ML20063M306

Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence

ML20063M306
Person / Time
Site:	Dresden
Issue date:	09/01/1982
From:	Steptoe P COMMONWEALTH EDISON CO., STEPTOE & JOHNSON
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8209100223
Download: ML20063M306 (6)

Text

MO a* ggLATED COM

-* DOCHETED USNRC y 9/1/82

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fu SB)-3 #0:47 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS hG TShfh' ERANCil THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-237-SP COMMONWEALTH EDISON COMPANY ) 50-249-SP (Dresden Station, ) (Spent Fuel Pool Units 2 & 3) ) Modification)

Dear Administrative Judges:

Enclosed are two letters relating to Common-wealth Edison's use of the 9 ton auxiliary hook of the main overhead crane system during the 1981 installation of 5 high density spent fuel racks at Dresden Station. This use was not contemplated by Edison's testimony in this proceeding, and was the subject of my telephone calls to Chief Judge Wolf and the other parties on August 26, 1982.

The first enclosure dated August 30, 1982 is a letter from Doug Scott, Station Superintendent at Dresden.

It explains what happened and why, the safety significance of the use of the crane and the corrective action taken. In addition, this letter indicates that the side of the pool l should have been marked with tape to indicate the safe load path but was not. However, I am informed that the correct load path was taken despite the absence of the marking tape.

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The second letter, dated August 26, 1982, from i

Tom Rausch to Darrell Eisenhut reflects Edison's reporting j

and discussion of this incident with the NRC Staff.

Commonwealth Edison believes that the incident described herein is a matter for NRC Region III, and does not require reopening the record in this proceeding. We sincerely regret the occurrence of this incident.

, Respectfully submitted, A./s l Sk&c /s, hp Philip'P. Steltoe l 'F G

RGP:es Enc.

cc: Service List 1

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SERVICE LIST John F. Wolf, Esq. Federal Express 3409 Shepherd Street Chevy Chase, Maryland 20015 Dr. Linda W. Little Federal Express 5000 Hermitage Drive Raleigh, North Carolina 27612 Dr. Forrest J. Remick Federal Express Apartment 205 The Carriage House 2201 L. Street N.W.

Washington, D. C. 20037 Atomic Safety and Licensing Board Panel Federal Express U.S. Nuclear Regulatory Commission Washing ton, D. C. 20555 Docketing and Service Regular Mail U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Richard Goddard Federal Express U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georget-wn Road Bethesda, Maryland 21202 Philip L. Willman Messenger Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 Alan S. Rosenthal, Chairman Regular Mail U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Washington, D. C. 20555 Thomas S. Moore Regular Mail U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Washington, D. C. 20555 Dr. Reginald L. Gotchy Regular Mail U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Washington, D. C. 20555

August 30, 1982 DJS LTR: 82-922

'IO: D. L. DelGeorge Director of Nuclear Licensing SUBJECI': Failure to Meet Ccmnit:ments Contained in Testimcny for Hearings on the Installation of High Density Spent Fuel Storage Racks at Dresden I. Description of Event On August 24, 1982, Cctmonwealth Edison Quality Assurance personnel at Dresden Station observed that the 9-tcn auxiliary hoist on the 125-ton reactor tuilding overhead crane was being used to rnove high density spent fuel racks still in shipping skids, and rnade an inquiry to deter-mine if the weight of a high density rack in a shipping skid might not exceed the rated capacity of the auxiliary hoist. The cognizant engineer for the reracking operation investigated the matter in response to the O.A. request. The loads and crane capacity are tabulated below:

9 x 11 High density rack 11,770 lbs., or 17,470 lbs. with skid 9 x 13 High density rack 13,825 lbs., or 19,525 lbs. with skid Shipping skid 5,700 lbs.

Old spent fuel rack 1,800 lbs.

9-Ton auxiliary hoist capacity 18,000 lbs.

While reviewing various affadavits and testimony to obtain the requested information, the cognizant engineer also discovered that a ccmnitment by the Station to use the redundant 125-ton main hoist for moving the high density racks was not being met. The reracking was halted and an investi-l gation into the matter was made.

The investigation revealed that following verbal approval of the NRC on September 11, 1981, for partial installaticn of 5 high density racks, the l

9-ton auxiliary hoist was used to install 5 racks in the Unit 3 spent fuel pool on October 8 and 9, 1981. Also, the side of the pool was not Irarked

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with tape to indicate to the crane operator the safe load path to bring l

the new racks over the pool side. All other ccanitments were met (and continue to be met) including mandrel testing, neutron attenuation testing, corrosion surveillance program, etc.

T% ccanitznents to use the redundant 125-ton main hoist and to mark safe load paths are contained in the written affadavit of Scott C. Pedigo of Ccumonwealth Edison Ccutpany, subnitted to the Atcmic Safety and Licensing Board on May 5, 1981.

