ML20033D057

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Testimony of Wa Paulson Re Oneill Contention Ii.G(A) Re Administrative Controls.Administrative Controls Are Adequate to Prevent Cask Drop Over Pool.Prof Qualifications & Certificate of Svc Encl
ML20033D057
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/03/1981
From: Paulson W
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20033D054 List:
References
NUDOCS 8112070170
Download: ML20033D057 (7)


Text

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f 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY

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Docket No. 50-155 (Big Rock Point Plant)

TESTIMONY OF WALTER A. PAULSON CONCERNING O'NEILL CONTENTION NO. II.G(a)

Q.1. Please state your name and your position with the Nuclear Regulatory Commission.

A.1. My name is Walter A. Paulson.

I am a Project Manager, Operating Reactors Branch 5, Division of Licensing, U.S. Nuclear Regulatory Commission, Washington, D.C.

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Q.2. Have you prepared a statement of professional qualifications?

A.2. I have prepared the statement of professional qualifications attached hereto.

Q.3. Describe your responsibilities as they pertain'to this proceeding.

A.3. As part of my duties, I am responsible for the safety and environ-mental review of tr.e proposed modification of the spent fuel pool at the Big Rock Point Plant, which is the subject of the above-captioned proceeding.

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Q.4. What is the scope of your testimony?

A.4. My testimony addressed O'Neill Contention No. II.G(a) which states:

Administrative controls proposed to prevent a cask drop over the pool are inadequate, These are main-tained on pages 4-9 of the application. Administrative controls have proved inadequate in the past in preventing incidents and are frequently violated at the plant.

Q.5. What administrative controls has the licensee proposed in its application?

A.S. The licensee's application dated April 23, 1979 states the following on page 4-9 with regard to administrative controls:

Administrative controls will be established for casks other than the fuel transfer cask to ensure that: (a) no cask is moved over stored spent fuel, (b) all cask handling operations are limited to the south west corner of the spent fuel pool, and (c) no spent fuel is stored in the two existing "A" racks adjacent to the cask handling area during cask handling operations. These controls will preclude the dropping or tipping of a cask onto a fuel rack with stored fuel. The fuel transfer cask is provided with additional safety slings and its use in the spent fuel pool has been found acceptable (Refer Docket 50-155 CPC0's letters dated 7/1/74, 1/22/76, 11/8/76 and NRC Division of Operating Reactors Docket 50-155, letter to CPC0 dated 2/6/76).

Q.6. What is the result of the NRC Staff's evaluation of the handling of heavy loads in the vicinity of the spent fuel pool?

A.6. Section 3.4.1.1 of the NRC Staff's Safety evaluation dated May 15, 1981 relating to the modification of the Big Rock Po nt spent fuel storage i

pool addresses the handling of heavy loads in the vicinity of the spent fuel pool.

The appropriate portion of Section 3.4.1.1 of the safety evaluation states that the heaviest load that will be trans-ported over the stored spent fuel is the 24-ton spent fuel transfer

case.

The 24-ton spent fuel transfer cask has a redundant support (safety sling) assembly that was designed to catch the case in the event of a main hoist / hook failure.

By letter dated August 14, 1980, the licensee proposed a Technical Specification that would require functional testing of the trip mecnanism of the spent fuel transfer cask redundant support assembly prior to commencing refueling activities.

Q.7. What other measures does the NRC Staff believe should be taken to assure safe handling of heavy loads in the vicinity of the spent fuel pool?

A.7. The NRC Staff has completed its generic review of 10ad handling operations in the vicinity of spent fuel pools.

A report describing the results of this review has been issued as NUREG-0612. " Control' of Heavy Loads at Nuclear Power Plants - Resolution of TAP A-36."

This report contains several recommendations to be implemented by all licensees to ensure the safe handling of heavy loads.

By letter dated December 22, 1980, which was sent to all licensees, the licensee was requested to review the controls for the haridling of heavy loads to determim. the extent to which the guidelines in NUREG-0612 are presently satisfied at the Big Rock Point Plant, and to identify the changes and modifications that would be required in order to fully satisfy these guidelines. Our December 22, 1980 letter also identified interim actions that the licensee should implement within 90 days (byletter'datedFebruary3,1981,thiswasextendedtoMay 15,1981).

These interim actions are:

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(1) Safe load paths should be defined per the guidelines of Section 5.1.1(1) of NUREG-0612 (2) Procedures should be developed and implemented per the guidelines of Section 5.1.1(2) of NUREG-0612 (3) Crane operators should be trained, qualified and conduct themselves per the guidelines of Section 5.1.1(3) of NUREG-0612, (4) Cranes should be inspected, tested, and maintained in accordance with the guidelines of Section 5.1.1(6) of NUREG-0612, and (5)

In addition to the above, special attentien should be given to procedures, equipment, and personnel for the handling of heavy loads over the core, such as vessel internals or vessel inspection tools.

