ML050270046

Summary of Telephone Conference Held on January 10, 2005, Between the U.S. Nuclear Regulatory Commission and Nuclear Management Company, LLC, Concerning Draft Requests for Additional Information Pertaining to the Point Beach Nuclear

ML050270046
Person / Time
Site:	Point Beach
Issue date:	01/19/2005
From:	Veronica Rodriguez NRC/NRR/DRIP/RLEP
To:	Nuclear Management Co
Rodriguez VM, RLEP/DRIP/NRR, 415-3703
References
Download: ML050270046 (16)

Text

January 19, 2005 LICENSEE: Nuclear Management Company, LLC FACILITY: Point Beach Nuclear Plant, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE HELD ON JANUARY 10, 2005, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NUCLEAR MANAGEMENT COMPANY, LLC, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of Nuclear Management Company, LLC (NMC) held a telephone conference on January 10, 2005, to discuss and clarify the staffs requests for additional information (RAIs) concerning the Point Beach Nuclear Plant, Units 1 and 2, license renewal application. The conference call was useful in clarifying the intent of the staffs RAIs. provides a listing of the meeting participants. Enclosure 2 contains a listing of the RAIs discussed with the applicant, including a brief description on the status of the items. contains draft responses provided by the applicant.

The applicant had an opportunity to comment on this summary.

/RA/

Verónica M. Rodríguez, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosures:

As stated cc w/encls: See next page

ML050270046 DOCUMENT NAME: E:\Filenet\ML050270046.wpd OFFICE PM:RLEP SC:RLEP NAME VRodríguez SLee DATE 1/14/05 1/19/05 Point Beach Nuclear Plant, Units 1 and 2 cc:

Jonathan Rogoff, Esq. Mr. Jeffrey Kitsembel Vice President, Counsel & Secretary Electric Division Nuclear Management Company, LLC Public Service Commission of Wisconsin 700 First Street P.O. Box 7854 Hudson, WI 54016 Madison, WI 53707-7854 Mr. Frederick D. Kuester David Weaver President and Chief Executive Officer Nuclear Asset Manager We Generation Wisconsin Electric Power Company 231 West Michigan Street 231 West Michigan Street Milwaukee, WI 53201 Milwaukee, WI 53201 James Connolly John Paul Cowan Manager, Regulatory Affairs Executive Vice President & Chief Nuclear Point Beach Nuclear Plant Officer Nuclear Management Company, LLC Nuclear Management Company, LLC 6610 Nuclear Road 700 First Street Two Rivers, WI 54241 Hudson, WI 54016 Mr. Ken Duveneck Douglas E. Cooper Town Chairman Senior Vice President - Group Operations Town of Two Creeks Palisades Nuclear Plant 13017 State Highway 42 Nuclear Management Company, LLC Mishicot, WI 54228 27780 Blue Star Memorial Highway Covert, MI 49043 Chairman Public Service Commission Fred Emerson of Wisconsin Nuclear Energy Institute P.O. Box 7854 1776 I Street, NW., Suite 400 Madison, WI 53707-7854 Washington, DC 20006-3708 Regional Administrator, Region III Roger A. Newton U.S. Nuclear Regulatory Commission 3623 Nagawicka Shores Drive 801 Warrenville Road Hartland, WI 53029 Lisle, IL 60532-4351 James E. Knorr Resident Inspector's Office License Renewal Project U.S. Nuclear Regulatory Commission Nuclear Management Company, LLC 6612 Nuclear Road 6610 Nuclear Road Two Rivers, WI 54241 Point Beach Nuclear Plant Two Rivers, WI 54241

DISTRIBUTION: Note to Licensee: NMC, LLC, Pt. Beach Nuclear Plant, Units 1 and 2, Re:

Summary of Telephone Conference Held on January 10, 2005, Dated: January 19, 2005 Adams Accession No.: ML050270046 HARD COPY RLEP RF E-MAIL:

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S. Duraiswamy Y. L. (Renee) Li RLEP Staff P. Lougheed, RIII J. Strasma, RIII A. Stone, RIII H. Chernoff W. Ruland C. Marco L. Raghavan T. Mensah OPA

LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE TO DISCUSS THE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION JANUARY 10, 2005 Participants Affiliations J. Knorr Nuclear Management Company, LLC M. Morgan Nuclear Regulatory Commission G. Suber Nuclear Regulatory Commission V. Rodriguez Nuclear Regulatory Commission Enclosure 1

DRAFT REQUESTS FOR ADDITIONAL INFORMATION (RAI)

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION January 10, 2005 The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of Nuclear Management Company, LLC (NMC) held a telephone conference call on January 10, 2005, to discuss and clarify the staffs requests for additional information (RAIs) concerning the Point Beach Nuclear Plant, Units 1 and 2, license renewal application (LRA). The following RAIs were discussed during the telephone conference call.

