ML20062H736
| ML20062H736 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/22/1980 |
| From: | Gallo J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | BIER, MILLS, CHRISTA-MARIA, ET AL |
| Shared Package | |
| ML19344D928 | List: |
| References | |
| NUDOCS 8008260371 | |
| Download: ML20062H736 (700) | |
Text
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CONSUMERS POWER COMPANY
)
Docket No. 50-155
)
(Big Rock Point Nuclear Power Plant)
ANSWERS OF CONSUMERS POWER COMPANY TO INTERROGATORIES PROPOUNDED BY CHRISTA-MARIA, ET AL.
Pursuant to 10 C.F.R.
S 2.740b and the schedule for discovery set forth in the Atomic Safety and Licensing Board's " Order Following Special Prehearing Conference,"
Consumers Power Company
(" Licensee") hereby submits answers to Interrogatories 3-1 through 3-4, 3-6 and 3-7 propounded by Crista-Maria.
Interrogatory 3-1 Is type 304 austenitic stainless steel used in any of the existing spent fuel racks or elsewhere in the spent fuel pool?
Which racks and where?
A.
Answer No type 304 aus+enitic stainless steel is used in the existing racks.
The spent fuel pool liner is made of this material.
Other components in the spent fuel pool that are made of stainless steel are listed below.
Except as noted, the specific stainless steel types are not known.
1.
The following appear on Bechtel Drawing 3159 C-137, da.ted 11/3/61, but are no longer in the pool:
800826o3 7 i THIS DOCUMENT CONTAINS P00R QUAllTY PAGES
a y
. (a)
R & D Equipment attachments (which have been subsequently removed with the installation of the spent fuel pool liner), consisting of bolts, angles, plate, and clips.
(b)
Nozzle Rack.
2.
Equipment now in the spent fuel pool:
(a)
Support Tubes (lower portion of fuel flow channels)
(b)
Control Blades (c)
Reactor Vessel Flange Protectors (d)
In-core Neutron Flux Detectors (e)
Underwater Periscope i
(f)
Irradiated Fuel Inspection Elevator (g)
Irradiated Fuel Rod Storage Cans (h)
Miscellaneous Storage Buckets (i)
Irradiated Colbalt Rod Storage Can (j)
Fuel Handling Cables and Tools (k)
Steam Baffle and Sparger Ring (will be moved next outage)
B.
Documents Relied Upon Bechtel Drawings 3159 C-137, and 3159 C-138 (copies pro-vided), Inventory notes dated 5/30/80 from L.
F. Monshor (copy provided).
l Leitelt Drawings 4349-1 and 10394-1 (copies provided),
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l.
i C.
Documents Reviewed But Not Relied Upon:
None.
D.
Further Activities None.
Interrogatory 3-2 Answer Question 3-1 with respect to the proposed additional racks.
A.
Answer All portions of the additional racks will be fabricated from Type 304 austenitic stainless steel except the following:
(1)
Hex head screw - Commercial 18-8.
(2)
Leveling leg - ASTM A276 - UNSS21-800 (Nitronic-60).
Both (1) and (2) are austenitic stainless steel (no t type 304).
B.
Documents Relied Upon NUS Proprietary Drawing No. 5148 M 2001, Sheet 2 of 2, titled " Rack Assembly and Details" (copy not provided).
C.
Documents Reviewed But Not Relied Upon Letter from David A.
Bixel to D. Ziemann dated October.
I 25, 1979-(copy attached).
Letter from D.
L. Ziemann to D. P. Hoffman dated February 19, 1980 (copy attached).
D.
Further Activities None.
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. Interrogatory 3-3 Provide the following information with respect to the proposed additional spent fuel racks and their components.
Please pro-vide a separate set of answers for each spent fuel rack.
If answers are the same for different racks, they need not be repeated.
a.
Describe the rack, identifying each component.
b.
Who will manufacture the rack?
c.
From whom will Licensee purchase the rack?
d.
Who will manufacture each component of the rack?
e.
What is the composition (metallic, chemical, physical) of each component?
f.
Provide a detailed description of the manufacture of each component from the raw materials to the completed product.
Identify and explain every test or quality assurance check that is performed on the component during the manufacturing process or after manufacture is completed, but prior to receipt by Licensee.
g.
Identify and explain all tests, research, and quality assurance checks and all test, research and quality assurance reports and other documents relied upon, referred to, or otherwise available to Licensee concerning the performance or use of the spent fuel rack components (and the materials from which they are made) in general and in the spent fuel pool environment in particular.
The requested documents include, but are not limited to, documents showing the history of the manu-facture, performance, or use of the spent fuel.
rack components; documents provided by the manu-facturer, vendor, a consultant, or other sources; documents recommending or otherwise judging the components.
h.
Identify.ind explain any problems that have been identified in the use of the spent fuel rack components, both in general and in the spent fuel pool environment in particular.
Explain why the problems do not threaten the safe operation of the spent fuel pool.
' i 1.
Identify and explain all changes that may occur in the spent fuel rack components during the time they are in the spent fuel pool.
Changes incit.de, but are not limited to chemical or physical reac-tions.
Explain the impact of these. changes on the integrity of the spent fuel rack and the safe operation of the spent fuel pool:
j.
Answer questions 3-3 (e), (f), (g) and (h) with respect to the spent fuel rack.
k.
Who will install the spent fuel rack?
si 1.
Provide a detailed description of the installation of the spent fuel rack.. Identify and explain every test or quality assurance check that is performed by either the installer, the Licensee, 4
or anyone else, to assure correct and safe installa-tion of the rack.
j m.
Answer questions 3-3(f) and (g) with respect to installation of the spent fuel rack.
n.
What is the design life of this' spent fuel rack?
Provide the basis for your answer and explain how the conclusion was reached.
Include all calcula-i tions, computer programs or models, experiential i
data or information, assumptions, and the justifi-cation for all assumptions.
o.
Explain the physical, chemical, radioactive, and other stresses to which the spent fuel rack or its components will be subjected in the spent fuel pool environment.
j p.
Explain the effects of these stresses on the spent fuel rack or its components.
q.
Explain the synergistic effects of combined stresses, including seismic stress, on the spent fuel rack or its components.
i r.
Explain why Licensee decided to use this spent fuel rack, as opposed to other possible racks, taking into account at least the design of the rack, the components from which the rack will be made, and the experience using this type of rack in other spent fuel pools.
4 5
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A.
Answer As discussed in the Licensee's Description and Safety Analysis Report submitted for review to the USNRC by letter from D.
P. Hoffman to D.
L.
- Ziemann, dated April 23, 1979, the three additional spent fuel racks are of identical design differing only with respect to the number of fuel storage locations provided (refer to Figure 2-1 of the Description and Safety Analysis Report).
Therefore, the answers provided to subparts (a) through (r) of this interrogatory apply to all three of the additional spent fuel racks.
(a)
The proposed additional spent fuel storage racks are described in Section 3.1 of the Descrip-tion and Safety Analysis Report, dated April 23, 1979.
(b)
A fabricator for the racks has not been chosen at this time.
Presently, four nuclear fuel rack fabricators have responded to our questionnaires.
These four fabricators have been evaluated with regard to their respective quality assurance programs, previous related experience, and commercial standing (Dunn and Bradstreet).
On the basis of this evaluation, these four fabricators are judged to have sufficient qualification to bid.
These four nuclear fuel rack f abricators are:
1
. (1)
Lamco Industries, Inc.
(2)
Speedway Machine & Tool Company (SMATCO)
(3)
Metal Products (4)
Leckenby Company The final selection of the fabricator for the additional three spent fuel racks will be made following evaluation of the bids.
The bid package for fabrication of the fuel racks is presently scheduled for issuance by June 30, 1980.