The reascn for the aforenenticned ccrinitments was the need, during the hearing process, to address the unresolved safety issue of heavy load handling with respect to the reracking operation. The basis of the

The Staticn agreed in the hearings to meet h applicaticn comtitments is NUREU-0612. tiated NUREG-0612 guidelfneu for the reracking operation with the NBC. fi ystem NUREL-0612 guidelines call for either use i htofofaaredundant single li t ng s when handling heavy loads (anything more than the we g fuel assembly) in certain areas of a nuclear power ible plant, such as o fuel pool or reacter cavity, or else providing analyses The single failure proof criteria (redundancy) may bei h a safety fac for all poss load drops.

achieved by use of dual lead carrying equipnent, Theeach 125-tcn w main t

Reactor I

of 5, or single equipnent, with a safety factor of 10. ho l

Buihling overhead crane does not.

II. Safety Significance

_ 9-ton hoist

'Ihe possible irapact on public health and d theof safety worst using the was minimal since no loads were handled over spent fuel an be noderate result of dropping a high density rack in the pool iwouldDropping ent damage to the pool liner.2 f load path.

floor would not cause significant damage to any safety related equ since the entire refueling floor has been designated as a sa e III. Cause d for the The direct cause of Use the of event the 125-ten was inadequate main hoist was written proce ures not specified in reracking operation. Failure to include the aWriate conmitments in the the procedures.

procedures can be attributed to the following factors: d t lly 1.

The Station cognizant engineer on the project, who s coinci en a prepared the testimony on the heavy load handling issue, w f changed in May,1981 'Ihis change as occurred part of aafter normal career canpletion rotation o of the assigned duties.

first and second hearings (in Morris and Chicago The new O' Hare but before the procedures were written and inplemented. f proce-f cognizant engineer who was involved in the first-hand involvement in the hearing process. l The amount of correspondence, affadavits, i of transcripts of ora

2. testimony, findings of fact, partial and final decis cms be reviewed by the ASLB, and orders of the ASLB which had toto extract b bility the assigned SNED and Station cognizant eng that something could be missed.

Dresden Special Report #41 Testimony of Terry A. Pickens, paragraph 41, page 26.

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,IV. Corrective Acticn_ f the The redundant 125-tcn hoist will beTheused hook h

for all futu hoist may be used in uprighting the skids holding the racks. l on the 125-ton hoist is so large that it interferes with otential the skid w en trying to tip the skid frca horizontal to vertical, creating a pThe safety hazard.

density racks away frcm the side of the Reactor Building t The where they ar ll away frcm uprighting operation and the repositicning are perf 1 the spent fuel storage pool. being All affadavits, transcripts, board decisicos and orders, etc. are Proce-reviewed This will ensure dures are alsotc check being thatagainst reviewed no other ccumitnents the ccumitments. have been mis king that all ccumitments will be met by the Staticn and that the rerac operaticn will be carried out as described during the hearing.

Prepared by 4//C S. C. Pedigo /

Technical Staff Approved by .D % cow.

D. J. Scott Qp Superintendent V Dresden Nuclear Power Station DIS:SCP:hjb cc: P. Steptoe J. Mcdonald D. Farrar R. Ragan J. Wulf J. Brunner S. Harris S. Pedigo File /IEA File / Numerical

l C:mm:nwe:lth Edis n one First Mt.one Pista Chggo lihno's .

Accress Reply to Post Othee Box 767 '

Ch cago. Ilknois 60690

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Augus t 26, 1982 Mr. Darrell G. Eise nhu t , Directo r Division o f Licensing U.S. toc 16cr Regulatory Commission Washington, DC 20555

Subject:

Dresden Station Units 2 and 3 Propose d License Amendment Concerning High Density Spent Fuel Racks NRC Docket Nos. 50-237/249 Re ference (a): Cordell Reed letter to E. G.

Case dated May 11, 1978.

Dea r Mr. Eisenhu t :

On August 26, 1982, Commonwealth Edison made initial notification to NRC Region III, Office of Executive Legal Director, Chief Judge Wol f, the State of Illinois, and the Dresden 2 NRR back-up Project Manager that the 1981 initial installation of five (5) high density spent fuel racks into the Dresden 3 spent fuel pool was made utilizing the auxiliary overhead crane. Testimony before the ASLB concerning this proposed amendment had stated that the redundant overhead crane would be used.

To preclude the possibility of a similar occurrence during the future installation and use of the high density fuel storage racks, Commonwealth Edison is taking measures as reflected in the j following proposed license condition to DPR-19 and 25:

Prior to the installation of high density fuel storage racks, the licensee shall review the testimony before the ASLB to ensure that commitments made by Commonwealth Edison regarding the installation and use of these racks will be complied with.

The redundant overhead cfrane will be utilized to install the high density fuel storage racks.

l Please address any questions you may have concerning this matter to this of fice.

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g D. G. Eisenhu t Augus t 26, 1982 One transmittal are(1) signedfor provided original your use. and thirty-nine (39) copies of this Very truly yours,

" v'g Thoma s J. Rausch M; clear Licensing Administrator 1m cc: Region III . inspector Dresden and Service List 4872N l

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