ML073170705

License Amendment Request 227 Relocation of Spent Fuel Pool Crane Technical Specification to Technical Requirements Manual

ML073170705
Person / Time
Site:	Kewaunee
Issue date:	11/09/2007
From:	Gerald Bichof Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
07-0352
Download: ML073170705 (86)

Text

Dominion Energy Kewaunee, Inc.

';1)1)1) Dominion Boulevard, Glen Allen, VA 231)!J1)

November 9, 2007 U. S. Nuclear Regulatory Commission Serial No: 07-0352 Attention: Document Control Desk KPS/L1C/BG: RO Washington, DC 20555 Docket No.: 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST 227 RELOCATION OF SPENT FUEL POOL CRANE TECHNICAL SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). This amendment would modify the Technical Specification (TS) restricting handling or placement of heavy loads over or in the spent fuel pools and relocates the modified requirements to a licensee-controlled document, the KPS Technical Requirements Manual (TRM).

The modification to the current TS is needed to facilitate future spent fuel cask handling activities in the KPS spent fuel pool. KPS is in the process of upgrading its Auxiliary Building (AB) crane, used for cask handling, to a single-failure-proof design, and constructing an Independent Spent Fuel Storage Installation (ISFSI) for on-site dry storage of spent nuclear fuel (NRC Docket No.72-064). Therefore, the site requires the capability to move spent fuel casks into and out of the spent fuel pool for fuel loading.

DEK has determined that the proposed amendment involves a no significant hazards consideration. This is because the AB crane upgrade provides adequate safety margins and associated commitments pertaining to heavy load control are consistent with the guidance provided in NRC NUREG 0612, "Control of Heavy Loads at Nuclear Power Plants," as described in Attachment 5.

The TS being relocated does not meet the criteria of 10 CFR 50.36(d)(2)(ii), "Limiting Condition for Operation," for inclusion into TS. Therefore, relocating these requirements to the KPS TRM is justified. Future changes to the relocated TRM requirements will be controlled under 10 CFR 50.59.

The proposed amendment is also consistent with NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 3, dated June 2004, as standard TSs do not contain requirements for control of heavy loads.

DEK requests expedited approval of the proposed amendment by May 30, 2008. Once approved, the amendment will be implemented within 60 days. DEK requests an expedited review because KPS will lose full core reserve (FCR) after the spring 2008 refueling outage. To recover FCR, DEK has constructed an ISFSI using the NUHOMS system. The cask loading area in the north spent fuel pool contains a spent fuel rack

Serial No. 07-0352 License Amendment Request 227 Page 2 of 3 seismic restraint that interferes with the placement of the storage cask in the pool for loading. The structure has been evaluated and can be removed. However, to remove the structure, KPS needs approval of this TS amendment, in conjunction with KPS License Amendment Request 234, to allow use of a single-failure-proof crane to move heavy loads in or over the pool. Following removal of the seismic structure, KPS can begin the dry runs required to demonstrate the capability of the ISFSI, and the associated equipment and procedures. Assuming approval of this proposed amendment in late May, the expected time line for this effort is: (1) seismic restraint in the north pool removed by mid to late July, (2) dry runs completed by mid to late September, and (3) completion of four cask loads by late October, prior to the onset of winter weather. to this letter contains a description of the change, safety evaluation, no significant hazards determination, and environmental consideration for the proposed amendment. Attachment 2 contains the marked-up Technical Specification pages. contains the proposed Technical Specification pages as revised. contains the proposed Technical Requirements Manual changes for information only. Attachments 5 and 6 contain compliance matrixes comparing the upgraded KPS Auxiliary Building crane, associated lifting devices, and interfacing lifting points with the guidance in NUREG-0612 and NUREG-0554, respectively. Attachment 7 lists the regulatory commitments made in this LAR.

The KPS Plant Operations Review Committee has approved the proposed amendment request and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91 (b).

If you have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424.

Very truly yours, t~~:~-6 Vice President - Nuclear Engineering COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this q y..... day Of--=)J,---,-_~~_ _, 2007.

N{?:;f~' /!), WAdZt2

• MARGARET I. IENNEn Notary Public .3'S¥...3 60l.

• Commonwealth of Virginia

• My Commlilion Expire. Aug 31. 2008

Serial No. 07-0352 License Amendment Request 227 Page 3 of 3 Attachments:

1. Discussion of Change, Safety Evaluation, Significant Hazards Determination and Environmental Considerations

2. Marked-up TS Pages

3. Affected TS Pages

4. Proposed Technical Requirements Manual Change Pages

5. NUREG-0612 Compliance Matrix for KPS Upgraded AB Crane Lifting System

6. NUREG-0554 Compliance Matrix for KPS Upgraded AB Crane

7. Regulatory Commitments cc: Regional Administrator U. S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Mr. P. D. Milano Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-8-H-4A Washington, D. C. 20555 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

ATTACHMENT 1 LICENSE AMENDMENT REQUEST 227 RELOCATION OF SPENT FUEL POOL CRANE TECHNICAL SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL DISCUSSION OF CHANGE, SAFETY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 1 of 28 Relocation of Spent Fuel Pool Crane Technical Specification to Technical Requirements Manual

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License DPR-43 for the Kewaunee Power Station (KPS). The proposed amendment would modify the language of the current Technical Specification (TS) governing the movement of heavy loads over and in the spent fuel pools and relocate the modified requirements to the KPS Technical Requirements Manual (TRM). The KP8 TRM will preserve the modified controls for heavy load movements over and in the spent fuel pool and ensure that any future changes to these requirements are controlled under 10 CFR 50.59.

The proposed modification to the TS language is needed to facilitate spent fuel cask handling activities over and in the spent fuel pool. KPS is in the process of upgrading its Auxiliary Building (AB) crane, used for spent fuel cask handling, to a single-failure-proof design, and constructing an Independent Spent Fuel Storage Installation (ISFSI) for on-site dry storage of spent fuel. Therefore, the site requires the capability to move spent fuel casks into and out of the spent fuel pool to facilitate dry spent fuel storage.

The T8 being relocated to the KPS TRM does not meet the criteria of 10 CFR 50.36(d)(2)(ii), "Limiting Condition for Operation," for inclusion into T8 and therefore relocation is justified. Future changes to the TRM requirements will be controlled under 10 CFR 50.59. The proposed amendment is also consistent with NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 3, dated June 2004 (reference 1).

2.0 PROPOSED CHANGE

The proposed amendment would modify and relocate the current KP8 T8 3.8.a.7, which is associated with the control of heavy loads over and in the spent fuel pool, to the TRM.

Markups of the TS pages and the revised TS pages are contained in Attachments 2 and 3, respectively.

KP8 T8 3.8.a.7 currently states:

7. Heavy loads, greater than the weight of a fuel assembly, will not be transported over or placed in either spent fuel pool when spent fuel is stored in that pool. Placement of additional fuel storage racks is permitted, however, these racks may not traverse directly above spent fuel stored in the pools.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 2 of 28 The proposed amendment would modify TS 3.8.a.7 to state the following and then relocate the modified TS 3.8.a.7 to the TRM.

7. Heavy loads greater than the weight of a fuel assembly, including its heaviest insert and handling tool, will not be transported over or placed in either spent fuel pool when spent fuel is stored in that pool, unless:

a. The heavy load does not traverse directly above spent fuel stored in the pool's spent fuel storage racks, and

b. The load handling system (e.g., crane, associated lifting devices, and interfacing lift points) used for these heavy load lifts meets the single-failure-proof handling system criteria.

After relocation of this TS to the TRM, the following required action will be added to the TRM (format and numbering will be adjusted to be consistent with the TRM convention):

If, during the movement of the heavy loads over or in the spent fuel pool, the load handling system is determined not to meet the applicable single-failure-proof criteria, then immediately place the suspended load in a safe condition (no longer suspended over the spent fuel pool) and cease further movement over the spent fuel pool until the crane can be repaired or other appropriate corrective actions implemented to restore compliance.

DEK is in the process of replacing the AB crane trolley, controls, hoisting components and upgrading the existing AB crane bridge so that the crane meets the requirements for a single-failure-proof crane as described in NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants" (reference 2), Section 5.1.6, and NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" (reference 3), as described in Attachments 5 and 6. Associated lifting devices and interfacing lift points will also meet the guidance in NUREG-0612, Section 5.1.6, as described in Attachment 5, to ensure the entire AB crane lifting system 1 may be considered single-failure-proof for lifts over or in the spent fuel pool.

Once TS 3.8.a.7 is relocated to the TRM, the proposed amendment also requests to change TS 3.8.a.7 to state:

7. Deleted In summary, the proposed amendment would modify KPS TS 3.8.a.7 to incorporate the use of a single-failure-proof lifting system for handling of necessary heavy loads over or I The "AB crane lifting system" means the AB crane, associated lifting devices, and interfacing lift points, as defined in NUREG-0612.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 3 of 28 in the spent fuel pool with irradiated fuel in either the fuel storage racks or in the just-loaded spent fuel canister in the spent fuel pool. In no case will heavy loads (loads greater than the weight of a fuel assembly, including its heaviest insert and handling tool) be handled over irradiated fuel in the spent fuel storage racks. However, in order to install the spent fuel canister upper shield plug after fuel is loaded into the canister, heavy loads (i.e., the shield plug itself) must be suspended over the irradiated fuel in the canister for the time it takes to align and lower the shield plug into position on the canister.

Once modified, the requirements of TS 3.8.a.7 would be relocated from the KPS TS to the KPS TRM. In addition, after approval of this amendment request, the cask drop accident will be removed from the KPS USAR as a design basis accident. Attachment 4 contains the proposed TRM pages to be implemented after NRC approval of the modification of the TS language and relocation of TS 3.8.a.7 to the KPS TRM.

3.0 BACKGROUND

DEK intends to complete construction and start operation of an ISFSI at the KPS site in the third quarter of 2008, under the general license provisions of 10 CFR 72, Subpart K (Docket No.72-064). DEK will be using the Transnuclear Standard NUHOMS@ dry spent fuel storage system in accordance with 10 CFR 72 Certificate of Compliance (CoC) 1004 and its associated Final Safety Analysis Report (FSAR). The generic Standardized NUHOMS@ System design requires the use of a transfer cask (TC) weighing up to 125 tons during cask handling operations in the AB. The actual weight of the transfer cask depends on, among other things, the TC and dry shielded canister (DSC) models chosen for use by the general licensee, and the fuel type to be loaded.

At KPS, the maximum loaded weight for the TC/DSC assemblage suspended from the AB crane hook and lifting yoke is 105 tons.

Use of the Standardized NUHOMS@ System requires the lifting and movement of heavy loads over the spent fuel pool during cask handling operations. Although movement of heavy loads over the spent fuel pool is required, the arrangement of the spent fuel cask loading pit and loading dock at KPS precludes the need to move heavy loads, including the TC, over irradiated fuel in the spent fuel racks during cask handling operations. The KPS AB crane lifting system will be used to lift and move the TC between the cask loading pit in the spent fuel pool and the loading dock, and to lift and move other heavy loads necessary to use the spent fuel cask in accordance with its 10 CFR 72 CoC and FSAR.

DEK has chosen to upgrade the AB crane lifting system to a single-failure-proof system to enhance the safety of heavy load handling in the spent fuel pool area at KPS and consequently to make a heavy load drop event sufficiently improbable that the lifting

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 4 of 28 system may be considered single-failure-proof, as defined in NUREG-0612, Section 5.1.6. Upgrading the AB crane system to a single-failure-proof system makes load drops while using this lifting system no longer considered credible. The existing AB crane is a 125-ton capacity, non-single-failure-proof Whiting Corporation bridge and trolley design of late-1960s vintage. The AB crane is being upgraded to a single-failure-proof crane by replacing the trolley and hoists with single-failure-proof designs, upgrading the crane controls, and modifying the existing bridge. Associated lifting devices and interfacing lift points will also meet the guidance in NUREG-0612, Section 5.1.6, as described in Attachment 5, in order to ensure that the entire AB crane lifting system is single-failure-proof for each heavy load lift made in or around the spent fuel pool. The design rated load and maximum critical load for the AB crane main hoist will remain 125 tons.

3.1 Fuel Handling System Design and Operation 3.1.1 Spent Fuel Storage The spent fuel pool is a part of KPS's fuel handling system. The fuel handling system provides a safe and effective means of transporting and handling fuel from the time it reaches the plant in an un-irradiated condition until it leaves the plant after post-irradiation cooling. The system is designed to minimize the possibility of mishandling that could cause fuel damage and potential fission-product release.

The Fuel Handling System consists of:

• The reactor refueling cavity,

• The spent fuel pool, and

• The fuel transfer system, including an underwater conveyor that transports fuel assemblies between the reactor refueling cavity and the spent fuel pool.

The spent fuel pool is designed for the underwater storage of spent fuel assemblies, rod control cluster assemblies (RCCAs), burnable poison rod assemblies, and thimble plugs after their removal from the reactor. The spent fuel pool is divided into three storage compartments and a fuel transfer canal, as shown in KPS USAR Figure 9.5-2.

Because the capacity of the spent fuel pool will be reached before plant operation ceases and the U.S. Department of Energy has not met their obligation to begin removing commercial reactor spent fuel from the operating plant sites, DEK has decided to implement on-site dry spent fuel storage under the general license provisions of 10 CFR 72, Subpart K. DEK has chosen the Transnuclear Standardized NUHOMS@ dry spent fuel storage system for use at the future on-site ISFSI. ISFSI construction is underway and ISFSI operations are scheduled to commence in mid-2008, which will enable KPS to minimize the time that full core reserve fuel storage capability in the

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 5 of 28 spent fuel pool is lost. After the KPS 2008 refueling outage, full core offload capability will be lost until spent fuel is moved to the ISFSI.

3.1.2 Overhead Load Handling Systems For handling spent fuel, two cranes are provided: the spent fuel pool bridge and the AB crane. The spent fuel pool bridge is a gantry crane spanning the spent fuel pool. The AB crane is a bridge-and-trolley type crane used for handling various loads, including spent fuel shipping and transfer casks. Fuel assemblies are moved within the spent fuel pool by using the spent fuel pool bridge crane while the AB crane is used for addition of new fuel and withdrawal of spent fuel.

The spent fuel pool bridge has an electric monorail hoist on an overhead structure. The fuel assemblies (new and spent) are moved within the spent fuel pool with the spent fuel pool bridge crane by means of a long-handled tool suspended from the hoist. The hoist travel and tool length are designed to limit the maximum lift of a fuel assembly to a safe shielding depth.

The AB crane was originally designed, fabricated, and qualified in accordance with Electric Overhead Crane Institute (EOCI) Standard No. 61, American National Standard Institute Standard B-30.2.0, 1967 Edition, and Pioneer Service and Engineering Company Standard Specification for Powerhouse Overhead Electrical Traveling Cranes. The AB crane trolley, hoisting components, and controls are being replaced with upgraded designs that meet the single-failure-proof guidance in NUREG-0612, Section 5.1.6, and NUREG-0554, as described in Attachments 5 and 6. Operation of the entire AB crane lifting system will conform to the guidance in NUREG-0612, Section 5.1.6, as described in Attachment 5, to ensure the dropping of a suspended spent fuel transfer cask remains a very improbable event.