This special review should include t'.e following for these loads: (1) review of procedures foe. install-ation of rigging or lifting devices and movement of the load to assure that sufficient detail is provided and that instructions are clear and concise; (2) visual inspections of load bearing components of cranes, slings, and special lifting devices to identify flaws or deficiencies that could lead to failure of the component; (3) appropriate repair and replacement of defective components; and (4) verify that the crane operators have been properly trained and are familiar with specific procedures used in handling these loads, e.g., hand signals, conduct of opera-tions, and content of procedures.

By letter dated June 10, 1981, the licensee stated that the interim actions have been completed except for the specific requirements associated with crane operator visual examinations. The letter stated that they intend to update the existing crane operator vicuft examinations to be in accordance with the referenced guidelinas.

Q.8. What is your conclusion as to the adequacy of the licensee's admin-istrative controls to prevent a cask drop over the spent fuel pool?

A.8. I conclude that the measures discussed above, including administrative controls, are adequate to prevent a cask drop over the pool.

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. ROFESS10!!Al. QUAllFICATIONS 0F h' ALTER A. PAULSON 1

I am the Nuclear Regulatory Commission Project Manager for the Big As a Project Rc:k Point Plant well as one other nuclear power plant.

Manager I manage h 3 participate in the review and eval I

of nuclear power facilities, especially those licensed for operation.

also currently participate in the Systematic Evaluation Program which involves a comprehensive review and evaluation of older op a<

current licensing requirements.I received a Bachelor of Chemical Enghneerin In 1959, I received a Master of Science Degree in Institute in 1957.

Huclear Science and Engineering from Rensselaer Polytech Savannah River Plant and held tie position of Chemica From 1962 to 1973 I was eroloyed and fuel element operational performance.

by the National Aeronautics and Space Administration at the Lewis Resea I held positions as nuclear engineer in heat transfer, fluid flow and shielding design, and supervisory nuclear engineer in these Center in Ohio.

In May 1973, I joined the Nuclear Regulatory Commission (formerly AEC) arees.

I have also held the positions of Research as a Licensing Project Manager.

Analyst. Technical Assistant, and Operating Reactors Project Manager.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!HISSION i

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CONSUMERS POWER COMPANY Docket No. 50-155

- (Big Rock Point Plant)

(Spent Fuel Pool Modification)

CERTIFICATE OF SERVICE I hereby certify that copies of " TESTIMONY OF JACK N. DON 0 HEW, JR. CONCERNING O'NEILL CONTENTION NO. II.E.4" and " TESTIMONY OF WALTER A. PAULSON CONCERNING O'NEILL CONTENTION N0. II.G(a)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, at indicated by an asterisk, through deposit in the Nuclear Regulatory Commis-sion's internal mail system, this 3rd day of December, 1981:

Herbert Grossman, Esq., Chairman Joseph Gallo, Esq.

Administrative Judge Isham, Lincoln & Beale Atomic Safety and Licensing Board 1120 Connecticut Ave, ii.W., #325 U.S. Nuclear Regulatcry Comission Washington, D. c. 20036 Washington, D.C.

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  • John A. Leithauser Dr. Oscar H. Paris Leithauser and Leithauser, P.C.

Administr3tive Judge Opal Plaza, Suite 212 Momic Safety and Licensing Board 18301 Eight Mile Road U.S. Nuclear Regulatory Commission East Detroit, MI 48021 Washington, D.C.

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  • John O'Neill, II~

4 Mr. Frederick J. Shon Route 2. Box 44 Administrative Judge Maple City, Michigan 49664-Atomic Safety )no Licensing Board U.S. Nuclear Regulatcry Commission Christa-Maria Washington, D.C.

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  • Route 2 Box 108c Charlevoix, MI 49720 Philip P. Steptoe, Esq.

Michael I. Miller, Esq.

Ms.-JoAnne Bier Isham, Lincoln & Beale' 204 Clinton One First National Plaza Charlevoix, MI 49720 Suite 4200 Chicago, Illinois 60603-W

  • Atomic Safety and I.icensing Mr. Thomas Dannann Appeal Board Panel Route 3. Box 241 U.S. Nuclear Regulatory Commission

20555 Judd L. Bacon. Esq.

  • Atomic Safety and Licensing Consumers Power Co.

Board Panel 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, MI 49201 Washington, D. C.

20555 Mr. Gordon Howie

  • Docketing and F *vice Section 411 Pine U.S. Nuclear Regulatorf Commission Boyne City, MI 49712 Washington, D. C.

20555 Mr. Jim Mills Herbert Semmel, Esq.

Route 2, Box 108 Urban Law Institute of Charlevoix, MI 49720 The Antioch School of Law 1624 Crescent Place, N.W.

Washington, D. C.

20009 Richard G. Bachmann Counsel for NRC Staff 2

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