Section 3.3 - Aging Management of Auxiliary Systems RAI 3.3-1 In LRA Tables 3.3.2-3, 3.3.2-7, and 3.3.2-9, heat exchangers and heater/coolers with heat transfer as the intended function are identified with only internal environments and associated aging effects. The external environment is listed as N/A. The applicant is requested to explain why the external environment and associated aging effects are not identified for these components. The applicant is also requested to address the similar question for the heat exchangers and heater/coolers in Tables 3.3.2-2, 3.3.2-3, 3.3.2-4, 3.3.2-5, 3.3.2-7, and 3.3.2-9 which have a pressure boundary as their intended function.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

RAI 3.3-2 LRA Table 3.3.2-7 identifies no aging effects for neoprene expansion joints with an internal environment of air and wetted gas less than 140EF. Also, LRA Table 3.3.2-13 identifies the aging effects change in material properties and cracking for neoprene expansion joints with an internal environment of indoor with no air condition but does not identify an aging management program for these aging effects. For similar neoprene components in a warm, moist environments, the GALL report identifies the aging effects hardening and loss of strength and recommends a plant specific AMP to manage these aging effects. The applicant is requested to provide justification why no aging effects were identified for the internals of the expansion joints in Table 3.3.2-7 and why no aging management program is identified to manage the aging effects for the expansion joints in Table 3.3.2-13.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

RAI 3.3-3 LRA Table 3.3.2-14 identifies the loss of material as an aging effect for carbon steel piping and fittings, and valve bodies in a raw water drainage environment. The applicant identifies the Enclosure 2

One-Time Inspection Program, LRA Section B2.1.13, to manage this aging effect. NUREG-1801, XI.M32 recommends one-time inspections as an appropriate aging management program where either an aging effect is not expected to occur but there is insufficient data to completely rule it out, or an aging effect is expected to progress very slowly. In cases where an aging effect is likely to occur, NUREG-1801 recommends periodic inspections. The staff does not consider a one-time inspection appropriate to manage the loss of material for carbon steel components in a raw water environment. The applicant is requested to justify use of a one-time inspection program to manage the loss of material for carbon steel components in a raw water environment.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

RAI 3.3-4 LRA Table 3.3.2-7 identifies no aging effects for carbon and low alloy steel tanks in a concrete environment. Staff notes that concrete has a high pH which is a natural inhibitor for steel; however, concrete contaminated with chlorides or concrete in contact with acidic water is subject to loss of material due to general, pitting, and crevice corrosion. The applicant is requested to describe the basis for concluding that no aging effects occur in this environment.

Also state the specific tanks, the location of the tanks including the external environment, describe how the concrete interfaces with the tanks, and discuss if chlorides or acidic water can be present in this environment.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

RAI 3.3-5 LRA Tables 3.3.2-7 and 3.3.2-9 identify the Periodic Surveillance and Preventive Maintenance (PSPM) program to manage the loss of heat transfer due to fouling for heat exchangers in oil, fuel oil, outdoor, and wetted air and gas environments. The monitoring and trending element in the applicants PSPM states that inspections, examination, testing, and component replacement activities are performed on a specified frequency based on operating experience or other requirements. The applicant stated that the results of these surveillance and preventive maintenance activities are documented, and subject to review and approval. NUREG-1800, Section A.1.2.3.5 recommends that monitoring and trending activities be described, and they should provide predictability of the extent of degradation and thus effect timely corrective actions. Plant specific and/or industry operating experience may be considered in evaluating the appropriateness of the technique and frequency. The applicant is requested to describe the inspection technique and frequency. The inspection frequency should be justified by plant operating experience and should be adequate to detect the aging effects such that the intended function will be maintained during the period of extended operation.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