The existing AB crane design includes an interlock system employing mechanical limit switches that precludes the trolley passing over irradiated fuel stored in the spent fuel storage racks and safe shutdown equipment. Redundant limit switches are furnished to ensure that the exclusion area is not inadvertently traversed by the malfunction of a single limit switch. Thus, interlocks on the AB crane prevent the transport of heavy loads, such as spent fuel transfer and shipping casks, over the spent fuel racks in the spent fuel pool or canal pool. An override feature is provided to administratively allow free movement of the trolley when spent fuel is not stored in the pool or with no load on the AB crane hook. The override is achieved by the use of a key lock switch and the key is under the control of the shift manager.

In addition, KPS has administrative procedural controls in place limiting the operation of the AB crane by providing safe load paths, pre-designated pathways or areas in which heavy loads can be safely handled, and requiring personnel operating or directing the

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 6 of 28 crane operator to have completed applicable training in accordance with ASME B30.2 (reference 4).

3.2 Regulatory History 3.2.1 NRC and Industry Communication Pertaining to Heavy Load Control In July 1980, the NRC issued NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

By letter dated December 22, 1980, the NRC issued an un-numbered generic letter (reference 5) to the industry stating that the staff had completed its review of Unresolved Safety Issue Task No. A-36, "Control of Heavy Loads Near Spent Fuel."

Licensees were requested to implement specific interim actions within 90 days.

Licensees were also required to submit review results for certain items identified in the letter within six months (Phase I) and within nine months (Phase II).

During the NRC's review of KPS's implementation of Phase I of this issue, numerous letters were exchanged between the NRC and the KPS licensee. The NRC determined that implementation of Phase I for KPS was acceptable as stated in their safety evaluation dated March 16, 1984 (reference 7).

On June 28, 1985, the NRC issued Generic Letter 85-11, "Completion of Phase II of Control of Heavy Loads at Nuclear Power Plants, NUREG 0612." Generic Letter 85-11 closed out Phase II of the Control of Heavy Loads issue.

Since that time, KPS has implemented its heavy load control program using procedures consistent with its operating license and commitments made in its responses to the generic letters related to NUREG-0612.

In response to a recommendation made by the Advisory Committee on Reactor Safeguards (ACRS), the NRC staff issued Regulatory Issue Summary (RIS) 2005-25, "Clarification of NRC Guidelines on Control of Heavy Loads," in October, 2005. The NRC supplemented RIS 2005-25 in May 2007 (reference 6). RIS 2005-25 did not require a response from licensees. However, licensees were expected to review the RIS and consider what actions may be appropriate to enhance their heavy load control programs, if any. The guidance in NUREG-0612, as clarified in RIS 2005-25, was used as the regulatory basis for the upgrade to the AB crane, as described in further detail below and in the matrix in Attachment 5. Augmented guidance was issued in RIS 2005-25, Supplement 1 after the AB crane upgrade project was underway, and was considered to the extent practicable.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 7 of 28 3.2.2 Summary of NUREG-0612 Applicability to KPS NUREG-0612, Sections 5.1 and 5.1.1, provide general guidelines for heavy load handling and are applicable to all U.S. commercial operating nuclear power plants, including KPS. These sections of NUREG-0612 address items such as load drop analysis acceptance criteria, operator training and qualification, equipment reliability and inspection, safe load paths, crane travel limiting devices, procedures, lifting devices, and cranes. This section of NUREG-0612 is considered Phase I.

NUREG 0612, Section 5.1.2, "Spent Fuel Pool Area - PWR," is also applicable to KPS and contains four alternate guidelines for heavy load handling in the spent fuel pool area, one of which should be satisfied. The first guideline recommends satisfying the single-failure-proof criteria of NUREG-0612, Section 5.1.6 for the overhead crane and associated lifting devices. The second and third guidelines involve implementing design features and administrative controls for non-single-failure-proof lifting systems to minimize the potential for a heavy load drop onto spent fuel in the spent fuel pool or equipment required for safe shutdown. The fourth guideline involves analyzing the effects of heavy load drops if the lifting system is not single-failure-proof and showing that the evaluation acceptance criteria of NUREG-0612, Section 5.1 are satisfied.

NUREG-0612, Section 5.1.2, is considered part of Phase II and is also included in the matrix in Attachment 5.

NUREG-0612, Section 5.1.3, "Containment Building-PWR," does not apply because this LAR only addresses heavy load lifts in the spent fuel pool area of the auxiliary building, which is separate from the containment building at KPS. NUREG-0612, 5.1.4, "Reactor Building - BWR," does not apply because KPS is a PWR plant. NUREG-0612, Section 5.1.5, "Other Areas" does not apply because this LAR only addresses heavy load lifts in the spent fuel pool area of the auxiliary building, which is separate from "other areas" (areas of the plant where a dropped load may damage safe shutdown equipment).

Therefore, these sections of NUREG-0612 are not discussed further. These sections are also considered part of NUREG-0612, Phase II.

NUREG 0612, Section 5.1.6, "Single-Failure-Proof Handling Systems," may be used to meet the guidelines of Sections 5.1.2, 5.1.3, 5.1.4, or 5.1.5 where the alternative of upgrading the crane and lifting devices is chosen. This alternative has been chosen to meet the guidelines contained in Section 5.1.2 for the handling of spent fuel casks at KPS. NUREG-0612, Section 5.1.6, is considered part of Phase II and is included in the matrix in Attachment 6.

Only the sections of NUREG-0612 applicable to KPS as described above, and the AB crane lifting system are germane to this LAR. A discussion of how the KPS upgraded AB crane lifting system meets the applicable guidance in NUREG-0612 is provided below and in Attachment 5.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 8 of 28 3.3 Applicability of NUREG-0612 to Upgraded AS Crane Lifting System DEK has chosen to update its commitments regarding heavy load control in the spent fuel pool area. DEK will now satisfy the first guideline of NUREG-0612, Section 5.1.2 for heavy load handling using the AB crane lifting system by upgrading the AB crane to a single-failure-proof design in accordance with NUREG-0612, Section 5.1.6, and committing to meet the other portions of NUREG-0612, Section 5.1.6 pertaining to lifting devices and interfacing lift points. NUREG-0612, Section 5.1.6 refers to NUREG-0554 for guidance on the design and operation of single-failure-proof cranes. The scope of the AB crane upgrade involves replacement of the crane trolley and hoist components, and upgrading of the crane controls to current standards. The AB crane bridge will not be replaced, but will be modified to increase its structural strength and re-used with the new trolley. Attachment 6 to this lAR provides an item-by-item compliance matrix of the guidance in NUREG-0554 against the upgraded AB crane design.

Lifting devices and interfacing lift points used with the AB crane will meet the guidance in NUREG-0612, Section 5.1.6, as described in Attachment 5 and 6, for the maximum critical lift (MCl) to ensure the entire lifting system may be considered single-failure-proof for the MCl lift. The MCl for the AB crane is the NUHOMS@ transfer cask containing a canister loaded with spent fuel. One AB crane heavy load lift has been identified that will not meet the NUREG-0612 guidance for interfacing lift points. This exception, and why it does not impact the basis for this lAR is discussed in further detail in Section 4.4.3. Attachment 5 to this lAR provides an item-by-item compliance matrix of the guidance in NUREG-0612, Section 5.1.6, applicable to lifting devices and interfacing lift points (as augmented by RIS 2005-25, as supplemented) against the components to be used for spent fuel cask handling operations.

3.4 NUREG-0612 Interpretation Change In February of 1990, KPS staff agreed to a NUREG-0612 interpretation whereby the AB crane main hook and load block assembly would conservatively be considered a heavy load, even though these components are included in the NUREG-0612 definition of the load handling system (reference 21). Based on DEK upgrading the AB crane to be single-failure-proof, dropping of the AB crane main hook or load block is no longer considered credible. Because dropping of these components is not considered credible, the conservative interpretation of these components being heavy loads is no longer necessary and hereby withdrawn.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 9 of 28

4.0 TECHNICAL ANALYSIS

DEK is constructing, and plans to operate an ISFSI on the KPS site under the general license provision of 10 CFR 72, Subpart K to provide additional required spent fuel storage capacity. DEK has chosen the Transnuclear Standardized NUHOMS@ Dry Spent Fuel Storage System for use at the KPS ISFSI. Moving spent fuel into dry storage from the spent fuel pool requires the handling of a spent fuel dry shielded canister (DSC) inside a spent fuel transfer cask (TC) over and nearby the KPS spent fuel pool and truck bay. There are several different DSC and TC designs available for use as part of the generic Standardized NUHOMS@ System. The licensee users choose the DSC and TC design that suits their plant's needs and capabilities. The maximum loaded weight of any TC used with the generically-designed Standardized NUHOMS system is 125 tons. The actual weight of the loaded TC used at a particular licensee's site depends, among other things, on the TC and DSC models chosen for use, and the fuel type. The TC and DSC models to be used at KPS have a maximum combined loaded weight of 105 tons. Therefore, the 125-ton design rated load for the AB crane provides additional safety margin for lifts of the 1OS-ton TC.

The spent fuel cask operating procedures also require handling of other heavy loads over and nearby the spent fuel pool to load and prepare the canister for storage operations in accordance with its CoC and FSAR. Some of these heavy loads (i.e., the DSC top shield plug) must necessarily be suspended, for short periods of time, over the irradiated fuel in the spent fuel canister while installing the shield plug into the canister.

A review of the KPS Part 50 technical specifications with respect to the equipment and operating procedures for the Standardized NUHOMS@ System revealed that a license amendment was required to permit the heavy load movements necessary to implement dry spent fuel storage in the Part 50 facility.

4.1 Modification of TS 3.B.a.7 Current KPS TS 3.8.a.7, as shown in Section 2.0 above, does not allow for the placement and handling of spent fuel casks or other heavy loads in or around the spent fuel pool with irradiated fuel in either the main spent fuel pool or the canal pool.

Because there is spent fuel in the spent fuel pool that cannot be moved elsewhere, dry spent fuel cask handling operations cannot be implemented at KPS with the current TS in place. However, with TS 3.8.a.7 modified as requested herein, cask-handling operations would be permitted. Furthermore, with the AB crane lifting system upgraded to a single-failure-proof design, the cask drop accident may be removed from the KPS licensing basis. With this change to the licensing basis for design basis accidents, KPS TS 3.8.a.7 no longer meets any of the criteria in 10 CFR 50.36(d)(2)(ii). Therefore, TS 3.8.a.7 is proposed to be revised as stated in Section 2.0 above and re-Iocated to the TRM.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 10 of 28 The sections below discuss KPS's licensing basis as it relates to each applicable subsection of NUREG-0612.

4.2 NUREG-0612, Section 5.1.1, "General" By letter dated March 16, 1984, (reference 7) the NRC issued a safety evaluation report (SER) to KPS concerning Phase I of the Control of Heavy Loads issue. In this SER the NRC stated:

"Based on our review and that of our consultant, the Franklin Research Center, we have concluded that the guidelines of NUREG-0612, Section 5.1.1 and 5.3 have been satisfied and the Phase I of this issue for KPS is acceptable."

This SER confirms that KPS met the guidelines contained in NUREG-0612, Section 5.1.1 in 1984. Attachment 5 provides an updated compliance matrix to confirm that KPS continues to meet the criteria in NUREG-0612, Section 5.1.1, as clarified in RIS 2005-25, as it pertains to the AB crane lifting system. The matrix in Attachment 5 includes consideration of the heavy load handling equipment and activities required for dry spent fuel cask handling operations, which were not considered at the time the original KPS NUREG-0612-related correspondence with the NRC took place in the 1980's.

4.3 NUREG-0612, Section 5.1.2, "Spent Fuel Pool Area - PWR" NUREG-0612, Section 5.1.2, states that, to provide assurance that the evaluation criteria of Section 5.1, "Recommended Guidelines," are met for load handling operations in the spent fuel pool area, in addition to satisfying the guidelines of Section 5.1.1, "General," one of the four guidelines listed in Section 5.1.2 should also be satisfied.

KPS's NUREG-0612-related responses to the NRC regarding cask handling in the early 1980s exclusively addressed shipping casks and stated, based on the spent fuel pool's capacity, "no spent fuel cask handling operations are planned or anticipated ..." The response further stated, "A detailed analysis of the consequences of an accidental drop of a spent fuel shipping cask will be made and procedures will be written prior to first use of a cask." However, since that time DEK has modified its position in this regard to take a more conservative approach. Rather than postulate and analyze cask drop events, DEK has decided to upgrade its cask handling lifting system to single-failure-proof and make the cask drop event so improbable that it may be considered non-credible and eliminated from the KPS licensing basis as a design basis event.

DEK has now chosen to satisfy NUREG-0612, Section 5.1.2, Guideline (1) for the AB crane lifting system as discussed in Section 3.2 above. This guideline states:

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 11 of 28

"(1) The overhead crane and associated lifting devices used for handling heavy loads in the spent fuel pool area should satisfy the single-failure-proof guidelines of Section 5. 1.6 of this report."

Section 4.4 below discusses KPS's compliance with NUREG-0612, Section 5.1.6, as augmented by RIS 2005-25.

4.4 NUREG-0612, Section 5.1.6, "Single-Failure-Proof Handling Systems" NUREG-0612, Section 5.1.6 provides guidelines addressing the alternative of upgrading the heavy load handling system. These guidelines address lifting devices, cranes (new and upgraded), and interfacing lift points. Each of these three areas is addressed separately below.

4.4.1 AS Crane System Lifting Devices NUREG-0612, Section 5.1.6, Guideline (1) has two sub-items: (a) special lifting devices, and (b) lifting devices that are not specially designed.

4.4.1.1 AS Crane System Special Lifting Devices For special lifting devices NUREG-0612, Guideline (1 )(a) states:

"(a) Special lifting devices that are used for heavy loads in the area where the crane is to be upgraded should meet ANSI N14.6 1978, "Standard For Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More For Nuclear Materials," as specified in Section 5. 1. 1(4) of this report except that the handling device should also comply with Section 6 of ANSI N14.6-1978.

If only a single lifting device is provided instead of dual devices, the special lifting device should have twice the design safety factor as required to satisfy the guidelines of Section 5. 1. 1(4). However, loads that have been evaluated and shown to satisfy the evaluation criteria of Section 5. 1 need not have lifting devices that also comply with Section 6 of ANSI N14.6."