Bids are expected by the end of July, and selection of the fabricator and award of the work (issuance of a Purchase Order) will be made approximately 30 days following receipt of the last bid (end of August or early September).
(c)
Licensee will purchase the racks directly from the fabricator.
(d)
Until a fabricator has been selected, the details of fabrication, including subcontracts, cannot be provided.
All fabricator activities will be monitored by CPCo and all quality-related activities will meet the requirements of the USNRC-approved CPCo, Quality Assurance Policies and Procedures.
(e)
Refer to the answer provided to Interrogatory 3-2.
i
(f)
Since as indicated in paragcaph (b) above, a fabricator for the new racks has not been selected, the manufacturing process of "each component from the raw materials to the com-pleted product" is not known.
Tests or quality assurance checks that are to be performed on the racks during or following fabrication and prior to shipment will be in-1 cluded in the fabricator-prepared Inspection and Test Plan.
The NUS Spent Fuel Rack Fabrication Specification 5148-M-200 provides direction and guidance to the fabricator for the preparation of the Inspection and Test 1l Plan.
More specific guidance will be provided by CPCo following the selection of the fabrica-tor.
The Inspection and Test Plan is scheduled to be approved by CPCo for use on the project approximately 60-90 days following the issuance by CPCo of a Purchase Order to the selected fabricator (that is, before the end of November 1980).
The Inspection and Test Plan will be approved by CPCo prior to the beginning of any fabrication.
(g)
An answer is not supplied to this paragraph of Interrogatory 3-3.
(h)
The Licensee is unaware of any reports of difficulty in the use of the spent fuel
~..
i
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rack components in environments similar to the Big Rock Point Plant spent fuel pool.
The issue of intergranular stress corrosion cracking has been identified by the USNRC as having a potential for occurring in systems containing oxygenated, borated, stagnant water.
This problem does not threaten the safe operation of the Big Rock Point Plant spent fuel racks as discussed in the answer to Interrogatory 3-7.
i (i)
There may be an insignificant amount of corrosion, however, no changes to the racks, 4
affecting the integrity of the racks or safe j
operation of the spent fuel pool are antici-pated during the expected operating life of the Big Rock Point Plant.
(j )
Refer to the answers to Interrogatory 3-3(e),
(f), (g) and (h).
(k)
An installation contractor for the racks has not been selected.
Due to the lead time ex-pected in fabrication (approximately 6-9
'l months), there are no plans to evaluate pos-sible installation contractors until the f abricator has been authorized by CPCo to begin fabrication of the racks.
CPCo presently intends to withhold authorization for fabrication work until approval by the
. NRC of the proposed license amendment has been received.
By delaying the selection of an installation contractor in this manner, CPCo hopes to minimize expenses and if possi-ble coordinate installation work with other contract work which anay be taking place at the Big Rock Point Plant in the same time frame.
(1)
The installation of the spent fuel racks will be performed in accordance with a detailed Installation Plan, prepared by the contractor and approved by CPCo.
The Installation Plan will be based upon the guidance provided by the NUS Installation Specification 5148-M-201 and specific instructions prepared by CPCo.
It is important to note that despite the use of an installation contractor, the movement of stored spent fuel, movement of racks within the pool and the movement of racks within the Big Rock Point Plant Reactor Building will be performed by licensed CPCo Reactor Opera-tors in accordance with established controls and administrative procedures.
(m)
See answers to (f), (g) and (1).
(n)
The design life of the proposed spent fuel i
storage rack is 40 years, based upon cur-rent practice in the nuclear utility in-dustry.
(o)
The physical, chemical and radioactive stresses to which the spent fuel racks and components will be subjected in the spent fuel pool environment during normal spent fuel pool operation are in general:
(1)
Physical.
Dead weight of fuel assem-blies in storage, hydrostatic pressure of the water, thermal due to temperature gradients and residual stresses from welding.
(2)
Chemical.
The Big Rock Point Plant spent fuel pool is not considered to be a stressful environment because of the good water chemistry at the Plant.
No signifi-cant chemical stresses are anticipated.
Refer to the answer to Interrogatory 3-7.
(3)
Radiation.
The radiation environment in the spent fuel pool is not anticipated to result in stresses that will affect the integrity of the racks or the safe operation of the spent fuel pool.
The maximum neutron flux is approximately 5
2 10 neutrons /CM -sec; the maximum gamma 6
flux in the pool is approximately 10 R/hr.
- Similar Type 304 austenitic stainless steel has experienced no significant degradation following exposure to radia-tion environments in reactor cores that are many orders of magnitude above that possible in the spent fuel pools.
(p)
The effect of th'e physical stresses is to impose loads on the supporting structures of the racks consistent with the nature and magnitude of such stresses.
These loads have been considered in the design of the spent fuel racks (Refer to Description and Safety Analysis Report Sections 2.0, 3.0 and 5.0).
The chemical and radiation stresses are negligible.
(q)
The te m " synergism" means the action of two or more m.'bstances, organs or organisms to achieve ar. effect of which each is individually incapable.
Thus, the term is not appropriately f
used in the context of combining load responses k
N for the design of equipment and piping.
The t
more appropriate term is " load combinations."
tj The combined loads imposed upon the racks, e
including seismic loads, have been determined T
v in accordance with USNRC SRP 3.8.4 as discussed 4
in Section 5.1 of the Description and Safety a
i
(
e i
t
. Analysis Report.
This method combines the loads in a conservative manner.
(r)
The rack design was chosen for its simplicity, ease of fabrication, and similarity to the existing racks.
The materials for the rack components were specified by NUS Corporation and have been used in similar applications in many other nuclear facilities.
In addition, during the period when proposed (conceptual) designs for the racks were being reviewed by CPCo, certain difficulties relating to off gas in borated (neutron-absorbing) racks were being experienced in the nuclear industry as well as at the Palisades Plant.
This experience tended, at the time, to over-shadow the advantages of the borated rack design and was a contributing factor in the decision to pursue the present design concept.
B.
Documents Relied Upon NUS Spent Fuel Rack Fabrication Specification 5148-M-200 (copy provided).
Memo from P. E. Lowe dated October 30, 1979 (copy provided).
Letter from S.
K.
Malur to C. L. Larsen dated July 26, 1979 (copy provided).
. A.B. Johnson, Jr.,
" Spent Fuel Storage Experience",
NUCLEAR TECHNOLOGY VOLUME 43 (Mid-April 1979) (copy provided).
Description and Safety Analysis Report.
C.
Documents Reviewed But Not Relied Upon None D.
Further Activities See answers to (b), (d), (f), (k) and (1) above.
Interrogatory 3-4 Please answer all parts of Question 3-3 with respect to the existing spent fuel racks, substituting the words " relocate" and " relocation" for " install" and " installation".
Where the questions use th future tense, please answer with respect to past events and experience as well as with respect to the future.
A.
Answer (a)
Spent Fuel Storage Racks Type A and B:
These racks consist of 3"x3"x3/16"x7" long vertical angles forming the corners of 7" square cells spaced one foot on centers.
These cells are later-ally stayed top and bottom by 3"x2"xl/4" horizontal angles and interconnecting 3"x3/16" bars welded to the vertical angles.
Each cell has a 7-1/2" square 5/16" base plate.
The rack is supported (on the bottom of the fuel pool) by 1/2" PVC pads under every other base plate.
The A rack has 48 cells, with a nominal width of 6'x8'.
The B rack has 72 cells, with I
l a nominal width of 6'x12'.
l l
l
I Spent Fuel Storage Rack Type C [ Channel Rack]:
This rack consists of vertical 6"x6"x3/16" fabri-cated struts, 5'-11" long, spaced 14-1/2" on center in an offset pattern interconnected by 3"x3/16" bars top and bottom.
Perimeter vertical struts are 3"x2.33 lb. structural tees.
Corner struts are 3"x3"x3/16" angles.