Enclosure 2

RAI 3.3-6 Loss of preload is an aging effect for closure bolting in high temperature or high pressure systems. NUREG-1801, XI.M18, Bolting Integrity program provides aging management inspections for this aging effect. LRA section 3.3 for the auxiliary systems does not identify loss of preload as an aging effect for closure bolting. The applicant is requested to discuss why the loss of preload was not identified as an aging effects for auxiliary systems closure bolting and the inspections in NUREG-1801, XI.M18 were not credited for managing this aging effect. This RAI is also applicable for closure bolting in the ESF and SPCS.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

Section 4.3.13 - Crane Load Cycle Limit RAI 4.3.13-1 LRA Section 4.3.13, Crane Load Cycle Limit, states that the load limit of the containment polar, auxiliary building, and turbine hall cranes are designed in accordance with CMAA-70 Class A service for 20,000 to 200,000 load cycles, and based on conservative usage assumptions, the cranes are expected to make 50,000 partial load lifts and less than 5.000 at or near rated load lift for the period of extended operation. The applicant is requested to provide the basis for concluding that 50,000 partial load lifts and less than 5,000 at or near rated load lift are in accordance with design of 20,000 to 200,000 load cycles.

Discussion: The applicant clarified their draft response. The applicant will provide their formal response in writing.

Enclosure 2

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION The following information is provided in response to the Nuclear Regulatory Commission (NRC) staff's request for additional information (RAI) regarding the Point Beach Nuclear Plant (PBNP)

License Renewal Application (LRA).

The NRC staff's questions are restated below, with the Nuclear Management Company (NMC) response following.

Section 3.3 - Aging Management of Auxiliary Systems NRC Question RAI 3.3-1:

In LRA Tables 3.3.2-3, 3.3.2-7, and 3.3.2-9, heat exchangers and heater/coolers with heat transfer as the intended function are identified with only internal environments and associated aging effects. The external environment is listed as N/A. The applicant is requested to explain why the external environment and associated aging effects are not identified for these components. The applicant is also requested to address the similar question for the heat exchangers and heater/coolers in Tables 3.3.2-2, 3.3.2-3, 3.3.2-4, 3.3.2-5, 3.3.2-7, and 3.3.2-9 which have a pressure boundary as their intended function.

NMC Response:

Due to the way our database was developed and used, tubing assets were identified as two separate components (tubing ID and tubing OD). This allowed us to select an internal environment for each (ID and OD), but since the database required each component to have both an internal and external environment, we would then document the external environment as N/A. This was done to keep internal and external environments somewhat standard (see PBNP LRA Table 3.0-1, Internal Service Environments and Table 3.0-2, External Service Environments). Note that in Tables 3.3.2-3, 3.3.2-7, and 3.3.2-9, you will find a Heat Exchanger (HX) material type with two different internal environments, which is reflective of the environments for the ID and OD of the tubing.

The only components that have a heat transfer intended function are the tubes. External environments (indoor-no air conditioning, outdoor, etc.) would only apply to the shell of the HX, and since the shell only has a pressure boundary function, it (the shell) and its external environment are not identified under the heat transfer intended function. Additionally, the shell is typically made of a different material than the tubes, and therefore would not be represented by the same line item as the tubing in the LRA.

We attempted to explain this in the 3.x.2 tables in the LRA, with Note 8 on each line item that had an N/A for an external environment.

Enclosure 3

This same methodology was used for heat exchangers and heater/coolers that have pressure boundary intended functions, which produces similar results in Tables 3.3.2-2, 3.3.2-3, 3.3.2-4, 3.3.2-5, 3.3.2-7, and 3.3.2-9.

NRC Question RAI 3.3-2:

LRA Table 3.3.2-7 identifies no aging effects for neoprene expansion joints with an internal environment of air and wetted gas less than 140<F. Also, LRA Table 3.3.2-13 identifies the aging effects change in material properties and cracking for neoprene expansion joints with an internal environment of indoor with no air condition but does not identify an aging management program for these aging effects. For similar neoprene components in a warm, moist environments, the GALL report identifies the aging effects hardening and loss of strength and recommends a plant specific AMP to manage these aging effects. The applicant is requested to provide justification why no aging effects were identified for the internals of the expansion joints in Table 3.3.2-7 and why no aging management program is identified to manage the aging effects for the expansion joints in Table 3.3.2-13.