RIS 2005-25, Supplement 1 augments the NUREG-0612 guidance on special lifting devices in single-failure-proof handling systems as follows:

"(1) A special lifting device that satisfies American National Standard Institute (ANSI) N14.6-1993, "Radioactive Materials - Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4,500 kg) or More," should be used for recurrent load movements in critical areas (i.e., reactor heads, reactor vessel internals, spent fuel casks). The lifting device should have either dual,

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 12 of 28 independent load paths or a single load patll with twice the design safety factor specified by ANSI N14.6 for the load.

KPS Position:

All components meeting the ANSI N14.6 (reference 8) definition of "special lifting device" and used with the AS crane lifting system to lift heavy loads in the area where the crane is to be upgraded will meet the guidance in NUREG-0612, Section 5.1.6, Guideline 1(a) and ANSI N14.6-1993. As an example, whenever the DSC is situated inside the TC (e.g., after the DSC is loaded with spent fuel), the assemblage will be lifted with a lifting yoke attached to the AS crane main hook and engaged with the lifting trunnions on the TC. The lifting yoke is considered a special lifting device and meets the applicable guidance of ANSI N14.6-1993. Therefore, this special lifting device meets the guidance in NUREG-0612, Section 5.1.5(1 )(a) for heavy load lifts.

The KPS heavy load control program and procedures ensure that all special lifting devices used for heavy load lifts in or over the spent fuel pool meet the guidance in NUREG-0612, Section 5.1.6.(1)(a) and ANSI N14.6-1993 to preserve the single-failure-proof designation of the AS crane lifting system.

4.4.1.2 AS Crane System Lifting Devices Not Specially Designed For lifting devices that are not specially designed, NUREG-0612, Guideline (1 )(b) states:

"(b) Lifting devices that are not specially designed and that are used for handling heavy loads in the area where the crane is to be upgraded should meet ANSI 830.9 - 1971, "Slings" as specified in Section 5.1.1(5) of this report, except that one of the following should also be satisfied unless the effects of a drop of the particular load have been analyzed and shown to satisfy the evaluation criteria of Section 5. 1:

(i) Provide dual or redundant slings or lifting devices such that a single component failure or malfunction in the sling will not result in uncontrolled lowering of the load; OR (ii) In selecting the proper sling, the load used should be twice what is called for in meeting Section 5. 1. 1(5) of this report."

2 As used in this context, a "load path" is defined as the collection of load-bearing members in which the induced stress is directly affected by the weight of the load connected to it. This is not to be confused with "safe load paths" as discussed in NUREG-0612, Section 5.1.1.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 13 of 28 RIS 2005-25, Supplement 1 augments the NUREG-0612 guidance on lifting devices not specially designed in single-failure-proof handling systems as follows:

"(2) Slings should satisfy the criteria of American Society of Mechanical Engineers (ASME) 830.9-2003, "Slings," and be constructed of metallic material (chain or wire rope). The slings should be either (a) configured to provide dual or redundant load paths or (b) selected to support a load twice the weight of the handled load. "

KPS Position:

When the DSC is inside the TC, the assemblage will be lifted with a lifting yoke attached to the AB crane main hook and lifting trunnions on the TC. The lifting yoke is considered a special lifting device and is addressed in Section 4.4.1.1 above. There are no intervening lifting devices between the crane hook and the TC lifting trunnions other than the lifting yoke. Therefore, Guideline 1(b) does not apply to TC lifts.

The KPS heavy load control program and procedures ensure that all lifting devices not "specially designed" and used for heavy load lifts in or over the spent fuel pool meet the guidance in NUREG-0612, Section 5.1.6.(1 )(b) and ASME B30.9-2003 (reference 9) to preserve the single-failure-proof designation of the AB crane lifting system. With regard to the RIS 2005-25 guidance recommending not using synthetic slings for heavy load lifts, KPS may use slings made of metallic or synthetic material in making heavy load lifts with the AB crane system, based on the nature of the lift and the lifting location. If synthetic slings are used, the rigging of those slings will be controlled by procedure to avoid the types of sling failure modes described in RIS 2005-25.

4.4.2 Upgraded AS Crane NUREG-0612, Section 5.1.6, Guideline (2) states:

"New cranes should be designed to meet NUREG-0554, "Single-Failure-Proof Cranes For Nuclear Power Plants." For operating plants or plants under construction, the crane should be upgraded in accordance with the implementation guidelines of Appendix C of this report."

RIS 2005-25, Attachment 1, Section B.2 provides NRC guidance applicable to upgrades of existing cranes to single-failure-proof in two major areas:

1. Evaluation of existing crane bridges; specifically, cold proof testing of the crane and heat treatment and non-destructive examination (NDE) of crane bridge welds, and;

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 14 of 28

2. Seismic evaluation of crane structures.

KPS Position:

The guidance in NUREG-0612 and NUREG-0554, as augmented by RIS 2005-25 (as supplemented), has been used in the AS crane upgrade project. The AS crane upgrade includes removing the existing trolley from the bridge and replacing it with an upgraded trolley and provided upgraded controls that meet the single-failure-proof guidance of NUREG-0554 and NUREG-0612. This upgrade includes both the AS crane main and auxiliary hoisting systems. The existing bridge will be upgraded by the addition of stiffener plates to strengthen the bridge girder to end tie connection, and re-used. provides and item-by-item compliance matrix describing how the upgraded AS crane meets the above guidance.

The seismic analysis of the upgraded crane meets the criteria in the design codes applicable to the projects and the guidance in RIS 2005-25. Additional details on the seismic analysis of the upgraded crane may be found in a recently submitted DEK license amendment request on that topic (reference 20).

4.4.3 AS Crane System Interfacing Lift Points NUREG-0612, Section 5.1.6, Guideline (3) states:

"Interfacing lift points such as lifting lugs or cask trunnions should also meet one of the following for heavy loads handled in the area where the crane is to be upgraded unless the effects of a drop of the particular load have been evaluated and shown to satisfy the evaluation criteria of Section 5. 1:

(a) Provide redundancy or duality such that a single lift point failure will not result in uncontrolled lowering of the load; lift points should have a design safety factor with respect to ultimate strength of five (5) times the maximum combined concurrent static and dynamic load after taking the single lift point failure.

OR (b) A non-redundant or non-dual lift point system should have a design safety factor of ten (10) times the maximum combined concurrent static and dynamic load. "

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 15 of 28 KPS Position:

When the DSC is inside the TC, it is lifted with a lifting yoke attached to the AB crane main hook and lifting trunnions on the TC. The TC lifting trunnions are considered non-redundant, dual interfacing lift points. The as 197H TC lifting trunnions are designed with safety factors of 6: 1 on yield stress and 10: 1 on ultimate stress for a design rated load of 125 tons. These lifting trunnions meet the safety factor recommended in NUREG-0612, Section 5.1.6(3) for non-redundant interfacing lift points in single-failure-proof lifting systems. The design rated load of 125 tons for the as 197H TC lifting trunnions also exceeds the design maximum TC weight for KPS of 105 tons, providing additional safety margin.

The lifting lugs attached to the inside of the DSC shell, which are interfacing lift points used when the empty DSC is lifted for insertion into the TC, do not meet the NUREG-0612, Section 5.1.6(3) design guidance for interfacing lifting points. This operation is conducted in the loading dock area of the Auxiliary Building, where there is no safe-shutdown equipment in the vicinity or under the loading dock floor. Therefore, a drop of the empty DSC would have no adverse consequences on KPS operation, the ability to safely shut down the plant, or the ability to maintain safe shutdown conditions.

To preserve the single-failure-proof designation of the lifting system for the lift, the KPS heavy load control program and procedures ensure that the interfacing lift points for the lifted load are designed in accordance with NUREG-0612, Section 5.1.6(3), for each heavy load lift in or over the spent fuel pool. In general, any heavy load lifted by the AB crane system with interfacing lift points not designed in accordance with NUREG-0612, Section 5.1.6(3), will be performed in a location where the consequences of a load drop are acceptable (see Attachment 5).

4.5 Summary of Upgraded AB Crane Lifting System Compliance with Regulatory Guidance Through the implementation of crane upgrades, physical controls, administrative controls, training, operations, and maintenance, KPS meets the guidelines contained in NUREG 0612, Sections 5.1.1, 5.1.2 and 5.1.6, as augmented by RIS 2005-25 for the AB crane lifting system. Attachments 5 and 6 provide item-by-item NUREG-0612 and NUREG-0554 compliance matrixes for the upgraded KPS AB overhead crane and heavy load handling system.

4.6 Post Single-Failure-Proof Auxiliary Building Crane Operation The modification to upgrade the AB crane to single-failure-proof will also change the operation of the crane by providing three modes of operation: "Normal," "New Fuel Handling," and "Cask Handling." Additionally, the crane upgrade will change the way

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 16 of 28 the travel limits are sensed from mechanical limit switches to a laser positioning system.

Post single-failure-proof AS crane "Normal" operation will still maintain the current travel limit restrictions. Additionally, KPS administrative procedures restrict movement of heavy loads within a critical area surrounding the spent fuel pool or the surrounding area when spent fuel is stored in the transfer canal. When the AS crane is in use outside of the spent fuel pool critical area the crane is restricted to operation only in the "Normal" mode.

To enter the critical area surrounding the spent fuel pool, the AS crane must be operated in the "New Fuel" or "Cask Handling" mode. The "New Fuel" mode allows the crane to enter the area above the new fuel pit and over the transfer canal but still prevents movement of the suspended load above the spent fuel pool including the area of the transfer canal where spent fuel can be stored. To insert a spent fuel cask into the area of the spent fuel pool designated for cask handling, the AS crane must be operated in the "Cask Handling" mode. The "Cask Handling" mode still maintains interlocks that prevent the load from traveling over spent fuel stored in the spent fuel pool but allows movement of the crane over the spent fuel pool area designated for cask handling.

4.7 Relocation of TS 3.8.a.7 to the Technical Requirements Manual In February 1987, the NRC published an interim policy statement on TS improvements for nuclear power reactors (reference 10). This policy statement established a specific set of criteria for determining which regulatory requirements and operating restrictions should be included in TS. In November 1987, the Westinghouse Owners Group (WOG) published WCAP-11618 (reference 11), in which the criteria contained in the interim policy statement were applied to standard Westinghouse TS to determine whether individual technical specifications should be removed and relocated to licensee controlled documents. As documented in WCAP-11618, the WOG determined that the requirements of standard Westinghouse TS 3/4.9.6 and TS 3/4.9.7 (requirements similar to KPS TS 3.8.a.7) were among those that could be relocated to another controlled document. In a May 1988 letter (reference 12), the NRC published its conclusions regarding the WOG determinations documented in WCAP-11618. The letter documented NRC agreement with the WOG conclusions regarding relocation of TS 3/4.9.6 and TS 3/4.9.7 to other licensee controlled documents.

In July 1993, the NRC published its Final Policy Statement on TS improvements (reference 13). This policy statement provided four specific criteria for determining which design features and information should be located in the TS as LCOs. These four criteria were very similar to the criteria published in the Interim Policy Statement.

The four criteria provided by the Final Policy Statement are as follows:

1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 17 of 28

2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The Final Policy Statement noted that those LCOs that do not meet any of the four criteria may be proposed for removal from the TS and relocated to a licensee-controlled document, such as the USAR. The Policy Statement also noted that licensees submitting amendment requests should identify the location and controls for the relocated requirements. The four criteria provided in the Final Policy Statement were subsequently codified in 10 CFR 50.36(d)(2)(ii).

The Final Policy Statement also encouraged licensees to implement a voluntary update program of their Technical Specifications to be consistent with the Standard Technical Specifications (e.g., NUREG-1431 for Westinghouse plants) (reference 1). The four 10 CFR 50.36 criteria provide a basis for relocating requirements from the Technical Specifications to other licensee-controlled documents, provided the requirements meet none of the four criteria.

Provided below is an evaluation of the requirements of KPS TS 3.8.a.7 against the four criteria defined in the NRC's Final Policy Statement and 10 CFR 50.36(d)(2)(ii).

TS 3.8.a.7 prohibits loads greater than the weight of a fuel assembly from being transported over or placed in either spent fuel pool when spent fuel is stored in that pool. Specific exceptions are provided for installation or movement of spent fuel storage racks, spent fuel casks, and heavy loads associated with spent fuel cask handling operations, under certain circumstances.

Evaluation against 10 CFR 50.36(d)(2)(ii) criteria:

1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Evaluation: The intent of this criterion is to ensure instrumentation that could detect a loss of coolant accident is included in TS. The spent fuel pool is not part of the reactor coolant pressure boundary under normal operating conditions. Prohibiting loads greater than the weight of a fuel

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 18 of 28 assembly from traveling over fuel assemblies in the spent fuel storage pool does not involve or otherwise affect installed instrumentation that is used to detect or indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, this criterion does not apply.

2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Evaluation: The design basis accident or transient of concern that pertains to the spent fuel pool is a fuel handing accident, considered a Condition IV event. Condition IV occurrences are faults that are not expected to occur but are postulated because their consequences would include the potential for the release of significant amounts of radioactive material. The KPS Updated Safety Analysis Report (USAR) section 14.2.1, "Fuel Handling Accidents," describes this design basis accident. This accident analysis has been reviewed and approved by the NRC as described in the NRC's safety evaluation dated March 8, 2007 (reference 14).

In USAR Section 14.2.1, it states that the following fuel handling accidents are evaluated to ensure that no hazards are created:

a. A fuel assembly becomes stuck inside the reactor vessel.

b. A fuel assembly or Rod Cluster Control Assembly (RCCA) is dropped onto the floor of the reactor refueling cavity or spent fuel pool.

c. A fuel assembly becomes stuck in the penetration valve.

d. A fuel assembly becomes stuck in the transfer tube or the carriage becomes stuck.

In USAR Section 14.2.1 under "Causes and Assumptions" the following statement is made:

"Crane facilities do not permit the handling of heavy objects, such as a spent fuel-shipping container, over the spent fuel storage area.

A detailed description of crane movement limitations appears in Section 9.5."

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 19 of 28 KPS TS 3.8.a.7 prohibits loads greater than the weight of a fuel assembly from being transported over or placed in either spent fuel pool when spent fuel is stored in that pool. Design features and operating restrictions are in place to prevent dropping a load on racks containing irradiated fuel that is stored in the spent fuel pool.

10 CFR 50.36(d)(2)(ii) Criterion 2 requires that design features or operating restrictions that are an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier have limiting conditions for operation of a nuclear reactor established. The initial condition of the design basis fuel handling accident is the dropping of a single fuel assembly. Therefore, the prohibiting of loads greater than the weight of a fuel assembly from traveling over fuel assemblies in the spent fuel storage pool is provided to prevent operation in a condition that could potentially lead to an unanalyzed load drop accident.

DEK has initiated modifications to upgrade the Auxiliary Building crane to meet the guidance for a single-failure-proof crane. The crane will be designed, fabricated, installed, and tested to the guidance of NUREG-0554 in accordance with the guidance in NUREG-0612, Section 5.1.6.

