Based on a review of the documents listed in the Attachment of this report related to heavy load lifts of the reactor vessel head and discussions with licensee personnel, the inspectors identified the following issues: The licensee could not demonstrate that a risk assessment had been performed for the increase in risk associated with the lifting and setting of the reactor vessel head. The licensee could not demonstrate that their reactor vessel head lifts, which lift the head to approximately 38 feet over the irradiated fuel in the reactor vessel, were bounded by any design calculations which evaluated the drop of the head through air onto the reactor vessel, upper internals, and irradiated fuel. The licensee could not demonstrate that their procedures for the reactor vessel head removal and installation, ever limited their head lifts to the bounds contained in an August 17, 1984 letter sent to the NRC concerning a load drop analysis for reactor vessel head lifts. The licensee could not demonstrate that their
UFSAR had been adequately updated to reflect information and analyses provided to the NRC as the result of all generic communications relative to their resolution of heavy loads issues. The licensee issued
PIPs M-07-3099, M-07-3410, and G-07-0449 to address the above issues. A complex maintenance plan was issued for the most recent head installation that occurred on May 18, 2007, to manage risk. A multi-site team has been formed to address the issues above and to work with vendors to determine whether an alternative design and licensing basis exists that bounds past practices. The issues identified above are greater than minor because they are associated with the design control attribute of the
Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown. The issues are also greater than minor because the failure to update the
UFSAR could have an impact on safety and may require a license amendment for resolution. These issues are unresolved pending the completion of the licensees investigation into whether an alternative design and licensing basis exists and whether reactor vessel head lifts were ever performed within the bounds of that basis. They are identified as
URI 05000369,370/2007003-02, Reactor Vessel Head Lift Practices Related to Design and Licensing Basis