NMC Response:

In accordance with the EPRI report 1002950, Aging Effects for Structures and Structural Components (Structural Tools), Revision 1, August 2003, no aging effects exist for this material in these environments and this is substantiated by PBNP plant specific Operating Experience (OE). We attempted to explain this using Note 16 in Table 3.3.2.7. Note 16 states that elastomer (neoprene, rubber, etc.) components are indoors and not subject to Ultraviolet (UV) or ozone, nor are they in locations that are subject to radiation exposure. These locations are also not subject to temperatures where change in material properties or cracking could occur, i.e., greater than 95ºF.

Although the environment definition implies that temperatures may reach 140 degrees F, the actual individual environments for these specific components were reviewed, and they do not exceed the 95 degree F threshold temperature. As a result, it was determined that these criteria are not exceeded in these instances, and therefore no aging management is required.

NRC Question RAI 3.3-3:

LRA Table 3.3.2-14 identifies the loss of material as an aging effect for carbon steel piping and fittings, and valve bodies in a raw water drainage environment. The applicant identifies the One-Time Inspection Program, LRA Section B2.1.13, to manage this aging effect. NUREG-1801, XI.M32 recommends one-time inspections as an appropriate aging management program where either an aging effect is not expected to occur but there is insufficient data to completely rule it out, or an aging effect is expected to progress very slowly. In cases where an aging effect is likely to occur, NUREG-1801 recommends periodic inspections. The staff does not consider a one-time inspection appropriate to manage the loss of material for carbon steel components in a raw water environment. The applicant is requested to justify use of a one-time inspection program to manage the loss of material for carbon steel components in a raw water environment.

Enclosure 3

NMC Response:

The few components in question are drainage and sump pump discharge piping and valves that are all shown on drawing LR-M-223 Sheet 3, location G-8. The internal environment is referred to as Raw Water - Drainage, but this will typically consist of ground-water coming from the Façade Sumps. Groundwater at PBNP is a non-aggressive environment (see LRA Table 3.5.0-1, responses to items 12 and 13). As this is a non-aggressive environment, we would expect any aging effects to proceed very slowly. Plant operating experience over 34 years of operation has not identified any leakage from these lines. Based on the non-aggressive environment and our plant specific operating experience, the use of one-time inspections to manage this aging effect was considered acceptable. A one-time inspection will provide ample indication of the condition of these components prior to the period of extended operation. Note that the One-Time Inspection Program provides for the option to change to periodic inspections or provide for repairs based on the results of the condition assessment after the one-time inspection.

NRC Question RAI 3.3-4:

LRA Table 3.3.2-7 identifies no aging effects for carbon and low alloy steel tanks in a concrete environment. Staff notes that concrete has a high pH which is a natural inhibitor for steel; however, concrete contaminated with chlorides or concrete in contact with acidic water is subject to loss of material due to general, pitting, and crevice corrosion. The applicant is requested to describe the basis for concluding that no aging effects occur in this environment.

Also state the specific tanks, the location of the tanks including the external environment, describe how the concrete interfaces with the tanks, and discuss if chlorides or acidic water can be present in this environment.

NMC Response:

The tanks referenced in Table 3.3.2-7 are fuel oil storage tanks, T-175A & B, reference drawings LR-M-219 Sheet 2 and Sheet 3. These tanks were installed via a modification to add two additional diesel generators in 1995. The 35,000 gallon carbon steel tanks were installed in a below-grade vault that was backfilled with concrete and are part of the diesel building structure, see arrangement below. The concrete filled vault is not expected to see any ground water infiltration. The ground and lake water has been analyzed for pH, chlorides, and sulfates and has been determined to be non-aggressive (no chloride contamination). The tanks are provided with a secondary containment, leak detection system. The tanks were covered with a high density polyethylene (HDPE) membrane system (40 mil thickness) manufactured by Gundle Lining Systems Inc, Houston, Texas. The membrane was applied to the tank before the tank was set in place and the placement of the concrete fill. Because of the membrane/liner the concrete is not in direct contact with the steel and therefore, chloride contamination is not possible. Associated with the membrane/liner is a collection box and piping routed to the buildings collection/leakage detection system as shown on drawing LR-M-219, Sh 2. The tank membrane/liner is monitored weekly for oil and/or water effluent to the building sump. The carbon steel tanks are not subject to chlorides or acidic water and therefore, have no aging effects requiring aging management.