In addition, the modified crane will be load-tested to 156.25 tons (125%

of the maximum critical load or design rated load). When these modifications are complete, the AB crane will meet the applicable guidance for a single-failure-proof crane, as described in Attachment 6.

The AB crane upgrade, combined with implementation of the NUREG-0612 guidelines applicable to lifting devices and interfacing lift points, will permit designating the AB crane lifting system as single-failure-proof lifting system, as defined in NUREG-0612. The AB crane modifications are scheduled for completion in December of 2007.

Once the crane modifications are complete (including NRC approval of DEK LAR 234 for the AB crane seismic analysis) and administrative and design controls are in place to ensure the remainder of the lifting system meets the single-failure-proof guidance, DEK intends to revise the USAR to remove the cask-drop accident from the licensing basis.

With the cask-drop accident removed from the licensing basis, Criterion 2 of 10 CFR 50.36 no longer applies to heavy load handling in the spent fuel pool, and the crane load limits may be relocated from the TS to the TRM, a document incorporated by reference in the USAR.

Because it is incorporated by reference in the USAR, changes to the TRM are controlled under the requirements of 10 CFR 50.59.

Serial No. 0?-0352 License Amendment Request 22?

Attachment 1 Page 20 of 28 When the modifications to make the AB crane single-failure proof are complete and administrative and design controls are in place to ensure the remainder of the lifting system meets the single-failure-proof guidance, DEK will inform the NRC staff.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Evaluation: The load and impact energy limits and the crane travel interlocks are not part of the primary success path to mitigate the consequences of a design basis accident or transient described in the KPS USAR. The AB crane lifting system serves no design basis accident mitigative function.

4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Evaluation: As summarized in Appendix A to WCAP-11618, TS similar to KPS TS 3.8.a.? were determined not to be risk significant based on core melt and health effects screening criteria. Although included in KPS's Maintenance Rule Program as a function providing the capability for movement of heavy loads into and across the spent fuel storage pool, it has been determined to not be a function with risk significance. The components associated with TS 3.8.a.? were not evaluated as risk contributors in the KPS Integrated Plant Examination.

Based on the above, once the AB crane modification is complete, the design features and information in T8 3.8.a.7 will not meet the criteria in 10 CFR 50.36(d)(2)(ii) for inclusion as a TS LCO and therefore may be relocated to the KPS Technical Requirements Manual.

The relocation of TS 3.8.a.? to the TRM is also consistent with NUREG-1431, "Standard Technical Specifications - Westinghouse Plants." NUREG 1431 does not include any specifications similar to TS 3.8.a.? Therefore, relocation of the requirements of TS 3.8.a.? is consistent with both past and current regulatory positions and requirements.

Included in the current KPS TS is a required action to be taken if the requirements of the current T8 3.8.a.? are not met. This required action is TS 3.8.b, which states:

If any of the specified limiting conditions for REFUELING OPERA nONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 21 of 28 violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

Because the TS proposed to be relocated to the KPS TRM is not associated with "Refueling Operations," DEK plans to add appropriate required actions to the TRM.

These planned required actions are included in the draft TRM pages in Attachment 4.

4.8 Precedent Licensing Actions Some licensing precedents for similar administrative changes to relocate spent fuel-related crane technical specifications include:

• St Lucie Units 1 and 2 received a license amendment on April 28, 2004, approving relocation of spent fuel pool crane technical specifications requirements (reference 15). This amendment implemented an administrative change to relocate certain technical specification requirements regarding the spent fuel and cask handling cranes to the respective units' Updated Final Safety Analysis Report. This was found acceptable because:

o At the time of the initial submittal, the requirements did not meet 10 CFR 50.36(d)(2)(ii), Criteria 1,3, and 4, and subsequently, o When new single-failure proof cranes were installed and the cask-drop accident was removed from the St Lucie licensing basis, 10 CFR 50.36(d)(2)(ii), Criterion 2 no longer applied.

• Beaver Valley Units 1 and 2 received a license amendment in 2000 to relocate technical specification requirements for their Spent Fuel Storage Pool Building Crane to another licensee-controlled document (reference 16).

• D. C. Cook Units 1 and 2 received a license amendment on April 18, 2002 to relocate two technical specifications for cranes related to Refueling Operations.

(reference 17).

• Hope Creek received a license amendment on January 17, 2002, to relocate TS 3/4.9.6, "Refueling Operations, Refueling Platform," TS 3/4.9.7, "Refueling Operations, Crane Travel - Spent Fuel Storage Pool," and the associated Bases, to the plant's UFSAR (reference 18).

• Millstone Nuclear Power Station, Unit 2 received a license amendment February 10, 2000 to relocate TS 3/4.9.6, "Refueling Operations, Crane Operability-Containment Building," TS 3/4.9.7, "Refueling Operations, Crane Travel - Spent Fuel Storage Building," and the associated Bases, to the plant's Technical Requirements Manual (reference 19).

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 22 of 28 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Dominion Energy KPS, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

No.

The proposed amendment revises Kewaunee Power Station (KPS) heavy load handling Technical Specification (TS) 3.8.a.7 requirements consistent with modifications to the Auxiliary Building (AB) crane and the NRC's current guidance for single-failure-proof lifting systems. The proposed amendment also relocates the affected heavy load handling-related TS to a licensee-controlled document, consistent with the NRC's regulations.

The proposed change to TS 3.8.a.7 permits spent fuel cask handling in the spent fuel pool, which is required for loading spent fuel for dry storage at the on-site Independent Spent Fuel Storage Installation (ISFSI). Proposed TS 3.8.a.7 includes a new requirement that the AB crane and associated lifting devices meet the applicable single-failure-proof criteria.

Heavy load handling will continue to be conducted in accordance with the KPS heavy load handling program, which meets the NRC's guidance in NUREG-0612, as described in this LAR, and as augmented by Regulatory Information Summary 2005-25. With the upgrade of the AB crane load handling system, drops of heavy loads will not be considered credible.

Notwithstanding the AB crane upgrade, heavy loads will still be prohibited from being suspended over irradiated fuel in the spent fuel pool storage racks under the revised requirements.

The previously evaluated cask drop accident is not considered credible with the upgraded AB crane because the crane trolley is being upgraded to a single-failure-proof design, consistent with applicable NRC-endorsed guidance. Lifting devices and interfacing lifting points associated with spent fuel cask handling will also be designed in accordance with applicable NRC guidance pertaining to single-failure-proof lifting systems. The result of these design upgrades is that the AB crane will retain the lifted load in the event of a single failure in the load path, including a failure of a wire rope. In addition,

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 23 of 28 the crane will hold the load and the trolley and bridge will be designed to stay on their respective rails during a design basis seismic event.

The relocation of TS 3.8.a.7 to the KPS Technical Requirements Manual (TRM) is an administrative change that does not affect plant operation or heavy load handling.

Revised TS 3.8.a.7 and its associated Bases will be relocated to the TRM after approval of this amendment request. Changes to the KPS TRM are controlled by 10 CFR 50.59. Regulation 10 CFR 50.59 requires that NRC approval be obtained prior to any change that would result in more than a minimal increase in 1) the frequency of occurrence of an accident previously evaluated, 2) likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated, or 3) consequences of a malfunction of a SSC important to safety previously evaluated. Accordingly, upon relocation of the requirements of TS 3.8.a.7 and associated Bases to the TRM, appropriate control of changes will be maintained, based on the criteria in 10 CFR 50.59.

Administrative relocation of the requirements of TS 3.8.a.7 does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, configuration of KPS or the manner in which it is operated.

Therefore, the proposed change does not significantly increase the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

No.

Heavy load handling will continue to be conducted in accordance with the KPS heavy load handling program, which meets the NRC's guidance in NUREG-0612, as approved for KPS. Drops of heavy loads will continue to be very improbable events and the upgrade of the KPS AB crane lifting system to a single-failure-proof design provides additional defense-in-depth against such events. Notwithstanding the AB crane upgrade, heavy loads will still be prohibited from being suspended over irradiated fuel in the spent fuel pool storage racks under the revised requirements.

Heavy load handling operations at KPS will continue to be conducted as they currently are and no new heavy load handling operations are required as a result of this amendment. The previously evaluated cask drop accident is not considered credible with the upgraded AS crane because the crane trolley is

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 24 of 28 being upgraded to a single-failure-proof design, consistent with applicable NRC-endorsed guidance. Lifting devices and interfacing lifting points associated with spent fuel cask handling will also be designed in accordance with applicable NRC guidance pertaining to single-failure-proof lifting systems. The result of these design upgrades is that the AB crane will retain the lifted load in the event of a single failure in the load path, including a failure of a wire rope. In addition, the crane will hold the load and the trolley and bridge will be designed to stay on their respective rails during a design basis seismic event.

The relocation of TS 3.8.a.7 to the KPS Technical Requirements Manual (TRM) is an administrative change that does not affect plant operation or heavy load handling.

Accordingly, upon relocation of the requirements of TS 3.8.a.7 and associated Bases to the TRM, appropriate control of changes will be maintained, based on the criteria in 10 CFR 50.59. Modification of the requirements of TS 3.8.a.7 does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, configuration of KPS or the manner in which it is operated.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

No.

The proposed amendment revises KPS heavy load handling TS 3.8.a.7 requirements consistent with modifications to the AB crane and the NRC's current guidance for single-failure-proof lifting systems.

Heavy load handling will continue to be conducted in accordance with the KPS heavy load handling program, which meets the NRC's guidance in NUREG-0612, as approved for KPS. Drops of heavy loads will continue to be very improbable events and the upgrade of the KPS AB crane lifting system to a single-failure-proof design provides additional defense-in-depth against such events and an increase in overall design margin. Notwithstanding the AB crane upgrade, heavy loads will still be prohibited from being suspended over irradiated fuel in the spent fuel pool storage racks under the revised requirements.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 25 of 28 Further, the relocation of TS 3.8.a.7 to the KPS Technical Requirements Manual (TRM) is an administrative change that does not affect plant operation or heavy load handling.

Heavy load handling operations at KPS will continue to be conducted as they currently are and no new heavy load handling operations are required as a result of this amendment. The previously evaluated cask drop accident is less probable with the upgraded AB crane because the crane trolley is being upgraded to a single-failure-proof design, consistent with applicable NRC-endorsed guidance. Lifting devices and interfacing lifting points associated with spent fuel cask handling will also be designed in accordance with applicable NRC guidance pertaining to single-failure-proof lifting systems.

The result of these design upgrades is that the AB crane will retain the lifted load in the event of a single failure in the load path, including a failure of a wire rope. In addition, the crane will hold the load and the trolley and bridge will be designed to stay on their respective rails during a design basis seismic event.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Dominion Energy Kewaunee, Inc. concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The US Atomic Energy Commission (AEC) issued their Safety Evaluation (SE) of the Kewaunee Power Station (KPS) on July 24, 1972 with supplements dated December 18, 1972 and May 10, 1973. In the AEC's SE, Section 3.1, "Conformance with AEC General Design Criteria," described the conclusions the AEC reached associated with the General Design Criteria in effect at the time. The AEC stated:

'The KPS plant was designed and constructed to meet the intent of the AEC's General Design Criteria, as originally proposed in July 1967. Construction of the plant was about 50% complete and the Final Safety Analysis Report (Amendment No.7) had been filed with the Commission before publication of the revised General Design Criteria in February 1971 and the present version of the criteria in July 1971. As a result, we did not require the applicant to reanalyze the plant or resubmit the FSAR. However, our technical review did assess the

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 26 of 28 plant against the General Design Criteria now in effect and we are satisfied that the plant design generally conforms to the intent of these criteria."

As such, the appropriate criteria KPS is licensed to, which are contained in the Final Safety Analysis (Amendment 7), and has been updated and re-titled the Updated Safety Analysis Report (USAR) are listed below.

Criterion 69: Provisions shall be made in the design of fuel and waste storage facilities such that no undue risk to the health and safety of the public could result from an accidental release of radioactivity (GDC 69).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. NUREG-1431, "Standard Technical Specification - Westinghouse Plants,"

Revision 3, June 2004 (ADAMS Accession No. ML041830612 (Specifications) and ML041830207 / ML041830209 (Basis)).

2. NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," dated July 1980.

3. NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants," dated May 1979.

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 27 of 28

4. ASME B30.2-1976 and 2005, "Overhead and Gantry Cranes."

5. Letter from Darrell G. Eisenhut (NRC) to All Licensees of Operating Plants, Applicants for Operating Licenses, and Holders of Construction Permits, "Control of Heavy Loads," dated December 22, 1980.

6. NRC Regulatory Information Summary 2006-25, "Clarification of NRC Guidelines on Control of Heavy Loads," dated October 31, 2005; and Supplement 1 dated May 29,2007.

7. Letter from Steven A. Varga (NRC) to C.W. Giesler (WPSC), "Control of Heavy Loads (Phase I)," dated March 16, 1984.

8. ANSI N14.6, "Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4,500 kg) or More," American National Standards Institute, 1993 Edition.

9. ASME B30.9, "Slings," American Society of Mechanical Engineers, 2003 Edition.

10. 52 FR 3788, "Nuclear Regulatory Commission - Proposed Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," dated February 6, 1987.

11. WCAP-11618, "Methodically Engineered, Restructured and Improved, Technical Specifications," dated November 1987.

12. Letter from T. E. Murley (NRC) to R. A. Newton (WOG) dated May 9, 1988.

13. 58 FR 39132, "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," dated July 22, 1993.

14. Letter from Robert F. Kuntz (NRC) to David A. Christian (DEK), "Kewaunee Power Station - Issuance of Amendment Re: Radiological Accident Analysis and Associated Technical Specifications Change (TAC NO. MC9715)," dated March 8, 2007 (ADAMS Accession No. ML070430020).

15. Letter from Brendan T. Moroney (NRC) to J.A. Stall (FP&L), "St. Lucie Units 1 and 2 - Issuance of Amendments Regarding the Relocation of Spent Fuel Pool Crane Technical Specification Requirements (TAC Nos MB5667 and MB5668)," dated April 28, 2004 (ADAMS Accession No. ML040440111).

16. NRC Safety Evaluation for Beaver Valley 1 & 2, dated September 7, 2000, "Approval to Relocate Technical Specification Requirements for Spent Fuel Storage Pool Building Crane to the Licensee Requirements Manual" (ADAMS Accession No. ML003748288.)

17. Letter from John F. Stang (NRC) to A. Christopher Bakken III (Indiana Michigan Power Company), "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments (TAC NOS. MB4231 and MB4232)," dated April 18, 2002 (ADAMS Accession No. ML020590065).

Serial No. 07-0352 License Amendment Request 227 Attachment 1 Page 28 of 28

18. PSE&G Nuclear, Hope Creek Generating Station, License Amendment No.137, dated January 17, 2002 (ADAMS Accession No. ML011130427).

19. Northeast Nuclear Energy Company, Millstone Nuclear Power Plant, Unit 2, License Amendment No. 240, dated February 10, 2000 (ADAMS Accession No. ML003684825).