The 3" bars and vertical struts are connected to a 3"x2"xl/4" angle extending around the perimeter on top, and a continuous 3/16" plate at the bottom.
The rack is supported on the bottom by a 1/2" PVC sheet bearing on the floor of the fuel pool.
(90 cells, nominal 9'x10').
Refer to Bechtel drawing 3159 C-137 for racks A, B, and C.
Spent Fuel Storage Rack D:
This rack was built similar to rack A (48 cells).
(The only difference that was noted - incore storage provision not on D rack.)
Reference Leitelt drawing 4349-1.
Failed Fuel Storage Rack:
This rack consists of 3"x3"x3/16" x 71" long vertical angles forming the corners of 12-11/16" square cells spaced as shown on drawing 10394-1.
These cells are laterally stayed on the top by 3"x2"x1/4" horizontal angles; on the bottom by 5" channels and interconnecting 3"x3/16" flat bars welded as shown on drawing 10394-1.
I
, _ _ _ _ ~,. - _... _ _ _. _,,
4 Each cell is attached to a large continuous 5/16" base plate.
The rack is supported (on bottom of pool) by a 1/2" thick PVC pad.
(25 cells; nominal 68"x68".)
Reference drawing 10394-1.
(b)
Racks A, B and C were manufactured by Aluminum and Architectural Metals Company, 1974 Franklin Street, Detroit 7, Michigan, Rack D and the Failed Fuel Storage Rack were manufactured by Leitelt Iron Works, Grand Rapids, Michigan.
(c)
Racks A, B, C,
D and the Failed Fuel Storage Rack were purchased from the vendors stated in (b).
(d)
The manufacturers of the rack components are shown in the " Documents Relied Upon" identified in Part B.
Except as shown in such documents, Consumers Power Company does not know who manufactured the rack components.
(e)
According to Bechtel drawing 3159 C-137 all metal members in spent fuel storage racks A, B, and C are made of aluminum alloy 6061-T6 or equivalent.
According to Leitelt drawings 4349-1 and 10394-1 spent fuel storage Rack D and the Failed Fuel Storage Rack are made of aluminum alloy 6061-T6, which is a heat treatable aluminum, alloyed with 1.0% magnesium and 0.6% silicon.
Tensile strength range 18,000 to 45,000 psi; good formability, l
weldability and corrosion resistance.
6,
1 i
~
Polyvinyl Chloride (PVC) pads are the flexible type.
They are fastened to the aluminum with Amercoat adhesive No. 204 or equivalent.
All bolts were furnished by Bechtel Field and were used for R & D attachments (reference Bechtel drawing 3159 C-137); bolts are stainless steel. These R & D attachments were removed when the spent fuel pool liner was installed.
( f)'
An answer is not supplied with respect to the first sentence of this question.
The second sentence in interrogatory (f) is answered as follows; our records show the fabrication of spent fuel racks A, B, and C, were to be in keeping with the good practice for the industry and were to conform to criteria set forth by the Aluminum Company of America publications; "Alcoa Aluminum Handbook", "Alcoa Structural Handbook", " Riveting Alcoa Aluminum", and " Welding Alcoa Aluminum".
Further, the shipment of the racks was contingent upon Bechtel Corp. inspection and release.
Our records show the D and Failed Fuel Storage racks were locally fabricated in Michigan by Leitelt Iron Works to drawings prepared by Bechtel and by Consumers Power Company in the case of the l
t !
D rack, and by CPCo for the failed fuel storage rack.
Review of the fabrication work effort was done by CPCo Engineers.
(g)
An answer is not supplied to this paragraph of Interrogatory 3-4.
(h)
Spent fuel rack D was removed from the spent fuel pool for the spent fuel pool relining effort and placed in storage.
The rack was reinstalled in tae spent fuel pool prior to the February 1979 refueling.
An inspection was made of this rack which showed some indication of cracks, non-fusion and inadequate weld penetrations, burning away of material and excess weld material.
Subsequent visual and NDT inspections and review were documented, i
and from this review it was concluded that the number of good welds securing the rack components more than offset the welds exhibiting poor quality, and that the cracks which appeared did not affect the integrity of the welds.
The poor weld quality was believed to be due to initial welding rather than corrosion.
Rack D was then placed back in the pool.
During the above inspection, the rack slipped and leaned against plant piping.
The incident caused no damage and it is documented under MO-79-FHS-02205-05 i
and MO-78-FHS-353-22-05 (copies provided).
. While reviewing data associated with the Spent Fuel Storage Rack D, it was discovered that the PVC pads were missing from Rack D.
Consequently a pad has been ordered for this Rack.
(i)
Consumers Power Company knows of no significant changes which have occurred or which may occur affecting the integrity of the aluminum racks and their components and the safe operation of the spent fuel pool.
An insig-nificant amount of corrosion has occurred and would be anticipated to continue throughout the remaining life of the aluminum racks.
(j)
See answers to (e), (f), (g) and (h).
(k)
Bechtel was responsible for installation of the initial spent fuel racks A, B,
and C under the Big Rock " turnkey" project.
Consumers Power Company installed spent fuel rack D and the Failed Fuel Storege Rack.
(1)
No documentation has been found in Consumers Power Company's files describing how Racks A, B, C, D and the Failed Fuel Storage Rack were initially installed.
However, spent fuel rack D was re-installed on or about 1/26/79 with installation instructions as shown in MO. 79-FHS-D22-05-05.
(m)
See answers to (f), (g) and (1).
(n) 40 years - Standard practice at the time of manu-facture for nuclear power plant components.
No documentation has been found in Consumers Power Company's files explaining this choice of design life.
, (o)
See answer to Interrogatory 3-3(o).
(p)
Consumers Power Company does not expect any adverse effects on the old racks from these stresses.
(q)
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of the original racks.
It is known that these racks were not seismically qualified; however, the spacing requirement among the racks specified in MO-78-FHS-022-05-05 takes into account movement of the racks during a seismic event.
(r)
Bechtel Corporation engineers with decisionmaking input fron Consumers Power Company chose the spent fuel racks A, B,
C.
The decision was made to use aluminum partially based upon GE's experience with aluminum for design of nuclear components.
Further, aluminum material was used at other nuclear facilities for this type of application in the late 1950'a and 1960's.
Aluminum material also has the characteristic of not scaling, (if present could add to the turbidity of spent fuel pool water).
Spent Fuel Rack D was purchased by Consumers Power Company engineers and was built very similar to the spent fuel rack A.
By using similar design criteria, the rationale for materials, strength, l
f etc. and criticality requirements needed for spent fuel rack A would be contained in the design of spent fuel rack D.
The Failed Fuel Rack was purchased by Consumers Power Company engineers and contains rack components quite similar to rack A, as shown on Bechtel drawing 3159 C-137.
Only the cell dimensions are different (larger) to allow spent fuel leaker cans to be stored in this rack.
The larger spacing of course ensures that criticality requirements are met.
Materials used in the Failed Fuel Storage. Rack are the same as in Spent Fuel Rack D.
B.
Documents Relied Upon Sections 3.4 and 3.5 in Attachment A, letter from R. B. Sewell to Karl R.
Goller dated July 1, 1974 (Postulated Cask Drop Accident Study)
(copy previously provided)
Bechtel Dwg. 3159-C-137 (copy provided)
Leitelt Dwg. 4349-1 (copy.provided)
MO-79-FHS-02205-05 and MO 78-FHS-353-22-05 (copy provided)
Requisition No. 3159-C-55 (2/2/62) (copy provided)
Purchase Order 3159-C-55 (2/2/62) (copy provided)
Letter 5/5/67 Leitelt to Consumers (R.
B. DeWitt)
(copy provided)
Letter 5/2/67 Consumers to Leitelt (copy provided)
Letter 9/1/67 Consumers to Leitelt (R. Heemstra)
(copy provided)
Letter 8/28/67 Leitelt to Consumers (R.