Enclosure 3 NRC Question RAI 3.3-5:

LRA Tables 3.3.2-7 and 3.3.2-9 identify the Periodic Surveillance and Preventive Maintenance (PSPM) program to manage the loss of heat transfer due to fouling for heat exchangers in oil, fuel oil, outdoor, and wetted air and gas environments. The monitoring and trending element in the applicants PSPM states that inspections, examination, testing, and component replacement activities are performed on a specified frequency based on operating experience or other requirements. The applicant stated that the results of these surveillance and preventive maintenance activities are documented, and subject to review and approval. NUREG-1800, Section A.1.2.3.5 recommends that monitoring and trending activities be described, and they should provide predictability of the extent of degradation and thus effect timely corrective actions. Plant specific and/or industry operating experience may be considered in evaluating the appropriateness of the technique and frequency. The applicant is requested to describe the inspection technique and frequency. The inspection frequency should be justified by plant operating experience and should be adequate to detect the aging effects such that the intended function will be maintained during the period of extended operation.

NMC Response:

By letter dated February 25, 2004 (NRC 2004-0016), Nuclear Management Company (NMC),

LLC, submitted the Point Beach Nuclear Plant (PBNP) Units 1 and 2 License Renewal Application (LRA). During the weeks of April 26 and June 7, 2004, the NRC performed an on-site audit of the PBNP aging management programs and aging management reviews. As a result of this audit and subsequent conversations between NMC and the NRC staff, the NRC staff requested various clarifications to the LRA. By letter dated July 12, 2004 (NRC 2004-0071), NMC submitted these LRA clarifications to the NRC staff. Several of these clarifications involved the Periodic Surveillance and Preventive Maintenance Program (LRA Section B2.1.15), including the responses to Audit items 69, 148 and 196 in the enclosure to this letter.

The response to Audit item 196 provides a table that links the aging effects/mechanisms managed by the Periodic Surveillance and Preventive Maintenance Program with the parameters monitored/inspected and the measurement methodology. The inspection method identified for loss of heat transfer due to fouling is General or Remote Visual. Where the material is in an oil or fuel oil environment, an oil sample will be taken and analyzed for evidence of Microbiologically Induced Corrosion (MIC), corrosion products, and/or other contaminants in lieu of these inspections. General or remote visual examinations will be performed in accordance with the requirements of ASME Section V and 10 CFR 50, Appendix B. This inspection methodology is capable of measuring the parameter monitored (i.e., tube fouling) and providing data that is adequate to conclude the aging effect is managed consistent with the current licensing basis. If a different inspection method is used, the basis for the revised inspection method will be documented. If degradation is identified through a visual inspection, additional Non-Destructive Examination (NDE) may be performed to characterize the degradation and determine the extent of condition. The inspection frequency will be justified by plant-specific operating experience and will be adequate to detect the aging effects such that the intended function will be maintained during the period of extended operation.

Enclosure 3

NRC Question RAI 3.3-6:

Loss of preload is an aging effect for closure bolting in high temperature or high pressure systems. NUREG-1801, XI.M18, Bolting Integrity program provides aging management inspections for this aging effect. LRA section 3.3 for the auxiliary systems does not identify loss of preload as an aging effect for closure bolting. The applicant is requested to discuss why the loss of preload was not identified as an aging effects for auxiliary systems closure bolting and the inspections in NUREG-1801, XI.M18 were not credited for managing this aging effect. This RAI is also applicable for closure bolting in the ESF and SPCS.

NMC Response:

PBNP considered loss of preload to be a design driven effect, and not an applicable aging effect for bolting in the Engineered Safety Feature (ESF), Auxiliary Systems, and Steam and Power Conversion Systems (SPCS) system groupings. Operating temperatures in these three system groupings are below the threshold temperature where creep of the bolting material could occur. Additionally, a properly designed and installed bolted joint will not be affected by loss of preload. Leakage at joints is typically associated with improper joint installation (e.g.,

proper cleanliness, gasketing, and preload) or inadequate joint design, not relaxation of the bolting materials. PBNP procedures for joint installation incorporate industry bolting guidance, which provide for the use of proper lubricants and sound bolt torquing practices. PBNPs plant specific operating experience shows that bolted joint failures due to loss of preload are not occurring within these system groupings. Therefore, the loss of preload due to stress relaxation for closure bolting in Auxiliary Systems, ESF, and SPCS does not require aging management based on system operating temperatures and industry bolting practices.