20. Letter from G.T. Bischof (DEK) to Document Control Deck (NRC) License Amendment Request 234, "Request for Review and Approval of Methodology Change Regarding Upgraded Auxiliary BUilding Crane."

21. Letter from John N. Hannon (NRC) to Ken H. Evers (WPSC), "NUREG-0612,

'Control of Heavy Loads at Nuclear Power Plants' (TAC 75162)," dated February 6, 1990.

ATTACHMENT 2 LICENSE AMENDMENT 227 RELOCATION OF SPENT FUEL POOL CRANE SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL MARKED-UP TS PAGES FOR LICENSE AMENDMENT REQUEST 227 KEWAUNEE POWER STATION MARKED-UP TS PAGES:

TS 3.8-2 DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 License Amendment Request 227 Attachment 2 Page 1 of 1

6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place.

7. Deleted. Heavy loads, greater than the weight of a fuel assembly, will not be transported over or plaoed in either spent fuel pool II/hen spent fuel is stored in that pool. Plaoement of additional fuel storage raol{s is permitted, however, these raol{s may not traverse direotly above spent fuel stored in the pools.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

~99% DOP removal and ~99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show ~95% radioactive methyl iodide removal when tested in accordance with ASTM 03803-89 at conditions of 30°C and 95% RH.

3. Fans shall operate within +/-10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

TS 3.8-2 LAR 224Amendment 165 03/11/2003

ATTACHMENT 3 LICENSE AMENDMENT 227 RELOCATION OF SPENT FUEL POOL CRANE SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL AFFECTED TS PAGES FOR LICENSE AMENDMENT REQUEST 227 KEWAUNEE POWER STATION AFFECTED TS PAGES TS 3.8-2 DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 License Amendment Request 227 Attachment 3 Page 1 of 1

6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place.

7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

.2::,99% DOP removal and .2::,99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show.2::,95% radioactive methyl iodide removal when tested in accordance with ASTM 03803-89 at conditions of 30 C D and 95% RH.

3. Fans shall operate within +/-10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

TS 3.8-2 LAR 227

ATTACHMENT 4 LICENSE AMENDMENT 227 RELOCATION OF SPENT FUEL POOL CRANE SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL PROPOSED TECHNICAL REQUIREMENTS MANUAL CHANGE PAGES KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 License Amendment Request 227 Attachment 4 Page 1 of 3 3.8.1 SPENT FUEL POOL - CONTROL OF HEAVY LOADS APPLICABILITY Whenever a load greater than the weight of a fuel assembly, including its heaviest insert and handling tool, is lifted in or around the spent fuel pool.

OBJECTIVE Control the movement of loads in excess of the nominal weight of a fuel assembly, including its heaviest insert and associated handling tool, in or around the spent fuel pool.

TECHNICAL REQUIREMENTS Administrative Limiting Conditions for Operation CALCOs)

a. Heavy loads greater than the weight of a fuel assembly, including its heaviest insert and handling tool, will not be transported over or placed in either spent fuel pool when spent fuel is stored in that pool, unless:

1. The heavy load does not traverse directly above spent fuel stored in the pool's spent fuel storage racks, and

2. The load handling system (e.g., crane, associated lifting devices, and interfacing lift points) used for these lifts meets the single-failure-proof handling system criteria.

b. If, during the movement of heavy loads over or in the spent fuel pool, the load handling system is determined not to meet the applicable single-failure-proof criteria, then immediately place the suspended load in a safe condition (no longer suspended over the spent fuel pool) and cease further movement over the spent fuel pool until the crane can be repaired or other appropriate corrective actions implemented to restore compliance.

Administrative Surveillance Requirement (ASRs)

c. The following test shall be performed in the frequency specified

1. None

Serial No. 07-0352 License Amendment Request 227 Attachment 4 Page 2 of 3 BASES A "heavy load" is defined as any load (a mass or weight suspended from the crane's hook) greater than the weight of a fuel assembly, including its heaviest insert and handling tool. The purpose of this administrative limiting condition for operation is to control the movement of heavy loads in or around the spent fuel pool.

This administrative limiting condition for operations was relocated from the Kewaunee Power Station Technical Specifications because it no longer meets any of the four criteria 10 CFR 50.36 lists for items required in technical specifications.

The Auxiliary Building crane (part of the load handling system 1) was modified to meet the criteria of a single-failure-proof crane found in NUREG-0612, Section 5.1.6(2) and the crane is designed, fabricated, installed, and tested to the guidance of NUREG-0554, as approved for KPS. The crane will be inspected, tested, and maintained in accordance with ASME B30.2-1976. In addition, the modified Auxiliary Building crane was load-tested to 156.25 tons (125%). The lifting devices and interfacing lift points associated with the Auxiliary Building crane also meet the guidance in NUREG-0612 to be considered a single-failure-proof lifting system. Specifically, special lifting devices will meet the guidance in NUREG-0612, Section 5.1.6(1 )(a) and lifting devices not specially designed will meet the guidance in NUREG-0612, Section 5.1.6(1 )(b).

Interfacing lift points will meet the guidance in NUREG-0612, Section 5.1.6(3). A single-failure-proof AB crane lifting system allows for the removal of the cask-drop accident from the licensing basis of the Kewaunee Power Station, as the accident is no longer credible.

With the cask-drop accident removed from the licensing basis, Criterion 2 of 10 CFR 50.36 no longer applies, and the crane load limits were relocated from the TSs to the TRM.

Crane interlocks are utilized to ensure safe load handling. Crane interlocks and administrative procedures will prevent the movement of heavy loads over spent fuel in the storage racks in spent fuel pool. Movement of necessary heavy loads over irradiated fuel in the spent fuel canister during cask handling operations will only be performed as required by the design of the spent fuel cask system. Removal/placement of additional spent fuel racks and support hardware will be controlled by procedures to prevent movement to directly above spent fuel. Handling of spent fuel storage casks and associated other heavy loads is controlled by procedures to prevent movement to directly above spent fuel, except as necessary to correctly load the cask system in accordance with the cask vendor's operating procedures.

I All load bearing components used to lift the load, including the crane or hoist, the lifting device, and the interfacing load lift points.

Serial No. 07-0352 License Amendment Request 227 Attachment 4 Page 3 of 3 References

1. License Amendment approving relocation when approved by the NRC.

2. Kewaunee Power Station Updated Safety Analysis Report (USAR) section 9.5, "Fuel Handling System."

3. USAR section 14.2.1, "Fuel Handling Accidents."

4. NUREG 0612, "Control of Heavy Loads at Nuclear Power Plants."

5. Letter from Darrell G. Eisenhut (NRC) to All Licensees of Operating Plants, Applicants for Operating Licenses, and Holders of Construction Permits, "Control of Heavy Loads," dated December 22, 1980.

6. Letter from Darrell G. Eisenhut (NRC) to Licensees, "Control of Heavy Loads (Generic Letter 81-07)," dated February 3, 1981.

7. Letter from Steven A. Varga (NRC) to C.W. Geisler (WPSC), "Control of Heavy Loads (Phase I)," dated March 16, 1984.

8. Letter from C.W. Geisler (WPSC) to D.G. Eisenhut (NRC), "Control of Heavy Loads - Nine-Month Response," dated March 9, 1983.

9. Letter from C.W. Geisler (WPSC) to D.G. Eisenhut (NRC), "Control of Heavy Loads," dated April 4, 1983.

10. Letter from A. Schwencer (NRC) to E.W. James (WPSC), dated March 6, 1979 (License Amendment 26).

11. 52 FR 3788, "Nuclear Regulatory Commission - Proposed Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," dated February 6, 1987.

12. WCAP-11618, "Methodically Engineered, Restructured and Improved, Technical Specifications," dated November 1987.

13. NUREG 0554, "Single-Failure-Proof Cranes for Nuclear Power Plants."

ATTACHMENT 5 LICENSE AMENDMENT REQUEST 227 RELOCATION OF SPENT FUEL POOL CRANE TECHNICAL SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 1 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes Safe load paths are defined in the KPS heavy load handling procedures. Spent fuel cask handling will not require the cask Safe load paths should be defined for to be suspended over irradiated the movement of heavy loads to fuel. Certain heavy loads, such as NUREG-0612 minimize the potential for heavy loads, the DSC shield plug and top Section if dropped, to impact irradiated fuel in cover plate must be handled over 5.1.1(1) the reactor vessel and in the spent fuel the irradiated fuel in the canister pool, or to impact safe shutdown during installation of these equipment. components. These components will be handled with the single-failure-proof A8 crane lifting system, including lifting devices and interfacing lift points.

Procedures should be developed to KPS heavy load handling cover load handling operations for procedures address those load NUREG-0612 heavy loads that are, or could be handling operations where heavy Section handled over, or in proximity to loads are, or could be handled 5.1 .1(2) irradiated fuel or safe shutdown over, or in proximity to irradiated equipment. fuel or safe shutdown equipment.

Crane operators should be trained, The KPS crane operator training NUREG-0612 qualified, and conduct themselves in program meets the guidance in Section accordance with Chapter 2-3 of ANSI Chapter 2-3 of ANSI [ASME]

5.1 .1(3)

[ASME] 830.2-1976. 830.2-2005

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 2 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes Special lifting devices should satisfy The special lifting devices used to the guidelines of ANSI [ASME] N14.6- lift and handle the spent fuel 1978. transfer cask and other heavy NUREG-0612 load components are part of the Section A8 crane single-failure-proof 5.1.1(4) lifting system. The evaluation of these devices is discussed under NUREG-0612, Section 5.1.6(1 )(a) in this matrix Lifting devices that are not specially The lifting devices used to lift and designed should be installed and used handle the spent fuel transfer in accordance with the guidelines of cask and other heavy load NUREG-0612 ANSI [ASME] 830.9-1971. components that are not specially Section designed are part of the A8 crane 5.1.1(5) single-failure-proof lifting system.

The evaluation of these devices is discussed under NUREG-0612, Section 5.1.6(1 )(b) in this matrix.

The crane should be inspected, tested, The A8 crane is inspected, and maintained in accordance with tested, and maintained in Chapter 2-2 of ANSI [ASME] 830.2- accordance with Chapter 2-2 of NUREG-0612 1976. ANSI [ASME] 830.2-1976. The Section crane trolley and controls are 5.1.1(6) being upgraded and will meet the inspection, testing and maintenance guidance in ANSI

[ASME] 830.2-1976 edition.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 3 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes The crane should be designed to meet The AB crane, used to lift and the applicable criteria and guidelines of handle the spent fuel transfer Chapter 2-1 of ANSI [ASME] B30.2- cask and other heavy load 1976 and CMAA-70 or suitable components, is being upgraded alternative provided the intent of ANSI to a single-failure-proof design

[ASME] B30.2 and CMAA-70 is through replacement of the crane satisfied. trolley and an upgrade of the crane controls. The existing AB crane bridge will be strengthened and re-used. The design codes and standards used for the NUREG-0612 upgraded AB crane trolley, Section bridge, and controls are a 5.1.1 (7) combination of CMAA-70 (2004),

ASME NOG-1 , and original plant design codes as discussed in more detail under NUREG-0612, Section 5.1.6(2) in this matrix.

Compliance with these codes and standards ensures that the AB crane, as a whole, meets the applicable criteria and guidelines of ANSI [ASME] B30.2-1976 and CMAA-70.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 4 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes For the spent fuel pool area of a PWR The AB crane and associated plant, the overhead crane and lifting devices used to lift and associated lifting devices used for handle the spent fuel transfer handling heavy loads in the spent fuel cask and other heavy loads NUREG-0612 pool area should satisfy the single- associated with spent fuel cask Section failure-proof guidelines in Section 5.1.6 handling operations are designed 5.1.2(1) of this report to be a single-failure-proof lifting system. See the discussion of compliance with NUREG-0612, Section 5.1.6 elsewhere in this matrix.

These sections provide acceptable Because the upgraded KPS AB NUREG-0612 alternatives to meeting the single- crane and associated lifting Sections failure-proof guidance in Section devices meet the guidance in 5.1.2(2) thru 5.1.2(1) for the overhead crane and Section 5.1.2(1), the guidance in 5.1.2(4) associated lifting devices. these sections is not applicable.

For the containment building of a PWR Because the upgraded KPS AB The AB crane lifting system is used plant, this section provides guidance crane is not located in, nor does it for heavy load handling in and around on heavy load control. have access to the KPS the spent fuel pool.

NUREG-0612 containment building, the Section 5.1.3 guidance in this section is not applicable within the scope of this LAR.

For the reactor building of a BWR Because KPS is a PWR plant, the NUREG-0612 plant, this section provides guidance guidance in this section is not Section 5.1.4 on heavy load control. applicable.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 5 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes If safe shutdown equipment are Spent fuel cask handling beneath or directly adjacent to a operations occur in the KPS potential travel load path of overhead spent fuel pool area. Therefore, handling systems, (Le., a path not the guidelines in NUREG-0612, restricted by limits of crane travel or by Section 5.1.2 are applicable as mechanical stops or electrical discussed elsewhere in this interlocks) one of the following should matrix. No other areas of the KPS be satisfied in addition to satisfying the facility where heavy loads are general guidelines of Section 5.1.1: handled as part of spent fuel cask (a) The crane and associated lifting handling operations contain devices should conform to the single- irradiated spent fuel or plant safe failure-proof guidelines of Section 5.1.6 shutdown equipment. Therefore of this report; OR this section of NUREG-0612 is (b) If the load drop could impair the not applicable within the scope of operation of equipment or cabling this LAR.

NUREG-0612 associated with redundant or dual safe Section shutdown paths, mechanical stops or 5.1.5(1) electrical interlocks should be provided to prevent movement of loads in proximity to the redundant or dual safe shutdown equipment (in this case credit should not be taken for intervening floors unless justified by analysis); OR (c) The effects of load drops have been analyzed and the results indicate that damage to safe shutdown equipment would not preclude operation of sufficient equipment to achieve safe shutdown. Analyses should conform to the guidelines of Appendix A, as applicable.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 6 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes Where the safe shutdown equipment Not applicable within the scope of has a ceiling separating it from an this LAR.

overhead handling system, an alternative to Section 5.1.5(1) above NUREG-0612 would be to show by analysis that the Section largest postulated load handled by the 5.1.5(2) handling system would not penetrate the ceiling or cause spalling that could cause failure of the safe shutdown equipment.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 7 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes Special lifting devices that are used for The lifting yoke used to lift the The spent fuel transfer cask is the heavy loads in the area where the transfer cask is a special lifting maximum critical load to be lifted by crane is to be upgraded should meet device and is designed and the AS crane.