B. DeWitt)
(copy provided)
Purchase Requisition 8/7/67 Job #4349 (copy provided)
Work Order Form 8/5/67 Job #4349 (copy provided)
Purchase Requisition 8/7/67 Job #4349 (copy provided)
Material Charges 9/1/67, 8/24/67, 10/18/67, 3/24/67, 8/18/67, Job #4349 (copy provided)
)
l Bechtel Dwg. #C-137, Job #3159 (copy provided)
Sketch #4349-1, 8/21/67 (copy provided)
I Material Charges, 4/1/66, 3/31/66, 4/11/66, Job #10394 (copy provided)
)
Leitelt Order Confirmation 2/17/66 (copy provided)
Purchase Requisition 3/8/66, Job #10394 (copy provided)
Invoice Walgren Company to Leitelt #4518, 4/9/66,
{
Job #1639 (copy provided)
Leitelt Purchase Order to Walgren Company, #6988, 3/18/66 (copy provided)
Drawing by ERC of #2 Storage Rack top view and "A" l
view (cooy provided)
Drawing #10394-1, 3/11/66 (copy provided)
Letter B Randolph to W. C. Cooper dated 9/29/61, Fuel Handling - Regarding the use of PVC and aluminum in design of the fuel handling equipment l
Ryerson Stock List Edition 118 (not provided) l Deviation Report D-BRP-79-03 (1/11/79) (copy provided)
Final Hazards Summary Report, Section 5 (copy provided)
C.
Documents Reviewed But Not Relied Upon Bechtel Requisition 3159-C-55 Rev. O dated 8/29/61 and attachments (copy provided)
Letter from E.
Barlow of Bechtel Corp. to F. J. Mueth of Aluminum and Architectural Metals Company dated 11/7/61 and attachments (copy provided)
Unreadable document numbered 699834 with handwritten note referring to a dolly (copy provided)
Letter from F. J. Mueth of Aluminum and Architectural Metals Company to E. Barlow of Bechtel Corp.
dated 10/27/61 (copy provided)
D.
Further Activities NUS is preparing a structural analysis of the old racks taking into account thermal stresses due to coolant system failure.
L
.o
. Interrogatory 3-6 Please identify all other components of the spent fuel pool that will be subjected to the spent fuel pool environment and answer all parts of Question 3-3 with respect to those components.
Where the questions use the future tense, please answer with respect to past events and experience as well as with respect to the future.
A.
Answer The major components of the spent fuel pool, other than the spent fuel racks and the liner, are the Fuel Pool Heat Exchangers. the Fuel Pool Water Circulation Pumps, the Fuel Pool Piping, the Fuel Pool Piping Valves, the Fuel Pool Filter, the Fuel Pool Strainers, and the Fuel Pool Surge Tank.
Interrogatory 3-6 is answered with respect to each such Fuel Pool component below.
I.
Spent Fuel Pool Heat Exchanges (a)
The heat exchangers are shell and tube type.
The design pressure is 75 psi.
The heat exchangers were built to TEMA " Class A" mechanical standards, except as otherwise noted in the specifications.
The heat exchangers ar'e mounted horizontally, arranged for single pass shell, multipass tubes, counterflow, with straight tubes and fixed tube sheets.
Tubes are 5/8" O.D.,
18 BWG thick in standard 10' lengths and pitched triangular.
Other components of the heat exchanger includd the shell covers, channels, i
l fixed tube sheets, cross baffles, ga.akets, flanged and drilled flat face nozzles, vents, and dra:.ns.
(b)
Struthers Wells Corp., Struthers Wells Division, Warren, Pennsylvania.
(c)
Engineered Process Equipment Co.,
600 Sixteenth Street, Oakland, California.
(d)
Consumers Power Company does not know who manu-factured the components of the fuel pool cooling heat exchanger.
(e)
The composition of the heat exchangers' components is as follows:
Shell-Seamless stell, SA-106 Gr. B (refer to ASME Code)
Shell Nozzles - Seamless Steel, SA-106 Gr. B (refer to ASME Code)
Shell Nozzles - Seamless Steel SA-106 Gr. B (refer to ASME Code)
FCO. (flange) Steel, SA-181 Cl 1 (refer to ASME Code)
Shell Cover - Alum. 5154-0, SB-209 Gr. 40A (refer to ASME Code)
Channel - Alum. 5154-0, SB-209 Gr. 40A (refer to ASME Code)
Channel Nozzles - Alum. 5154-0, SB-209 Gr. 40A (refer to ASME Code)
Tube Sheet - FBX (firebox) STL, SA-295-C with aluminum liner (refer to ASME Code)
Cross Baffles ~ (and Baffle) - Steel (on cooling water side)
Tubes - Aluminum 6061-T6 Gaskets - Composition Asbestos
6 (f)
An answer is not supplied with respect to the first sentence of this question.
The second sentence in (f) is answered as follows:
Bechtel Requisition 3159-M-10 shows the heat exchangers were specified to be completely shop assembled and tested.
The heat exchangers were specified to be in accord with the ASME Code for Unfired Pressure Vessels,Section VIII.
Inspection and tests were specified in accordance with the recommendations of the TEMA for the comple.ted heat exchangers.
According to the Struthers Wells Heat Exchanger Construction Sheet, the heat exchanger shell and tube sides were to be pressure tested at 115 psi.
(g)
An answer is not supplied to this paragraph of Interrogatory 3-6.
(h)
Degradation has been found in certain heat exchanger tubes.
This is documented in Maintenance Order 1-78 SFP-233-10-05 and Maintenance Order 1 SFP-207-02-04.
Tubes showing eddy current signals between 70-100% were plugged.
Following plugging, the heat exchangers were either hydro or leak i
t tested and returned to service.
The degradation was detected by minor increases in activity in the secondary side.
Such activity was not released to the environment.
(i)
Apart from the gradual degradation of certain tubes referred to in (h) which is normal for this type of heat exchanger, Licensee knows of no significant changes which would occur in the heat exchanger as a result of normal operation as a part of the spent fuel pool cooling system.
(j)
See answers to (e), (f), (g) and (h).
(k)
Bechtel Corporation, as primary contractor for the Big Rock Point Plant, was responsible for instal-la. tion of the heat exchangers.
( 1)
Consumers Power Company has found no records relating to the installation of the spent fuel pool cooling heat exchangers.
However, Licensee conducted performance tests on the heat exchangers and other components.
Results of these tests are documented in Performance Test Sequence #29, Fuel Pit Cooling and Filtering System.
( m)
See answers to (f), (g) and (1).
, (n) 40 years - Standard practice at time of manu-facture for nuclear power plant components.
No documentation relating to this choice has been found.
(o)
One stress seen by the spent fuel pool heat exchangers is the thermal stress, which should not significantly effect the operation of the exchangers.
Heat exchangers are specifically designed to handle thermal stresses.
Chemical and physical stresses,. including possibly vibration, also exist and have caused the minor degradation noted in (h) and (i) above.
Corrosion is minimized by control of water chemistry.
The spent fuel pool water chemistry is described in the response to Interrogatory 3-7.
Finally, radiation from impurities in the spent fuel pool water should have no effect on the spent fuel pool heat exchangers.
(p)
The stresses described in (o) above are not expected to have any significant adverse effects on the spent fuel pool heat exchangers for the remaining life of the plant.
This judgment is supported by the minimal degradation seen to date over approxi-J mately 20 years of operation.
(q )
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of i
the spent fuel pool heat exchangers.
However, it is known that the heat exchangers are not seismical-ly qualified.
00)
Bechtel Corporation engineers with decisionmaking input from Consumers Power Company chose the spent fuel pool heat exchangers.
Consumers Power Company has not found any records indicating why these particular heat exchangers were chosen.
B.