Also note that the GALL line items for closure bolting in ESF (E.2-a, E.2-b), Auxiliary Systems (I.2-a, I.2-b), and SPCS (H.2-a, H.2-b), do not list loss of preload as an aging effect requiring management. Therefore, PBNPs position that loss of preload is not an aging effect requiring management, is consistent with the GALL for bolting components in these system groupings.

Section 4.3.13 - Crane Load Cycle Limit NRC Question RAI 4.3.13-1:

LRA Section 4.3.13, Crane Load Cycle Limit, states that the load limit of the containment polar, auxiliary building, and turbine hall cranes are designed in accordance with CMAA-70 Class A service for 20,000 to 200,000 load cycles, and based on conservative usage assumptions, the cranes are expected to make 50,000 partial load lifts and less than 5.000 at or near rated load lift for the period of extended operation. The applicant is requested to provide the basis for concluding that 50,000 partial load lifts and less than 5,000 at or near rated load lift are in accordance with design of 20,000 to 200,000 load cycles.

NMC Response:

In response to the unnumbered December 22, 1980 Generic Letter regarding the control of heavy loads (NUREG-0612), Revision 1 to the Six Month Report was transmitted to the NRC on Enclosure 3

January 11, 1982. The submittal contained Appendix B, detailing our crane design review, which has been excerpted below.

APPENDIX B CONTAINMENT POLAR AND TURBINE BUILDING MAIN CRANE DESIGN REVIEW CMAA Specification 70 and ANSI B30.2-1976 apply to the Containment Building, Turbine Building and Auxiliary Building Cranes.

The Containment Building, Turbine Building and Auxiliary Building Cranes were designed to comply with EOCI Specification 61, which was superceded by CMAA Specification 70. The differences between these two specifications which impact the evaluation of the safe handling of heavy loads are addressed below with respect to the Containment and Turbine Building Cranes. The Auxiliary Building Crane will be modified to provide adequate redundant lifting features. The modification will take into consideration the requirements of CMAA specification 70 and ANSI B30.2-1976 and the guidance of Regulatory Guide 1.13.

It is to be noted that the Franklin Research Center, a division of the Franklin Institute, conducted a comparison of the recommendations of CMAA-70 with those contained in EOCI-61. Generally, the requirements of CMAA-70 represent the codification of good engineering practice which should have been incorporated in cranes built to EOCI-61 specification although specific requirements were not contained in EOCI-61. The Franklin Research Center study is addressed in "Technical Evaluation Report", NRC Docket No. 50-334, dated September 24, 1981 performed under NRC Contract No. NRC-03-79-118.

Fatigue Considerations CMAA-70, Article 3.3.3.1.3 provides substantial guidance with respect to fatigue failure by indicating allowable stress ranges for various structural members in joints under repeated loads. EOCI-61 does not address fatigue failure. The requirements of CMAA-70 are not of consequence for the Containment Building and Turbine Building Cranes since these cranes are not generally subjected to frequent loads at or near design conditions (CMAA-70 provides allowable stress ranges for loading cycles in excess of 20,000 cycles) and are not generally subjected to stress reversal (CMAA-70 allowable stress range is reduced to below the basic allowable stress for only a limited number of joint configurations).

As used in the LRA we intended a rated load lift as being equal to or greater than 50 percent of the cranes rating. A partial load lift is less than 50 percent of the cranes rating. The Primary Auxiliary Building crane is the most limiting for rated load lifts, while the Containment crane is most limiting for partial load lifts.

Enclosure 3

The conservative usage assumptions for the two cranes are:

1. Primary Auxiliary Building Crane - Usage is composed of three components, fuel cask lifts (NUHOM), maintenance loads, and original fuel casks (VCS-24). The estimated number of lifts is 2700, 600, and 892 respectively, totaling less than 5,000 lifts for the 60 year life of the plant.

2. Containment Crane - It is assumed that a total of 60 outages, with twenty days of lifting per outage, and a total of 40 lifts per day will produce a total of less than 50,000 lifts for the 60 year life of the plant.

Consistent with our Current Licensing Basis (CLB) and loading and usage patterns, fatigue failures are not a concern for the Containment Building, Turbine Building and Primary Auxiliary Building cranes during the period of extended operation.

Enclosure 3