ANSI N14.6-1978, including Section 6 fabricated in accordance with of that document. If only a single lifting ANSI N14.6-1993. The rated device is provided instead of dual load of the lift yoke is 105 tons.

devices, the special lifting device The design safety factors for the should have twice the design safety lifting yoke are based on a static factor as required to satisfy the plus dynamic load of 115% of the guidelines of NUREG-0612, Section rated load, or 120.75 tons. The 5.1.1(4). safety factors for the lifting yoke are 6: 1 against the yield strength From RIS 2005-25, Supplement 1: of the material and 10: 1 against the ultimate strength of the A special lifting device that satisfies material. These safety factors NUREG-0612 American National Standard Institute are twice the safety factors Section (ANSI) N14.6-1993, "Radioactive specific in ANS N14.6-1993.

5.1.6( 1)(a)

Materials - Special Lifting Devices for Shipping Containers Weighing 10,000 There are no other intervening lift Pounds (4,500 kg) or More," should be devices between the crane hook used for recurrent load movements in and the transfer cask lifting critical areas (i.e., reactor heads, trunnions for these lifts.

reactor vessel internals, spent fuel casks). The lifting device should have Other special lifting devices, such either dual, independent load paths or as shackles, that will be used for a single load path with twice the design heavy load handling with the AS safety factor specified by ANSI N14.6 crane system will meet the for the load. guidance in ANSI N14.6-1993 for the particular load being lifted.

This is controlled through the KPS heavy load control program and procedures.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 8 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes Lifting devices that are not specifically The spent fuel transfer cask is designed and that are used for handling lifted with a lifting yoke attached heavy loads in the area where the crane is to the AB crane hook and the TC to be upgraded should meet ANSI 830.9- lifting trunnions. There are no 1971, "Slings" as specified in NUREG-other lifting devices used in the 0612, Section 5.1.1 (5), except that one of the following should also be satisfied maximum critical load (MCl) lift.

unless the effects of the drop of the Therefore, this guidance does not particular load have been analyzed and apply to the cask handling lift.

shown to satisfy the evaluation criteria of NUREG-0612, Section 5.1: Other lifting devices not specially designed, such as slings, wire (i) Provide dual or redundant slings or ropes, etc., that will be used for lifting devices such that a single heavy load handling with the AB component failure or malfunction in crane system will meet the NUREG-0612 the sling will not result in guidance in ANSI [ASME] B30.9-uncontrolled lowering of the load; Section 2003 for the particular load being OR 5.1.6(1 )(b) lifted. This is controlled through (ii) In selecting the proper sling, the load the KPS heavy load control used should be twice what is called program and procedures.

for in meeting NUREG-0612, Section 5.1.1(5). KPS may use slings made of metallic or synthetic material in From RIS 2005-25, Supplement 1: making heavy load lifts with the AB crane system, based on the Slings should satisfy the criteria of nature of the lift and the lifting American Society of Mechanical Engineers (ASME) 830.9-2003, "Slings," and be location. When synthetic slings constructed of metallic material (chain or are used, the rigging of those wire rope). The slings should be either (a) slings is controlled by procedure configured to provide dual or redundant to avoid the types of sling failure load paths or (b) selected to support a load modes described in RIS 2005-25.

twice the weight of the handled load.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 9 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes New cranes should be designed to The AS crane is being upgraded meet NUREG-0554. to a single-failure-proof design through replacement of the crane trolley and controls. See the NUREG-0612 NUREG-0554 portion of this Section compliance matrix for a point-by-5.1.6(2) point compliance discussion of each guideline in NUREG-0554 as it pertains to the upgraded AS crane. The upgraded AS crane meets this guidance.

Serial No. 07-0352 License Amendment Request 227 Attachment 5 Page 10 of 10 NUREG-0612 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE LIFTING SYSTEM Section Guidance Evaluation Notes Interfacing lifting points, such as lifting When the empty or loaded DSC is inside lugs or cask trunnions should also the as 197H TC, the TC is lifted and handled with a lifting yoke attached to the meet one of the following for heavy TC upper lifting trunnions. The TC upper loads handled in the area where the lifting trunnions are considered a non-crane is to be upgraded unless the redundant, dual lift point system. The effects of the drop of the particular load upper lifting trunnions and trunnion sleeves are designed and fabricated in have been analyzed and shown to accordance with the ANSI N14.6-1993 satisfy the evaluation criteria of guidance for non-redundant interfacing NUREG-0612, Section 5.1: lift points. The safety factors for the TC upper lifting trunnions are 6: 1 against the (a) Provide redundancy or duality such yield strength of the material and 10: 1 against the ultimate strength of the that a single lift point failure will not material. This safety factor meets the result in uncontrolled lowering of safety factor specific in NUREG-0612 for NUREG-0612 the load; lift points should have a a non-redundant lift point system. The design safety factor with respect to loaded TC to be used at KPS weighs a Section maximum of 105 tons in its heaviest 5.1.6(3) ultimate strength of five (5) times configuration, providing additional margin the maximum combined concurrent on these safety factor values.

static and dynamic load after taking the single lift point failure. When the empty DSC is lifted for initial insertion into the TC, it is lifted by lifting lugs attached to the inside of the canister OR shell. These lifting lugs are considered interfacing lift points for these lifts. The (b) A non-redundant or non-dual lift DSC lifting lugs are not designed with the point system should have a design safety factors specified in NUREG-0612.

However, these lifts occur only with no safety factor of ten (10) times the fuel in the DSC and in the dock area of maximum combined concurrent the AB. There is no safe-shutdown static and dynamic load. equipment near, or below the area of this lift. Therefore, a drop of the empty DSC will have no unacceptable consequences.

Serial No. 07-0352 ATTACHMENT 6 LICENSE AMENDMENT REQUEST 227 RELOCATION OF SPENT FUEL POOL CRANE TECHNICAL SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 Attachment 6 Page 1 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

The replacement trolley was installed on an existing bridge Design criteria for construction phase and was not utilized in the construction of the plant nor for any operation. construction lifts. The usage of the replacement trolley and existing bridge is limited to operational load handling.

The existing trolley was replaced with a new trolley; hence the new trolley design was in accordance with the latest revision of CMAA Specification #70. The replacement trolley meets the applicable allowable stress limits for plant operation as indicated in section 3.4 of CMAA Specification #70-2004.

Allowable design stress limits of Table 2.1 3.3.3.1.3-1 of CMAA Specification The existing bridge structure was re-used as part of the

1. 70-1975. upgrade. The existing bridge was evaluated for the loading Construction imposed by the new replacement trolley in accordance with its None And original design and licensing basis requirements including Operating Periods EGCI 61, which bound the applicable allowable stress limits for plant operation as indicated in section 3.4 of CMAA Specification #70-2004.

The main hoist, auxiliary hoist and trolley were designed and manufactured in accordance with CMAA #70-2004 for Class A service, minimum. This service class is consistent with the anticipated trolley usage.

Design reflects the appropriate duty cycle in CMAA Specification #70.

The existing bridge structure was re-used as part of the upgrade. The bridge design basis exceeds current and projected usage as original design basis requirements of EGCI 61 are consistent with CMAA 70 service level and duty cycles.

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Structural analysis for various load combinations was used to maintain allowable design margins.

The trolley was designed for the applicable loading Sum total of simultaneously applied loads combinations from CMAA Specification #70-2004, NUREG (static and dynamic) should not result in 0554 design basis accident conditions (broken rope, two-stress levels causing permanent blocking and load hang-up) and OBE (Operating Basis deformation, other than localized strain Earthquake) and SSE (Safe Shutdown Earthquake) 2.1 concentration, in any part of the handling combinations Construction system.

The existing bridge was evaluated for the applicable load None And Operating combinations from EOCI-61, NUREG 0554 design basis Periods accident conditions (broken rope, two-blocking and load hang-up) and OBE and SSE combinations.

The main hoist and auxiliary hoist motions employed flux vector variable frequency drives while the trolley and bridge Effects of cyclic loading induced by motions employed scalar frequency drives to provide smooth jogging or plugging ... included in the slow speed positioning and gradual acceleration and design specifications.

deceleration, eliminating the effects of cyclic loadings induced by jOQQinQ and pluQQinQ.

Single-failure-proof crane should be The main hoist, trolley and bridge were designed for the designed to handle the maximum critical specified maximum critical load (MCl) of 125 tons. The load (MCl) ... auxiliary hoist was designed for the specified MCl of 15 tons.

Wearing components in the main hoist and auxiliary hoist, including wire ropes, sister hook, brakes, reducers and 2.2 bearings were designed with at least a 15% increase above Maximum Critical Increase of approximately 15% of the the MCl rating to account for degradation due to wear. The None Load design load (MCl) for component parts single prong hook for the auxiliary hoist was a commercial item subjected to degradation due to wear and provided with a 10% additional design factor for wear. The exposure. crane operates indoors in a clean environment and subject to limited usage, therefore no appreciable degradation due to wear and exposure is expected. As such, the 10% additional desiqn factor provided for the auxiliary hook is acceptable.

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The MCl (Maximum Critical load) and DRl (Design Rated The MCl rating should be clearly marked load) markings were clearly marked on the replacement on the crane. trolley, crane bridge and on both sides of the hoist lower blocks.

2.2 Certain single-failure-proof cranes may be required to handle non-critical loads of None Maximum Critical This requirement was not applicable to the upgraded crane.

Load magnitude greater than the MCl during plant maintenance period.

The MCl and DRl markings were clearly marked on the The DRl rating marked on the crane replacement trolley, crane bridge and on both sides of the separately from the MCl marking.

main & auxiliary hoist lower blocks.

60°F to 105°F, 100% maximum relative humidity, atmosphere Operating environment ... specified for pressure, and no emergency corrosive or hazardous the crane and lifting fixtures.

conditions were specified as design criteria.

2.3 The crane was located indoors, but outside of containment.

Closed boxed sections of the crane The crane is not subject to pressurization from tests or plant structure vented to avoid collapse during None Operating operational loads; therefore box sections were closed and not Environment containment pressurization.

vented. The crane is not exposed to containment spray.

Drainage should be provided to avoid Since the crane is located indoors, accumulation of water on standing water in the crane structure. the trolley was not a concern.

Serial No. 07-0352 Attachment 6 Page 4 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

The existing bridge structure was subjected to a cold proof Already fabricated crane structural load test @ 125% of rated capacity. The minimum operating components should be tested by temperature for the crane was set equal to the metal None subjecting the crane to a test lift at the temperature of the crane bridge girders recorded at the time of lowest anticipated operating temperature.

proof testing.

Impact testing Structural members (exceeding % inch) NOT required essential to structural integrity tested in All structural members essential to structural integrity of the for material with accordance with the following impact test new replacement trolley were subjected to Charpy V-notch nominal requirements. Either drop weight test per testing. The existing bridge structure was subjected to a cold thickness of 5/8" ASTM E-208 or Charpy test per ASTM A- proof load test @ 125% of rated capacity. or less per 370 may be used for impact testing. NC-2300 &

ASME NOG-1.

2.4 Material The existing bridge structure (girders, endtrucks and endties)

Properties Toughness recommendations were was fabricated from rolled plates with thicknesses ranging from 1,4 in. to 1 Y2 in, inclusive. The typical section thicknesses developed ... typical material section thickness for crane girders ... (2 in.). recommendations were not applicable for the existing bridge.

However, later information indicates that The replacement trolley was fabricated from plates and material thickness of (4 in.) or more ... structural shapes rolled from carbon steel with thicknesses The rules of ASME Code Class 3 Charpy ranging from 1,4 in. to 1 Y2 in, inclusive. For the structural testing do not make adjustments for members essential to the structural integrity of the None thickness greater than (2 1/2 in) ... replacement trolley, the required energy values of Table NOG-4212-1 were satisfied.

As an alternative, cold proof testing The existing bridge structure was subjected to a cold proof consisting of a single dummy test load load test @ 125% of rated capacity. The minimum operating equal to 1.25 times the MCl shall be temperature for the crane was set equal to the metal used to establish the minimum operating temperature of the crane bridge girders recorded at the time of temperature. proof load testinq.

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The cold proof test should be followed by a nondestructive examination of welds The welds on the existing bridge structure, whose failure could whose failure could result in the drop of result in the drop of the critical load, were subject to the critical load. The nondestructive nondestructive examination after cold proof load testing.

examination of critical areas should be repeated at four year intervals or less.

Cranes and lifting fixtures made of low-The existing bridge structure was not fabricated from ASTM 2.4 alloy steel such as ASTM A514 should A514 steel; however the existing bridge structure was Material be subjected to the cold-proof test in any None Properties subjected to a cold proof load test @ 125% of rated capacity.

case.

Cast iron should not be used for load-bearing components such as rope drums.

Cast iron was not used for any load bearing components.

Cast iron may be used for electric motor frames and brake drums.

Alternative methods of fracture analysis that achieve an equivalent margin of Not applicable for supplied equipment.

safety aQainst fracture ...

The crane was designed to retain control of the 125 ton MCl 2.5 Crane designed to retain control of and (Main Hoist) and 15 ton MCl (Aux Hoist) for all load None Seismic Design hold the load. combinations inclUding broken rope, two-blocking, load hang-up and aBE & SSE seismic events.

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The seismic and structural analysis of the crane determined that there was no trolley uplift for any of the applied loading combinations. The replacement trolley was provided with seismic restraints to trap it between the bridge girders in the Bridge and trolley designed to remain in event of wheel flange or rail failure.

place during a seismic event with their wheels prevented from leaving the The seismic and structural analysis of the crane determined tracks. that there was negligible bridge uplift for seismic condition with no live load on the crane hooks. However, the existing bridge was provided with seismic restraints to engage the runway rail head that provides both vertical and lateral restraint to prevent the crane bridqe from leavinq the tracks.

Analysis and the presence of seismic restraints ensure that the Bridge remains on the runway with bridge would remain on the runway and the trolley will remain brakes applied, and the trolley remains on the bridge with brakes applied during an aBE and SSE on the crane girders with brakes applied event. All crane brakes will be set when the crane is not being during a SSE event.

operated or power is removed.

The crane's design satisfied regulatory position 2 of 2.5 Crane designed and constructed in Regulatory Guide 1.29. The crane was designed to remain in accordance with regulatory position 2 of None place and hold the load during and after an aBE and SSE Seismic Design Regulatory Guide 1.29.

event.

The MCl plus operational and seismically induced pendulum and The crane mathematical model appropriately considered swinging load effects ... considered in seismically induced pendulum and swinging load effects. The the trolley design and they should be pendulum effect due to horizontal seismic input and swinging added to the trolley weight for the bridge load effects was evaluated and determined to be insignificant.

desiqn.

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The structural components of the replacement trolley and 2.6 Examine the (weld) joints by radiography existing bridge structure were welded together via primarily or ultrasonic inspection ... to ensure the structural fillet welds. The design eliminated the concern of None Lamellar absence of lamellar tearing in the base lamellar tearing since heavy plates were not used. Hoist Tearing metal and soundness in the weld metal. drums shell and hub weld integrity were verified by radiography or ultrasonic inspection.