Documents Relied Upon Requisition No. 3159-M-10, Rev. 2 " Fuel Pit Cooling Heat Exchanger" (Material required at job site not later than 7/1/61.)
Struthers Wells " Heat Exchanger Construction Sheet" (Drawing Certified for Fabrication 12/12/60)
(copy provided)
Consumers Power Company Performance Test Sequence No. 29, " Fuel Pit Cooling and Filtering System,"
12/4/62 Consumers Power Company Nuclear Plant Maintenance Order 1-78-SFP-2070204 (copy provided)
Consumers Power Company, Nuclear Plant Maintenance Order 1-78-SFP-2331005 (copy provided)
ERC Notes, dated 5/30/80 (copy provided)
Consumers Power Company, Big Rock Point Plant Mechanical Requisition Index (copy not provided)
C.
Documents Reviewed But Not Relied Upon None.
Further Activities None.
(
1
~29-II.
Spent Fuel Pool Piping Valves a)
The spent fuel pool piping system includes Walworth 3" check valves, Mark #258; 125 psi cast iron A-126.
They are flanged, bolted cap or body joint, stainless trim, renewable seat, balanced type swing disc valves.
The system also includes Walworth 2" gate valves mark #51F, cast iron A-126.
They are screwed clamp-type bolted bonnet with M and F body joint, stainless steel trim, solid wedge disc valves.
The system also includes Chapman 3" and 4" gate valves, mark #49, 150 psi cast iron A-126.
They are flanged, bolted bonnet, non-rising stainless steel trim; double disc, parallel seat AWWA pattern valves.
The system also includes Walworth 4" globe valves, mark 152, 125 psi cast iron A-116.
They are flanged ends, bolted bonnet, outside saddle and yoke, stainless steel trim, cone type disc valves.
Finally a Blade Sivalls and Bryson control valve is used to control the water level in the fuel i
pool filter.
No data could be found describing i
l this valve more precisely.
]
i i
I l
_-..-----,J
. 1 b)
The manufacturers are indicated in (a).
c)
The vendors were:
Walworth Company, c/o Pacific Pipe Company, 401 Folsom Street, San Francisco, California and The Chapman Valve Mfg. Co.,
1462 - 67th Street, Emeryville, California.
d)
Consumers Power Company does not know who manu-factured each component of the valves.
e)
For composition of the valve components refer to Requistion 3159-M-110 A and 3159-M-110 B.
f)
An answer is not submitted with respect to the first sentence of this question.
The second sentence in Interrogatory (f) is answered as follows:
Our records show the valves were to be inspected by Bechtel Corp. and not released for shipment pending Bechtel approval.
Consumers Power Company has found no records documenting these approvals.
g)
An answer is not submitted to this-paragraph of Interrogatory 3-6.
h)
None, other than that all valves require normal maintenance.
9 i)
Consumers Power Company knows of no significant
)
changes which would occur to the fuel pool valves as a result of normal operations as a part of the spent fuel pool cooling system.
j)
See answers to (e ), (f), (g) and (h).
k)
Bechtel, as prime contractor for the Big Rock Point Plant, was responsible for initial installa-tion of the fuel pool piping valves.
1)
Consumers Power Company has found no records describing how the valves were installed.
How-ever, review Performance Test Sequence #29, Fuel Pit Cooling and Filtering System, for test results, m)
See answers to (f), (g) and (1).
n) 40 years - Standard practice at the time of manu-facture for nuclear power plant components.
No documentation relating to this choice has been found.
o)
The fuel pool piping valves are external to the spent fuel pool.
However, the valve internals would be exposed to the spent fuel pool water chemistry described in the response to Inter-rogatory 3-7.
No abnormal stresses are anticipated for the fuel pool piping valves.
i l p)
Consumers Power Company does not anticipate any i
adverse effects due to the stresses described l
in (o).
q)
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of the valves.
However, it is known that the valves are not seismically qualified.
r)
Bechtel Corporation engineers with decisionmaking input from Consumers Power Company chose the fuel pool piping valves.
Consumers Power Company records do not explain why these particular valves were chosen.
B.
Documents Relied Upon Requisitions 3159-M-110 A and 3159-M-110 B (copies i
provided)
Piping Schedule M-53 Class M (Bechtel) (copy to be pro-vided ASAP Under separate cover)
Big Rock Mechanical Requisition Index (copy not provided)
Drawing M-111 (Bechtel) (copy not provided)
Walworth and Chapman drawings for valves, (1) C-66623-1, i
(2) D5-2252, ( 3 ) SK-5582-G, (4) SK-5770 (copies provided)
Fuel Pit Cooling and Filtering System #29 Performance Test (copy provided)
Telecon L. Monshor to E.R.C. dated 6/4/80 (copy to be provided ASAP under separate cover)
ERC Notes dated 5/30/80 (copy provided)
C.
Documents Reviewed But Not Relied Upon i
Walworth Sketch 5921 Walworth Report of Chemical & Physical Tests 4/7/61, 3/24/61 Notification of Purchase 9/12/60 Bechtel Purchase Order 3159-M-108-A, 1/26/61 Bechtel Requisition 3159-M-108, 3/24/61 D.
Further Activities None.
. III. Fuel Pool Strainers a)
There are two strainers in each spent fuel pool cooling train.
One in each train is a Crane 4" 125 psi cast iron "Y" pattern sediment separator flanged with 20-mesh monel screen.
The other in each train is a Muessco 2" wye strainer.
b)
The manufacturers of the strainers are indicated in (a).
c)
Crane Supply Co.,
301 Brannon St.,
San Francisco, California furnished the Crane strainer.
Consumers Power Company does not know the vendor for the Muessco strainer.
d)
Consumers Power Company does not know who manu-factured the components of the strainers.
e)
For composition of the ctrainer components, refer to Crane Drawing No. B-39812.
CPCo could not locate any information in its records on the Muessco strainers.
f)
No answer is submitted to the first sentence of this cuestion.
Consumers Power Company has found no records relating to the subject matter of the second sentence.
i
l
. g)
Ho answer is submitted to paragraph g of Inter-rogatory 3-6.
h)
None, other than that the strainers require normal maintenance.
i)
Consumers Power Company knows of no significant changes which would occur to the fuel pool strainers as a result of normal operation as a part of the spent fuel pool cooling' system.
j)
See answers to (e ), ( f ),
(g) and (h).
kj Bechtel Corporation was responsible for installa-tion of the strainers.
1)
Consumers Power Company has found no records describing how the strainers were installed.
How-ever, review Performance Test Sequence 29, Fuel Pit Cooling and Filtering System, for test results.
m)
See answers to (f), (g) ano (1).
n) 40 years - Standard practice at time of manu-facture for nuclear power plant components.
No documentation has been found relating to this choice.
o)
Essentially all fuel pool strainers are external to the opent fuel pool.
However, the strainer internals would be exposed to the spent fuel pool water chemistry described in the response to Interrogatory 3-7.
No abnormal stresses are anti-cipated for the fuel pool strainers.
3 p)
Consumers Power Company does not expect any ad-verse effects on the strainers due to the condi-tions described in (o).
q)
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of the strainers.
However, it is known that the strainers are not seismically qualified.
r)
Bechtel Corporation engineers with decisionmaking input from Consumers Power Company chose the fuel pool strainers.
Consumers Power Company doesn't know why these particular strainers were selected.
B.
Documents Relied Upon Requisition 3159-M-83 (copy provided)
Consumers Power Company Big Rock Point Plant Mechanical Requisition Index (copy not provided)
Crane Dwg #B-39812 (copy to be provided ASAP under separate cover)
ERC notes 3/30/80 (copy provided)
Consumers Power Company Performance Test Sequence No. 29, " Fuel Pit Cooling and Filtering Sequence" (copy provided)
C.
