The inspectors identified that the licensee failed to incorporate a heavy load lift analysis into their
UFSAR. Failure to update the
UFSAR to reflect aspects of heavy load lifts involving the reactor vessel head and include information from a reactor vessel head drop analysis was a violation of
10 CFR 50.71(e). The NRC has found industry uncertainty regarding the licensing bases for handling of reactor vessel heads, and as a result issued
EGM 07-006,
Enforcement Discretion for Heavy Load Handling Activities, on September 28, 2007. NEI has informed NRC of industry approval of a formal initiative that specifies actions each plant will take to ensure that heavy load lifts continue to be conducted safely and that plant licensing bases accurately reflect plant practices. The NRC staff believes implementation of the initiative will resolve uncertainty in the licensing bases for heavy load handling, and
enforcement discretion related to the uncertain aspects of the licensing basis is appropriate during the implementation of the initiative. During inspection of heavy load lifts, the inspectors determined that the licensee implemented interim actions prior to the specified lifts in accordance with the industry initiative, thereby meeting the following criteria to warrant enforcement discretion: 1) The licensee had neither a single-failure-proof crane nor a load drop analysis (generic or plant-specific) that bounded the planned lifts with respect to load weight, load height, and medium present, so the licensee conducted the head lift at the minimum practicable height and flooded the refueling cavity with water during the head movement to limit the maximum potential impact velocity of the head. The licensee maintained the bottom of the head less than 15 feet above the refueling cavity water surface when the head was lifted above the guide studs. Once the cavity was fully flooded [greater than 23 feet above the reactor vessel flange], the reactor vessel head was allowed to be lifted more than 15 feet above the water surface as necessary to lift the head above immovable structures around the refueling cavity. 2) Included the movement of heavy loads as a configuration management activity in administrative controls established to implement
10 CFR50.65(a)(4). Therefore, consistent with
EGM 07-006, we are exercising
enforcement discretion for the above violation in accordance with Section VII.B.6 of the
NRC Enforcement Policy and are not issuing enforcement action for the violation.