Dye penetrant or magnetic particle examinations of new fabrication critical welds were. The weld joint geometries were not susceptible to lamellar tearing as the plates used in the Weld joints whose failure could result in joints were not heavy plates. The use of plates considered the drop of a critical load should be thin eliminates lamellar tearing concerns.

2.6 nondestructively examined. If these weld joint geometries would be susceptible to The welds on the existing bridge structure, whose failure could None Lamellar Tearing lamellar tearing, the base metal at the result in the drop of the critical load, were subject to joint should be nondestructively nondestructive examination after cold proof load testing. The examined. weld joint geometries on the existing bridge structure were not susceptible to lamellar tearing as the plates used in the joints were not heavy plates. The use of plates considered thin eliminates lamellar tearing concerns.

Historical data, as well as projected crane usage indicates far Fatigue analysis should be considered 2.7 less than 20,000 cycles will be applied to the replacement for the critical load-bearing structures and trolley. Therefore, additional fatigue analysis was not needed None components of the crane handling Structural for any components on the trolley, as CMAA Specification #70 Fatigue system used 20,000 cycles, minimum, as its design basis.

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The structural fatigue usage factors from CMAA Specification

1. 70-2004, Table 3.4.7-1 were used in the design of the replacement trolley. The design of the mechanical Cumulative fatigue usage factors should components of the replacement trolley considered the reflect effects of the cyclic loading from allowable stresses from CMAA Specification #70-2004 for the both construction and operating periods. appropriate service class (class A). The replacement trolley or existing bridge were not used for construction. The cumulative usage factor appropriately reflects the operating period for the crane.

Preheat temperatures for all weldments All welding procedures for the replacement trolley specified specified in the weld procedures. preheat temperatures per AWS 01.1.

2.8 Post weld heat treatment for all weldments specified in the weld None All welding procedures for the replacement trolley specified Welding procedures. To include section 2.6 Procedures post-weld heat treatment, per AWS 01.1, 2004. This is in welds, which shall be post-weld heat accordance with Sub Article 3.9 of AWS 01.1, 1976.

treated in accordance with Sub article 3.9 of AWS 01-1.

Primary or principal load-bearing components, equipment, and 3.1 Quality inspections and checks for the primary or principle load subsystems such as driving equipment, bearing components of the replacement trolley were None drum, rope reeving system, hooks, General performed.

blocks, control systems, and braking system should receive special attention.

Auxiliary hoisting systems of the main crane handling system ... single failure The design for the auxiliary hoist system is single failure proof.

3.2 proof.

None Auxiliary Systems Auxiliary systems or dual components for Oual systems were provided on the main hoist ensuring the the main hoisting mechanism ...

load will be retained upon a component or subsystem failure.

immobile safe position.

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Special features were provided in the design to sense over travel (control and power), overweight, overspeed, mis-spooling and unbalanced reeving. The electrical design Automatic controls and limiting devices 3.3 addressed the effects of phase reversal or phase loss in the designed ... disorders due to inadvertent hoist power supply (USNRC letter dated Aug. 26, 1983) as operator action, component malfunction None Electric Control well as undervoltage, overvoltage, and overcurrent protection.

Systems ... will not prevent the handling system Detection of any of the above faults removes power from the from stopping and holding the load.

hoists, placing them in a safe condition. Bridge and trolley motions were limited by travel limit switches, which de-energize the motor at ends of travel.

3.3 Emergency stop buttons were provided on the radio Emergency stop button added to the transmitter and back-up pendant station. These buttons will Electric Control None control station to stop all motion. remove power from all crane motors and set all brakes when Systems actuated.

3.4 Both the main and auxiliary hoists were provided with A crane that has been immobilized redundant brakes to allow portions of the hoist drive train to be None Emergency Repairs because of malfunction or failure of repaired while retaining the load. The hydraulic drum brakes controls or components while holding a on the main hoist can be manually modulated to lower a load critical load should be able to hold the in the event of hoisting equipment failure or power failure. The load or set the load down while repairs or auxiliary hoist holding brakes were provided with manual adjustments are made.

override levers to permit manual load lowering.

The hydraulic drum brakes on the main hoist can be manually modulated to lower a load in the event of hoisting equipment Manual operation of the hoisting system failure. A hand pump was provided to allow for power fail and the bridge and trolley transfer operation of the hydraulic system. The auxiliary hoist holding mechanisms to a safe laydown area. brakes were provided with manual override levers to permit manual load lowering. The bridge and trolley were provided with attachment points for manual operation.

Serial No. 07-0352 Attachment 6 Page 10 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC #

Crane design and operating area include provisions ... cause release of radioactivity during corrective repairs, Provisions (i.e. attachment points) were made to allow the replacements or adjustments are being trolley and bridge to be moved to a safe area for component made to place the crane handling system repair or replacement with a suspended load.

back into service after component failure(s).

Protection against excessive wire rope The Operating & Maintenance Manual provided includes wear ... through scheduled inspection instructions for scheduled inspection and maintenance of the and maintenance. wire rope consistent with OSHA 1910.179.

4.1 Design of the rope reeving systems(s) None The design of the main and auxiliary hoist reeving systems Reeving System should be dual with each system was dual with each system providing independent load providing separately the load balance ...

balance on the head and load blocks through configuration of configuration of ropes and rope ropes and rope equalizers.

equalizer(s).

Selection of the hoisting rope or running The selection of the wire rope for the main and auxiliary hoist 4.1 rope ... to maintain efficient working of reeving systems was consistent with the wire rope None Reeving System the individual wire strands ... during the manufacturer's application recommendations for their wire hoisting operation. rope.

The effects of impact loadings, Impact and dynamic loadings, including acceleration, acceleration and emergency stops emergency stops, broken rope, two-blocking, load hang-up should be included in selecting rope and seismic were considered in sizing the main and auxiliary reeving systems. hoist wire ropes and reeving system components.

Maximum load, including static and The maximum load, including the static and dynamic forces for inertia forces, on each individual wire normal operation on each individual wire rope in the dual rope in the dual reeving system with the reeving system with the MCl attached, does not exceed 10%

MCl attached should not exceed 10% of of the wire rope manufacturer's published breaking strength on the manufacturer's published breaking the total system or 20% on each of the dual systems for both strenqth. the main hoist and auxiliary hoist.

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The wire rope selection criteria used was based upon the Consider the wire rope yield strength, as ultimate strength of the rope. The transferred load under a well as ultimate strength, when specifying broken rope scenario was limited to 40% of the ultimate wire rope to ensure the desired margin strength of the rope in accordance with the requirements of on rope strength. ASME NOG-1 to ensure satisfactory safety margins are maintained, thereby minimizing rope yield strength concerns.

Maximum fleet angle from drum to lead sheave in the load block or between individual sheaves should not exceed 3 The hoist systems were designed such that the maximum fleet 1/2° at anyone point during hoisting angle in each hoist system does not exceed 3 1/2°.

except that for the last three (3) feet of maximum lift elevation the fleet angle may increase slightly.

The use of reverse bends is limited by the design. The design Reverse bends for running wire ropes utilized running sheave to wire rope diameters of 22:1 and should be limited, and the use of larger 26.8: 1 for the main hoist and running sheave to wire rope 4.1 sheaves considered where a diameters of 21:1 and 23:1 for the auxiliary hoist, which disproportional reduction in wire rope None Reeving System exceeds the 16:1 ratio required by CMAA and ratios fatigue life would be expected from the recommended by the sheave and wire rope manufacturers for use of standard sheave diameters for this application, thereby minimizing the stochastic affects of reverse bends.

fatigue.

Equalizer for stretch and load on the rope The design of the main hoist equalizer was a combination of reeving ... beam or sheave type or sheave and rocker beam. The design of the auxiliary hoist combinations thereof. equalizer was of the beam type.

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Dual rope reeving system with individual attaching points and means for balancing The main hoist design employed an equalizer rocker beam or distributing the load between the two and hydraulic shock absorbers to balance an~ .distrib~te the operating rope reeving systems will forces associated with load transfer. The aUXIliary hOist permit either rope system to hold the equalizer design limited equalizer travel to minimize transfer critical load and transfer the critical load forces.

without excessive shock in case of failure of the other rope system.

Pitch diameter of running sheaves and The pitch diameter of the drums and running sheave~ was drums ... in accordance with greater than 16 times the wire rope diameter as reqUired by recommendations of CMAA Spec. #70. Tables 4.5.2-1 and 4.6.4-1, respectively, of CMAA Specification. #70-2004 for class A service and 6 X 37 class rope.

The main hoist design used two drums with two ropes, with a Dual reeving system may be a single balanced dual reeving system with each rope terminatin.g on rope from each end of a drum terminating the drum it originated on. Each rope is capable of carrYing the at one of the blocks or equalizer with total load with a factor of safety of 5: 1 against the provisions ... designed for total load.

4.1 manufacturer's published breaking strength.

Alternatively, a 2-rope system may be None used from each drum or separate drums Reeving System The auxiliary hoist design used one drum with two r?pe~, with using a sheave equalizer or beam a balanced dual reeving system with the ropes terminating on equalizer or any other combination that the equalizer. Each rope is capable of carrying the total load provides two separate and complete with a factor of safety of 5: 1 against the manufacturer's reeving systems.

published breakinq strenQth.

Load hoisting drum ... structural and 4.2 The drum retaining devices are steel structures, which ensures mechanical safety devices to limit the that a shaft or bearing failure will not allow the main and None drop of the drum ... from disengaging Drum Supports auxiliary hoist drums to disengage from the brakes.

from its holding brake system.

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Head and load blocks should be The head and load blocks are designed to use a dual reeving designed to maintain a vertical load design to maintain a vertical load balanced about the center of None balance about the center of lift ... reeving the lift. The balanced dual reeving system eliminates tilt of the system of dual design. load block.

The design provides an equivalent margin of safety by load-block assembly should be provided Design providing a single load path (attachment point) with a 10: 1 with two load-attaching points, ... each ... consistent with factor of safety on ultimate strength consistent with NUREG 4.3 able to support a load of three times the NUREG 0612 0612 Appendix C and ASME NOG-1. The main hook design load (static and dynamic) ... without Appendix C and MCl was 125 tons and the auxiliary hook design MCl was 15 Head and Load permanent deformation. ASME NOG-1 Blocks tons.

Individual component parts of the main and auxiliary hoist systems were designed to support a static load of 200% of the Individual component parts of the vertical Design respective MCL. The single failure point components of the hoisting system ... head block, rope consistent with main and auxiliary hoist load and head blocks were designed reeving system ... load block ... dual- NUREG 0612 to support static loads of 125 tons and 15 tons, respectively, load attaching device designed to Appendix C and based upon a 10: 1 factor of safety on the average ultimate support a static load of 200% of the MCL. ASME NOG-1 strength of the material consistent with NUREG 0612 Appendix C and ASME NOG-1.

4.3 All load attaching points of the main hoist sister hook and auxiliary hoist single prong hook were statically load tested at 200% static load test performed for hook. None Head and Load a minimum of 200 % of their respective MCl ratings (i.e. proof Blocks testinQ at a minimum of 250 tons and 30 tons, respectively)

Measurements of the geometric All hook critical dimensions were measured before and after configuration of the hooks ... before and the load test.

after the load test.

Hook volumetric nondestructive exam, to verify soundness and integrity, before An ultrasonic examination was performed on the hooks before and after load test. Hook surface the proof load test and a magnetic particle test was performed examination, to verify soundness and on the hooks after the proof load test.

inteQrity, before and after load test.

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Load block should be non-destructively The load block hooks, hook nuts and crossheads components examined by surface and volumetric were non-destructively examined by surface and volumetric techniques. inspections.

Results of examinations documented and All test reports were provided to DEK in the quality control recorded. document package.

The maximum main hoist speed was 5 FPM, as given in CMAA Spec. #70-1975, Fig. 70.6 for slow speed. The Auxiliary hoist maximum critical load hoist speed for the auxiliary hoist of 20 Maximum hoisting speed for the critical speed is not in FPM was 5 FPM faster than recommended in CMAA Spec.

load ... limited to "slow" column of CMAA compliance.

1. 70-1975, Fig. 70.6 for slow speed. This is based on the use 4.4 Spec. #70. Complies with of commercially available gearbox ratios, which is permitted by NOG-1-2004.

section 5.2.10.3 of CMAA 70-2004. The auxiliary hoist speed Hoisting Speed provided complies with Table 5331.1-1 of ASME NOG-1-2004.

Conservative industry practice limits the By design, the maximum line speed of the main and auxiliary hoist wire ropes was less than 50 FPM. None rope line speed to 50 FPM at the drum.

4.5 The design of the main and auxiliary hoists employed the The reeving system designed to prevent means to two-block without cutting or crushing of the wire the cutting or crushing of the wire rope if None Design Against ropes as well as the alternate method, i.e. redundant travel Two-Blocking a two-blocking incident were to occur.

limit switches.

The mechanical and structural components of the complete hoisting The mechanical and structural components of the hoisting system .... required strength to resist systems were designed to withstand a two-blocking and load failure ... for two-blocking and load hang- hang-up event without permanent deformation or damage.

up.

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Means provided within the reeving system located on the head or on the A mechanical slip clutch was provided in the hoist drive train to load-block combinations to absorb or absorb the kinetic energy of the rotating machinery during a control the kinetic energy of rotating two-blocking or load hang-up event.

machinery during the incident of two-blockinq.

As an alternative, the protective control system to prevent the hoisting from two- The design used the alternative method, as well as the blocking should include, as a minimum, capability to withstand a two-block event. Primary rotary limit two independent travel-limit devices of switch on the drum shaft senses both the upper and lower different designs, and activated by positions of load block travel and stops the motion by de-separate mechanical means. These energizing the hoist controls. The secondary lever-operated devices de-energize the hoist drive motor power limit switch is tripped by the lower block and directly and the main power supply to prevent the breaks power to the hoist motor.

hoist from two-blockinq.

Each hoist frequency drive was programmed to only provide a margin of torque above what is required to lift the load, thereby limiting input energy into the system. Torque demand above The protective control system for load this value faults the drive and sets the brake. Additionally, an 4.5 hang-up should consist of load cell overload switch was installed in the hoist reeving systems.

systems in the drive train or motor The overload switches sense overloads that result from two- None Design Against Two- Blocking current sensing devices or mechanical blocking or load hang-up and de-energizes the hoist control in load-limiting devices. the up motion. The above systems were in addition to a mechanical slip clutch installed in the hoist drive train to absorb the energy associated with two-blocking and load hang-up.

Serial No. 07-0352 Attachment 6 Page 16 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC #

The main hoist used two shoe-type holding brakes on the high speed shafting to hold the load during normal operation. The Location of the mechanical holding hydraulic drum caliper brakes provide single failure proof brakes and their controls should provide braking for the design.

positive, reliable and capable means to stop and hold the hoisting drum. The auxiliary hoist utilized gearboxes and shoe brakes on each side of the drum to provide single failure proof/redundant brakinq capabilities.