Documents Reviewed But Not Relied Upon None
. D.
Further Activities None IV.
Fuel Pool Piping a)
The majority of the fuel pool piping is seamless aluminum, ASTM B-241, alloys GS11A-T6 or GS10A-T6 Schedule 40, with a primary rating of 125 psi at 100*F.
GS11A-T6 is the same alloy as 6061-T6.
The overflow pipe is seamless carbon steel, ASTM A-53, Grade A, Schedule 40, with primary rating of 125 psi at 350*F.
The old four inch drain line at the bottom of the pool, which was plugged when the liner was in-stalled, is made of stainless steel, b)
Grinnell Company, 260 W.
Exchange St.,
Providence, Rhode Island.
c)
Fuel pool piping was purchased from the vendor identified in (b).
d)
Consumers Power Company does not know who manu-factured the components of the piping, which was purchased complete from Grinnell Company.
e)
Aluminum piping is heat treatable alloy of alumi-num with 1.0% magnesium and 0.6% silicon.
Tensile strength ranges from 18,000 to 45,000 psi with good formability, weldability and corrosion resistance.
. Carbon steel piping contains the following elements:
0.25% C, 0.95% Mn, 0.05% Pb, and 0.06% S.
It has a tensile strength of 48,000 psi.
CPCo has found no data on the stainless steel por-tion of the drain piping.
f)
Aluminum and Carbon Steel Piping No answer is submitted with respect to the first sentence of Interrogatory (f).
The second sentence in Interrogatory (f) is answered as follows:
our records show the fabrication of the piping was to be in keeping with the good practice for the industry and was to conform to criteria set forth by the latest issue of the adopted and tentative specifications of the American Society for Testing Materials, the American Standard Code for Pressure Piping and the American Society of Mechanical Engineer's Boiler and Pressure Vessel Code.
In addition, materials and procedures were to conform to the requirements of the Owner's insuring agent; with proper certification given.
However, Consumers Power Co. has found no records confirming such certification.
All fabrication procedures including preheating, welding, bending and post-treating were to be consistent with Bechtel Specification 3159M-ll3.
Consumers Power Company files show inspection
' records by two purchasing departments of Bechtel dated 7/26/61 releasing shipment of piping, an inspection report (Bechtel) dated 6/7/61 regarding aluminum piping fabrication and a letter from Bechtel to Grinnell dated 6/15/61 approving the aluminum pipe spool sketches and others.
g)
No answer is submitted to paragraph g.
of Inter-rogatory 3-6.
h)
In 1972 a reactor scram occurred while the spent fuel pool system was operating with a partial recycle through the radwaste system.
The scram closed the sphere isolation valves and stopped the fuel pool pump.
This condition trapped water in the line Jrom the fuel pool fill pipe, through the recycle line to radwaste such that when the sphere isolation valves were reopened without restarting the fuel pool pump, a siphoning effect was initiated, drawing water from the fuel pool to radwaste.
The situation was resolved without any adverse effects by operator action.
Subsequently, three small holes were drilled in the fuel pool fill pipe to act as a vacumn breaker in the fuel pool fill pipe when fuel pool water level drops below them.
A confirmatory test of this function was satisfactorily performed.
. 1)
Consumers Power Company knows of no significant changes which would occur to the fuel pool piping due to exposure to pool water.
j)
See answers to (e), (f), (g) and (h).
k)
Bechtel was responsible for installation of the initial fuel pool piping.
1)
Consumers Power Company has found no records in this area.
However, review Performance Test Sequence
- 29, Fuel Pit Cooling and Filtering System, for test results.
m)
See answers to (f), (g) and (1).
n) 40 years - Standard practice at the time of manu-facture for nuclear power plant components; no documentation has been found relating to this choice.
o)
Virtually all fuel pool piping is external to the spent fuel pool.
However, the piping internals would be subjected to the spent fuel pool water chemistry described in the answer to Interrogatory 3-7.
No abnormal stresses are anticipated for the fuel pool piping.
i
- 4 p)
The effects of the stresses described in (o) are expected to be negligible.
l q)
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of the spent fuel pool piping. However, it is known that the spent fuel pool piping is not seismically qualified.
r)
Bechtel Corporation engineers with decisionmaking input from Consumers Power Company chose the fuel pool piping carbon steel for the overflow pipe because it is not normally in contact with spent fuel pool water and therefore the additional corrosion resistance of aluminum was not necessary.
Consumers Power Company does not know why the particular aluminum and stainless piping described in (a) was chosen.
B.
Documents Relied Upon Bechtel Piping schedule M-53 Classes F and M (copy provided) Consumers Power Company Big Rock Point Plant Mechanical Requisition Index (copy not provided)
Becthel Requisition 3159-M-ll3 and accompanying one page note (copy provided) Bechtel Purchase Order 3159-M-ll3 (copy provided) Ryerson Stock List Edition 118 (copy not provided)
. Bechtel Inspection Report dated 7/6/61 (copy provided)
Approval letter Bechtel to Grinnal dated 6/15/61 and attached Bechtel correspondence dated 6/6/61 and 5/9/61 (copies to be provided ASAP under separate cover)
Bechtel Purchasing Department Inspection 7/26/61 (copy to be provided ASAP under separate cover)
Consumers Power Company Performance Test Sequence No. 29, " Fuel Pit Cooling & Filtering System" (copy provided)
Weekly Operations Report #488 (copy provided)
PRC Meeting Minutes dated April 4, 1972 (Incident 1-72)
(copy to be provided ASAP under separate cover)
Operating Incidents Report 1-72 dated January 25, 1972 (copy to be provided ASAP under separate cover)
Letter Sewell to Morris 3/3/72 (copy to be provided ASAP under separate cover)
Design and Safety Analysis Report dated 4/23/79 C.
Documents Reviewed But Not Relied Upon Bechtel Inspection Report dated 1/27/62 (copy provided)
Bechtel Inspection Report No. 2 dated 1/6/61 (copy provided)
Bechtel Engineering Progress Report dated 11/16/61 (copy provided)
Bechtel Engineering Progress Report dated 6/2/61 (copy provided)
Bechtel Engineering Progress Report dated 7/15/61 (copy provided)
Bechtel Engineering Progress Report dated 11/16/61 (copy provided)
Grinnell c'orged Carbon Steel Flanges Catalog WF-58 (copy provided)
Letter from D.
G. Burr of Grinnell Company to J
Bechtel Corp dated 1/23/61 (copy provided) 1 Grinnell Company Schedule C Net Prices, Carbon Steel, Butt Welding Fittings (copy provided)
Teletype from E.M.
Pease to E. Darlow of Bechtel Corp. dated 3/16/61 (copy provided)
Letter from E. M. Pease of Grinnell Company to E.
Barlow of Bechtel Corp. dated 3/17/61 (copy provided)
Letter, same as above, different letterhead (copy provided)
l
- E
)
File, " Pipe and Fittings for Condensate and Demin.
1 Water Lines" identified as M-105 and No. 259912 (copy provided)
Bechtel Corp. Purchase Order No. 3159-M-113 dated
)
10/25/60, plus attachments (copy provided)
{
Letter from A. E. Walmsley of Grinnell Company to E.
Barlow of Bechtel Corp. dated 12/1/60 i
(copy provided) l Bechtel Corp. Inter-Office Memorandum dated 11/11/60 and attachments (copy provided)
Bechtel Corp. Inter-office Memorandum dated 10/25/60 j
and attachment (copy provided) i Letter from E. M.
Pease of Grinnell Company to i
E.
Barlow of Bechtel Corp. dated 10/13/60 (copy provided)
Grinnell Company Unit Price Schedule dated 10/13/60 d
(copy provided) j Grinnell Company Resale Discounts Applying to Pipe j
Fittings Catalog PF-1960 effective 9/1/60,
)
Schedule "G" Section 1 and attachments j
(copy provided) j Letter from B. H. Randolph of Bechtel Corp. to
]
A.
