter of
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CONSUMERS POWER COMPANY
) Docket No. 50-155-OLA
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(3 pent Fuel Pool r.,~.
(Big Rock Point Nuclear Power Plant)
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Modification)
AFFIDAVIT OF DAVID P. BLANCHARD County of Charlevoix)
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s My name is David P. Blanchard. I am employed by Consumers Power Company as a Technical Engineer at the Big Rock Point Plant located near 1
Charlevoix, Michigan.
I have a Bachelor of Science degree in Nuclear Engineering from the University of Missouri - Rolla. Upon graduation from engineering school in 1971, I joined Consumers Power Company as a Graduate Engineer, and I was assigned to the engineering staff at the Big Rock Point plant. In 1972, I transferred to the Company's corporate headquarters in 1
Jackson, Michigan.
I was assigned to the Reactor Physics Group as an Associate Engineer. I was responsible for nuclear and thermal hydraulic analyses and design of the reactor cores for the Big Rock Point plant. In early 1976, I was. temporarily assigned to Babcock and Wilcox's facility in Lynchberg, i
irginia, as a General Engineer. My work included the performance of reactor physics analyses for input to the FSAR of the Midland nuclear plant. I returned to the Big Rock Point plant at the end of 1976, and I was assigned j
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.the position of Reactor Engineer. In-this position, I was responsible for
.the performance of analyses of the Big Rock Point reactor tc insure conformance with nuclear fuel thermal bydraulic limits associated with transient and
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N 5 tsceident conditions, _ua well as steady state operation, I was also s
nj renponsible for imp} ementation of a program for the handling and accounta-bility of nuclear fuel and reactor internals hardware at the Big Rock Point ite. Theseresponsibilitiesincludeddevelopmentofprocedurejforhandling nuclear fuel from t he time of its arrival at Big Rock, threugh its receipt inspection and acceptance, insertion into the reactor for power production, 2,.
transfer so spent fuel storage on deplation of its useful fissile material and ditimately tc
.ipment oirsite to a fucl reprocessing facility.
N Dcrelopmeni of controls and procedures fgr full handling daring refueling s,
activities and irradiated fuel.exas.ination activities by the nuclear fuel vendors sere also among my respon ibilities. Accounting for the handling and transfer of fuel within the plant is required by 10 C.F.R. Part 70, and as Reactor Engineer, I was responsible in implementing fuel accountability methods which complied with these regulations.
have been plant Project Engineer for several plant modifications, incl,uding replacement of the emergen:y core cooling sparger in the reactor venuel.
In t980, I was the plant individual assigned the responsibility of working with Science Applications, Inc., in the development of a Probablistic Risk Assessment for the Big Rock Point plant.
In March 1981, I moved to the position of Senior Engineer, and I was promoted subsequently to the positicn of Technical Engineer. I have been assigned to the spent fuel expansion project since early 1978, and I was involved in developing a method to accomplish remote actuation of water addition to the spent fuel pool.
i Based on my educational background and work experience, I believe I am qualified to answer Christa-Maria Contention 8 and O'Neill Contention IIIE-2, O'Neill Contention IIG(b), and Licensing Board Question 2.
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I am the author of the testimony addreccing Christa-Maria Contention 8 and O'Neill Contention IIIE-2, O'Neill Contention IIG(b), and Licensing Board i
(' '
Question 2.
I swear that the statements ar.1 inf-crmation contained in this affidavit, the referenced testimony, and in the figures and exhibits attached thereto are true and correct to the best of my knowledge and belief.
l Executed at Charlevoix, Michigan.
sv0$ }) Sf0xClht.h Sulseribed and sworn to before me this 2nd day of October, 1981, w&m A
>E Ndary Public M andMor the State of Michigan and County of Charlevoix Eugene A Dsiedzic My commission expires March 6, 1983.
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