E. Walmsley of Grinnell Company dated i
1/30/61 (copy provided)
Letter from K. E. Wilkinson of Grinnell Company to l
B.
H. Randolph of Bechtel Corp. dated 1/26/61 j
and attachments (copy provided)
Bechtel Corp. Engineering Progress Report dated i
8/31/61 (copy provided)
[
Sheet 4 of Requisition 3159-M-113 Rev. 2 (copy provided) i Sheet 7 of Requisition 3159-M-113 j
(copy provided)
{
Harry W. Taylor Company " Customer's Packing Slip" dated 9/6/73 and attachments (copy provided)
)
e i
1
, V.
Fuel Pit Water Circulation Pumps a)
The (2) spent fuel pool circulation pumps are centrifugal horizontal 2-1/2 x 2-1/2 GH6 pumps.
Each pump has a flow capacity of 250 gallo..s per minute.
The components of the pumps are:
casing impeller suction ring stuffing Box ring shaft sleeve waterseal valve set packing seal cage split gland impeller retaining nut stuffing box cover casing gasket gaskets deflector shaft casing bolts b)
The SFP circulation pumps are manufactured by:
Allis-Chalmers Mfg. Co., 650 Harrison St.,
San Francisco, California c)
Licensee purchased the SFP circulation pumps from:
Allis-Chalmers Mfg. Co.,
650 Harrison St.,
San Francisco, California d)
Consumers Power Company does not know who manu-factured the components of the pumps.
The pumps were purchased as a package from Allis-Chalmers.
. e) casing - cast iron impeller - bronze suction ring - bronze stuffing box ring - bronze shaf t sleeve - bronze set packing - graphited asbestos seal cage - Bakelite i
split gland - bronze impeller retaining nut - 416 stainless steel Stuffing Box Cover - cast iron Deflector - synthetic rubber shaft - stainless steel casing bolts - steel Consumers Power Company has no records indicating the composition of the waterseal valve, casing gasket, and other gaskets.
f)
No answer is submitted with respect to the first sentence of this question.
Regarding the second sentence of this interrogatory, no QA programs comparable to those in existence today were in effect at the time the SFP circulation pumps were i
manufactured.
However, in keeping with good l
engineering practice the SFP circulating pumps were designed to be free from undue vibration and r
to withstand all stresses that would be developed throughout the entire operating range as well as stresses due to full voltage starting.
The crit-ical speed was designed to be a safe margin above operating speed.
g)
No answer is submitted paragraph g. of Interrog-atory 3-6.
i
)
i d
1 P
h
. -, - - - -...., -. -,,, ~ - - -..
.,,..,..,..-.__.-,.,,-,,,,.,,..,,,,...-.n
. h)
There have not been any problems identified in the use of the spent fuel pool circulation pump compo-nents, either in general or in the spent fuel pool environment in particular.
i)
Consumers Power Company knows of no significant changes which would occur to the spent fuel pool circulation pumps as a result of normal operation as a part of the spent fuel pool cooling system.
j)
See answer to interrogatories 3-3(e), (f), (g) and (h).
k)
Bechtel Corporation of San Francisco, California was the prime contractor and therefore was respon-sible for installation.
1)
Consumers Power Company has found no records on the details of installation of the spent fuel pool circulation pumps.
However, Review Performance Test Sequence #29, Fuel Pit Cooling and Filtering System, for test results.
m)
See answer to (f), (g) and (1).
n) 40 years - Standard practice at time of manufacture for nuclear power plant components.
No documentation relating to this choice has been found.
o)
The spent fual pool circulation pumps and their components will be exposed to the thermal, chemical and radiological stresses associated with spent fuel pool water, as described in the response to Interrogatories 3-2 and 3-7.
I p)
The effects of these stresses are negligible.
q)
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of the spent fuel pool circulation pumps. However, it is known that the spent fuel pool circulation pumps are not seismically qualified.
r)
Consumers Power Company has no documentation that explains why Bechtel Power Corp. chose this design over other designs.
B.
Documents Relied Upon Requisition 3159-M-21, Rev. 1 (For August 1, 1961 delivery) and eight pages of attached correspondence.
(Copies provided. )
C.
Documents Review But Not Relied Upon l
None.
D.
Further Activities l
None.
VI.
Spent Fuel Pool Surge Tank a)
The spent fuel pool surge tank is a rectangular open top tank (23'-10" L x 4'3" W x 7'-0" D) of welded aluminum construction (5052-H32/3/16" aluminum) with nominal capacity of 4750 gallons.
The tank also has three horizontal stiffeners consisting of 4" aluminum channels around inside periphery of tank.
These channels are tied to-gether with 3" x 2" x 1/4" cross angles.
. b)
Niles Steel Tank Company, 713 Wayne Street, Niles, Michigan.
c)
Niles Steel Tank Company, 713 Wayne Street, Niles, Michigan.
d)
Consumers Power Company does not know who manu-factured the components of the surge tank.
The SFP surge tank was purchased as a package from Niles Steel Tank Company, e) 5052-H32 aluminum plate 3/16" thick 4 inch aluminum channels 3" x 2" x 1/4" aluminum cross angles SCH 40 Bevelled aluminum welding fittings f)
No answer is submitted with respect to the first sentence of this question.
Regarding the second sentence of this interrogatory, no QA programs were in effect at the time this tank was purchased.
However, in keeping with good engineering practice the SFP surge tank was built to the then applicable API Specifications for Welded Aluminum-Alloy Storage Tanks.
Also, upon delivery of the SFP surge tank to the plant site, in the presence of a j
Bechtel Corporation inspector, the tank was to be filled with water and exhibit maximum plate deflec-tion of the walls of not more than 3/16" in eight feet of length.
. g)
No answer is submitted to paragraph g. of this l
Interrogatory.
h)
No known problems have been identified in the use of the SFP surge tank in general or in the Big Rock Point Plant spent fuel pool environment in particular.
i)
Consumers Power Company knows of no significant changes which would occur to the SFP surge tank as a result of normal operation of the spent fuel pool.
j)
See answers to (e), (f), (g) and (h).
i k)
Bechtel Corporation, San Francisco, California, was the prime contractor and was responsible for installation.
1)
Consumers Power Company has found no records on installation of the SFP surge tank.
m)
See answers to (f), (g) and (1).
n) 40 years - Standard practice at time of manufacture for nuclear power plant components.
No documenta-tion relating to this choice has been found.
o)
Since the SFP surge tank contains only SFP water of a low temperature thermal stresses are negligible.
Another stress would be the stress of supporting 4750 gallons of water.
However this was what the SFP surge tank was designed to do.
l i
. p)
The above stresses are negligible.
q)
No documentation has been found in the Licensee's files that describes the type of combined loading analysis that was performed during the design of the spent fuel pool surge tank. However, the surge tank is braced to withstand a.05g lateral load imposed by earthquake.
r)
This SFP surge tank was chosen by engineers of the Bechtel Corporatior with decisionmaking input from Consumers Power Company.
Other designs from other manufacturers were considered.
This design was chosen because the manufacturer of the SFP surge tank had done competent work on other projects connected with the construction of the Big Rock Point Plant.
Moreover, the Niles Steel Tank Company design met design criteria and Niles chose 5052-H-32 aluminum rather than 6061-T6 aluminum for the material to be used (5052-H-32 aluminum is comparable in strength and unit cost to 6061-T6 and is more easily welded).
B.
Documents Relied Upon Requisition No. 3159-M-218 Rev. 1 and attachments (copy provided)
C.
Documents Reviewed But Not Relied Upon None.
D.
Further Activities l
None.
1
l
. \\
I VII. Spent Fuel Pool Filter a)
The Big Rock Point Plant spent fuel pool' filter l
(often referred to as a sock filter, because of its appearance) is a pressure filter with 180 gallons per minute continuous flow capacity, designed for 50 psig working pressure used to remove algae and/or dirt from the spent fuel storage pool water.
This filter is provided to insure sufficient water clarity for good spent fuel pool visibility.
b)
Ronniger - Retter Company, Vicksburg, Michigan.
c)
Original filter was purchased from Ronniger -
Retter Company, Vicksburg, Michigan.
Replacement filter socks are purchased from National Filter Media Corp., Hamden, Connecticut.
d)
The Diatomaceous Earth Coating for the sock filters is supplied by Johns Manville Corporation.
Consumers Power Company does not know who manufactured the components of the fuel pool filter.
e)
All metal in contact with the fuel pool water is aluminum to avoid scaling.
Gaskets are standard asbestos composition material.
Filtering screens are stainless steel.
Filter Sock Retaining rings are Carbon Steel.
Filter socks are 100% cotton.
, f)
No answer is submitted with respect to the first sentence of this question.
Consumers Power Company has no records relating to the second sentence.
g)
No answer is submitted to paragraph g. of this Interrogatory.
h)
Problems associated with the use of the spent fuel filter center around handling.
The sock filters are normally removed by remote handling techniques (long poles with decoupling type hooks on the ends).
Since the filter performs no safety function, this handling problem does not threaten the safe operation of the spent fuel pool.
Shielding has been added to reduce occupational doses during this replacement procedure.
i)
The only change that occurs to the spent fuel filter takes place in the sock filters themselves.
These sock filters become clogged and radioactive with time and must be removed and replaced periodi-cally.
This change does not impact in any way the integrity of the spent fuel filter or the safe operation of the spent fuel pool.
j)
See answers to (e), (f), (g) and (h).
k)
Bechtel Corporation, San Francisco, California was the primary contractor and was responsible for installation.
1
i
. 1)
Consumers Power Company has found no records relating to installation of the Fuel Pool Filter and therefore cannot provide the requested de-scription.
However, review Performance Test Se-quence #29, Fuel Pit Cooling and Filtering System, for test results.
m)
See answers to (f), (g) and (1).
n) 40 years - Standard practice at time of manufac-ture for nuclear power plant components.
No docu-mentation relating to this choice has been found.
Sock filters themselves are replaced periodically.
o)
The only stress seen by the spent fuel pool filter is the radioactive crud build-up seen by the cotton sock filters themselves.
Thermal stresses are considered negligible due to the low operating temperatures.
p)
The effects of radioactive crud build-up are minimal because-the sock filters are normally removed and replaced before any significant degrada-tion takes place.
q)
No documentation has been found in the Licensee's files that describe the type of combined loading analysis that was performed during the design of the spent fuel pool filter.
However, it is known that the filter is not seismically qualified.
, r)
Spent fuel pool filter used was chosen by engineers of the Bechtel Corporation with deciaionmaking input from Consumers Power Company.
This design was chosen because of its filtering capability, quick change feature of sock filters and relatively long length of time avai,lable between changes of sock filters.
B.
Documents Relied Upon Letter to Burr H. Rendolph, (Bechtel) from W. C. Cooper, Consumers Power Company, dated 8/2/60, and attachments (copy provided).
C.
Documents Reviewed But Not Relied Upon None.
D.
Further Activities None.
Interrogatory 3-7 Dr. John Weeks, an NRC consultant, recently informed the NRC that a number of stress corrosion cracks have been discovered in Type 304 austenitic stainless steel pipe containing boric acid in spent fuel storage pools.
Letter to Herbert Conrad, NRC Division of Systems Safety, October 30, 1979).
Weeks stated that PWR spent fuel pools frequently contain several thousand ppm of boric acid, which is used with demineralizer resins to remove radioactive halides from the pool water.
(BNL-NUREG 23021, pp. 3-4).
Please provide the following information concerning the use of boric acid, the function that boric acid performs in other spent fuel pools, and the chemistry of the spent fuel pool water:
a.
Has boric acid or boron ever been used in connec-tion with the spent fuel storage pool at Big Rock?
. b.
If boric acid or boron has been used in the spent fuel pool, please explain how and when it has been used and provide a complete description of its function.
c.
Even if not used for any specific purpose, has boric acid or boron ever been present in the pool water?
If so, in what amounts, when, why, and if not intentional, how was it discovered?
d.
Will boric acid or boron be used in connection with the spent fuel pool after the proposed additional spent fuel racks have been installed?
How and for what purposes?
e.
Will boron or boric acid be present in the spent fuel pool water in any amount after the proposed additional racks have been installed?
f.
If neither boron nor boric acid will be used with the demineralizer resins to filer radioactive halides from the pool water, please explain in detail how that function will ba performed.
g.
If neither boron nor boric acid will be used in any way in connection with the spent fuel pool, please explain how the functions that it serves in other spent fuel pools will be performed at Big Rock.
h.
If the answers to Question 3-7(d) and (e) are "no," what tests or studies has the Licensee performed or referred to for assurance that corrosion cracking and other problems found in spent fuel pools where boron or boric acid are present will not occur at Big Rock?
1.
What is the expected normal water chemistry in the expanded capacity spent fuel pool?
j.
What are the maximum expected ranges of the water chemistry in the spent fuel pool?
A.
Answer The answers to (a) throgh (e) are all no.
. f)
Radioactive species in the spent fuel pool water consist of soluble (ionic) and particulate matter.
The purpose of the spent fuel pool filter sock tank is to remove particulate matter suspended in the water.
Spent fuel pool water can be routed to the rad-waste demineralizer for removal of soluble (ionic) species (such as radioactive halides).
These demineralizers do not require the presence of boron or boric acid to perform this function.
g)
Neither boron nor boric acid is used in the Big Rock Point Plant spent fuel pool.
Pressurized water reactors (PWR's) use boric acid in the primary coolant system for reactivity control.
One consequence of this is that PWR's also are designed to have boric acid in their spent fuel pool water, because the primary system and the spent fuel pool water inter-mix during refueling.
Boiling water reactors, such as Big Rock Point Plant, do not employ boric acid in their primary systems for reactivity control.
Since the primary system and spent fuel pool water also inter-mix in BWR's during refueling, BWR spent fuel water is kept free of boric acid to avoid contaminating the primary system.
It should be noted that while the boric acid in PWR spent fuel pools performs the incidental function of reducing reactivity, current NRC guidance does not allow licensees or vendors to take credit for this effect.
Thus sub-criticality in PWR and BWR spent fuel pools is ensured by the geometry of the racks and in some cases (not including Big Rock Point Plant), by the presence of neutron-absorbing materials in the rack structure.
h)
The BWR spent fuel pool utilizes demineralized water where, unlike PWR spent fuel pools using boric acid, there have been no corrosion or stress-corrosion service failures.
Extensive tests or studies for Big Rock Point were not necessary because the corrosion and stress-corrosion characteristics of demineralized water have been adequately identified by many investi-gators.
Thus, corrective measures to deal with such corrosion are well-known, i.e.,
carefully controlled water chemistry for the pool, and these measures have been and are being implemented at the Big Rock Point Plant.
i)
Conductivity 1-2 umhos/cm pH 6.5 - 7.5 Chloride 4 20 ppb j)
Conductivity 10 umhos 1 cm pH 6-8 Chloride ( 40 ppb
,,. *
- B.
Documents Relied Upon Big Rock Point Spent Fuel Pool - daily plotc of fuel pool water chemistry (copies not provided).
C.
Documents Reviewed But Not Relied Upon None.
D.
Further Activities None.
f Jo ph Gplo of the Attorneys for Consumers Power Company Isham, Lincoln & Beale 1120 Connecticut Avenue, N.W.
Suite 325 Washington, D.C.
20036 202/833-9730 l
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