The maximum torque of the main and auxiliary hoist driving This should include capability to motors is limited by the flux vector drives. The main and withstand the maximum torque of the auxiliary hoist drive trains, were designed to absorb this driving motor if a malfunction occurs and corresponding maximum motor torque. The hoist holding power to the driving motor cannot be brakes are designed to stop and hold the load under all shutoff.

specified loading conditions.

The primary rotary limit switch on the drum shaft senses both The auxiliary hoist, if supplied, should be the upper and lower positions of load block travel and stops equipped with two independent travel- the hoist motion by de-energizing the hoist controls. The limit switches to prevent two-blocking. secondary lever operated limit switch is tripped by the load block and directly interrupts power to the motor.

Lifting devices attached to the load block such as ... designed with a dual or 4.6 auxiliary device or combinations thereof. Lifting devices and interfacing lift points used for handling Each designed or selected to support a heavy loads will meet the associated requirements in NUREG- None Lifting Devices load of 3Xs the load (static and dynamic) 0612, Section 5.1.6.

being handled without permanent deformation.

Serial No. 07-0352 Attachment 6 Page 17 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

In the event of an excessive off-center lift with the main hoist, If side loads cannot be avoided, the 4.7 the unbalanced load limits will be tripped and the hoisting reeving system should be equipped with motion will be stopped. The main and auxiliary hoists were a guard that would keep the wire rope None Wire Rope also equipped with drum wire rope level wind limit s~itches Protection properly located in the grooves on the that would stop the hoisting motion if the wire rope did not drum.

spool properly into the drum grooves.

The proper functioning of the hoisting Component parts and the welds or bolting were designed in machinery during load handling ensured accordance with CMAA Spec. #70-2004 and ASME NOG by providing adequate support strength 2004. Deflection calculations were performed under load to of the individual component parts and the confirm frame deflection does not affect machinery alignment.

welds or bolting that bind them together.

4.8 None Machinery Alignment The main hoist design employed dual gear trains between the Where gear trains are interposed holding brakes and hoisting drums, but additionally employ~d between the holding brakes and the hydraulic drum brakes to provide single failur~ proof operation.

hoisting drum, these gear trains should A gear train was interposed between the holding bra~es and be single failure proof and should be of the hoisting drum on the auxiliary hoist. The gear trams are dual design.

dual and single failure proof.

The holding brakes should be applied 4.9 The holding brakes in the main and auxiliary hoisting systems when power is off and should be are applied when power is off or when a drum overspe~d automatically applied on overspeed to None Hoist Braking occurs. The braking systems are fail-safe, i.e. automatically System the full holding position if a malfunction activated when electrical power is removed.

occurs.

Each holding brake of the main and auxiliary hoists was Each holding brake should have a torque designed with a minimum capacity o~ 125% of th~ torque rating not less than 125% of the full-load developed during the hoisting operation at the pOint of brake hoisting torque at the point of application.

application.

Serial No. 07-0352 Attachment 6 Page 18 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

Minimum hoisting braking system should The main and auxiliary hoist control systems were provided include one power control braking system with dynamic braking through the flux vector drives.

(not mechanical or draq brake tvpe) ...

Two (2) ~hoe type high speed holding brakes were provided on the high speed shafting for the main hoist.

Minimum hoisting braking system should include ... two holding brakes. One (1) holding brake located on the high speed shaft and one (1) opposite the secondary gear reducer was provided for the auxiliary hoist.

Clarification.

Only the Minimum number of braking systems that Emergency The .main hoist emergency hydraulic drum brake system was should be operable for emergency Drum Brake provided to allow emergency lowering of a main hoist load.

lowering after a single brake failure system is Either of the two (2) auxiliary hoist holding brakes can be used should be two holding brakes for required to to lower the load.

stopping and controlling drum rotation. safely lower the load for the main hoist.

The main hoist design employed dual gear trains between the holding.brakes and hoisting drums, but additionally employed Holding brake system should be single hydraulic drum brakes to provide single failure proof operation.

failure proof; any component or gear train None should be dual if interposed between the The auxiliary hoist utilized gearboxes and shoe brakes on holding brakes and hoist drum.

each side of the drum to provide single failure proof/redundant brakinq capabilities.

Component parts, welds, and bolting were designed in accordance with CMAA Spec. #70-2004 and ASME-NOG 4.9 Dynamic and static alignment of all 2004, including seismic design in accordance R.G 1.92 and hoi~ting machinery components ... range 1.61 to assure machinery alignment during dynamic and static None Hoist Braking of lifted loads ... positioned and anchored System conditions. Deflection calculations were performed under load on the trolley platform.

to confirm frame deflection does not adversely affect machinery alianment.

Serial No. 07-0352 Attachment 6 Page 19 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

The main hoist drum emergency hydraulic brakes can be Provisions for manual operation of the manually modulated for emergency lowering. Either of the two hoisting brakes during an emergency auxiliary hoist holding brakes can be modulated through a condition.

control lever for emergency lowering.

The main hoist hydraulic brake system is capable of Adequate heat dissipation from the continuous lowering of the rated load at minimum speed brakes to preclude damage from without exceeding the brake temperature limits. The auxiliary excessive lowering velocity. hoist brakes also have sufficient thermal capacity for manual lowering through brake modulation.

Both the main and auxiliary hoist drums were supplied with Portable instruments to indicate the battery powered speed indicators to ensure lowering speeds lowering speed during emergency are not excessive. The speed indicators are located in an area operations.

visible from where manual lowering will be performed.

Only the main hoist emergency hydraulic drum brake was 4.9 Malfunction of a holding brake during required to safely control the load during emergency lowering emergency lowering of the load ... operations. Should a malfunction of the braking system occur, None Hoist Braking restore brake to working condition before it could be restored to operation before lowering is started.

System any lowering is started. Either of the two auxiliary hoist holding brakes can be used to lower the load.

5.1 Bridge and trolley drives provided with The bridge and trolley scalar frequency drives provide control and holding braking systems ... controlled braking. Holding brakes located on each motor are None Braking Capacity applied when power off. automatically applied when power is off.

Bridge and trolley drives provided with The bridge and trolley motor brakes will automatically set when control and holding braking systems ...

an overload condition is detected by the frequency drive.

applied on overload.

Serial No. 07-0352 Attachment 6 Page 20 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

Bridge and trolley drives provided with The bridge and trolley motor brakes will automatically set in control and holding braking systems ...

the event of a drive failure.

applied on failure in the drive system.

Maximum torque capability of the driving The maximum torque capacity of the driving motor and gear motor and gear reducer ... not exceed reducer for bridge and trolley motions was selected to not the capability of the gear train and brakes exceed the capacity of the gear train and brakes to stop the to stop the trolley and bridge from the motion from the maximum speed with the design rated load maximum speed with DRL attached. attached.

Incremental or fractional inch movements should be provided by such items as Subject provision is provided for bridge and trolley via use of variable speed controls or inching motor scalar frequency drive controls.

drives.

Control and holding brakes rated at The bridge and trolley control and holding brakes are capable 100% of maximum torque that can be of applying a counter torque that is 100% of maximum drive developed at the point of application. torque that can be developed at the point of application.

The trolley was provided with the A-4 drive arrangement per CMAA Spec. #70-2004. One mechanical brake is provided for 5.1 If two mechanical brakes, one for control each drive (i.e. 2 total).

and one for holding ... adjusted with one None Braking Capacity brake leading ... The bridge was provided with the A-5 drive arrangement per CMAA Spec. #70-2004. One mechanical brake is provided for each drive (i.e. 1 total).

Serial No. 07-0352 Attachment 6 Page 21 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

The bridge and trolley motors are provided with spring set, Brakes mechanically tripped to the on or electrically released holding brakes that are automatically holding position in the event of power applied when power is interrupted. For an overspeed supply malfunction or an overspeed situation, the frequency drives will sense an over voltage condition. condition and traverse brakes would set and prevent further travel.

Provisions made for manual emergency The bridge and trolley brakes included a manual release lever operation of the brakes. to permit manual emergency operation.

Holding brake should be designed so that Design of the bridge and trolley holding brakes is such that it cannot be used as a foot-operated they cannot be used as a foot-operated slowdown brake.

slowdown brake.

Drag brakes should not be used. Drag brakes are not used for the bridge or trolley drives.

The opposite drive wheels were inspected and found to be within the tolerance of +/-0.01 0". The bridges appear to be Opposite driven wheels on bridge or tracking properly on the runway as excessive wear was not trolley ... matched and identical noted on either the runway rail or crane bridge wheels. Had diameters. excessive wear been observed, it would have been an indication that the bridge drive wheels were not manufactured to the tolerances described above.

The bridge and trolley speeds are in compliance with the slow Trolley and bridge slow speed limits of operating speed given in CMAA Specification #70-1975 for CMAA Spec. #70 for handling MCl's. 125 ton capacity. The bridge speed was 50 FPM and the trolley speed was 40 FPM.

Serial No. 07-0352 Attachment 6 Page 22 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

Mechanical limiting devices provided to Positive mechanical end stops are installed on the runway for control or prevent over travel and limiting the bridge travel and on the bridge girders for limiting overspeed of the trolley and bridge. the trolley travel.

Travel limit switches are provided for the bridge and trolley to prevent over travel. Additionally, a restricted path system Electrical limiting devices provided to utilizing PlC and lasers is incorporated. For an overspeed control or prevent over travel and situation, the frequency drives would sense an over voltage overspeed of the trolley and bridge.

5.2 condition and traverse brakes would set and prevent further travel. None Safety Stops Buffers for bridge and trolley travel Compression bumpers, attached to the trolley and bridge, are should be included at the end of the rails. included for buffering contact with end of travel stops.

Safety devices such as limit-type Trolley and bridge limit switches are provided as safety switches provided for malfunction ... devices, in addition to the end stops and bumpers. The should be in addition to and separate switches are not intended for control of the trolley and bridge from the limiting means or control during normal crane operations. Additionally, a restricted path devices provided for operation. system utilizing PlC and lasers are incorporated.

The design of the individual components of the hoisting Horsepower rating of the hoist driving systems was based on the maximum torque capability (when 6.1 motor ... matched with the calculated ... hoisting the MCl at maximum acceleration and rated speed) of None Driver Selection design load and acceleration to the the hoist motor. The hoisting acceleration rate was controlled design hoisting speed. via the flux vector drive. Control of acceleration limits strain on the machinery and load-carryinq devices.

Serial No. 07-0352 Attachment 6 Page 23 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

To preclude excessive motor torque, the maximum torque capability of the electric The maximum motor torque was limited by the flux vector motor drive for hoisting should not frequency drive, preventing excessive motor torque build-up.

exceed the rating or capability of the This rated motor torque is less than the torque capacity of the individual components of the hoisting individual hoist components under all normal operating system required to hoist the MCl at the conditions, ensuring the motor does not overpower the hoist maximum design hoist speed. Over components. The main hoist has an overspeed switch, which power and overspeed conditions should causes all brakes to set when tripped.

be considered an operatinQ hazard.

The hoisting motion for the main hoist can be stopped within 3 inches with maximum critical load at maximum design hoist speed with all brakes operating. Additionally, ACECO's "defense in-depth" design of the main hoist braking system provides the capability of stopping the maximum critical load at 6.1 maximum design hoist speed within 5 inches, with each of the Controls capable of stopping the hoisting None Driver Selection three (3) individual brakes, being the two (2) holding brakes movement ... maximum hoisting and one (1) emergency brake system.

movement of 3 inches an acceptable stopping distance.

The hoisting motion for the auxiliary hoist can be stopped within 3 inches with maximum critical load at maximum design hoist speed with all brakes operating. The design of the auxiliary hoist braking system provides the capability of stopping the maximum critical load at maximum design hoist speed within 5 inches, with each of the two (2) holdinQ brakes.

The hoists are designed to stop and safely hold the load Prudent to include safety devices in the following any of the following fault conditions: overload, control system ... to ensure the controls overspeed, over travel, wire rope mis-spooling, and will return to or maintain a safe holding unbalanced load. Electrical design included provisions for the position in case of malfunction. Electrical effects of overvoltage, undervoltage, phase reversal, or phase circuit design ...

loss in the hoist power supply.

Serial No. 07-0352 Attachment 6 Page 24 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

For elaborate control systems, radio Emergency stop buttons that will remove power from all motors control ... an "emergency stop button" and set all brakes are provided on the radio transmitter and on placed at ground level to remove power the back-up pendant. Additionally, a floor mounted conductor from the crane independent of the crane bar disconnect switch is provided to remove all crane power.

6.1 controls.

For cranes with a DRl rating much None Driver Selection higher than the MCl rating ... electrical The main hoist, trolley and bridge MCl and DRl were both or mechanical resetting of the overload 125 tons, while the auxiliary hoist MCl and DRl were both 15 sensing device, away from the operator tons. Therefore, it was unnecessary to provide electrical or cab and included in an administrative mechanical resetting of overload sensing devices.

proQram.

Control system(s) provided should The effects of the inertia of the rotating hoisting machinery include consideration of ... the effects of such as motor armature, shafting and coupling, gear reducer, the inertia of the rotating hoisting and drum are considered in the design of the main and machinery, ... and drum. auxiliary hoist control systems.

Control system provided should include Hoisting (raising and lowering) of all loads, including the rated consideration of the hoisting (raising and load, is considered in the design of the control systems for the lowering) of all loads, including the rated 6.2 single failure proof crane.

load.

None Driver Control The crane will not be used to move individual spent fuel Systems elements. The main hoist will be used predominately to lift Control system adaptable to include spent fuel casks and cask components. The auxiliary hoist will interlocks that will prevent trolley and be used to move new fuel assemblies. ACECO's design bridge movements while spent fuel included a provision to prevent bridge and trolley operation elements are being lifted free of a reactor and allow main hoist and auxiliary hoist operation only. An vessel or storage rack. operator controlled selector switch is provided on the remote radio transmitter and back-up pendant to allow the subject feature.

Serial No. 07-0352 Attachment 6 Page 25 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

The design employed sensors in the motor control circuits to Means provided in the motor control detect and respond to excessive electrical current, excessive circuits to sense and respond to such motor temperature via thermostats embedded in the motor items as excessive electric current, windings, over travel via the hoisting limit switches, overspeed excessive motor temperature, overspeed, via the drum overspeed limit, and overload via the weight 6.3 overload, and over travel.

sensing switch.

The main and auxiliary hoist dynamic braking systems were None Malfunction Protection designed to absorb the kinetic energy of the rotating Controls should be provided to absorb machinery and stop the hoisting motion should one rope fail.

the kinetic energy of the rotating These forces were also designed to be absorbed via the machinery and stop ... if one rope or one mechanical holding brake systems. The kinetic energy of the reeving systems should fail.

released during rope failure will be absorbed in the equalizer system.

Increment drives for hoisting may be The main hoist speed is variable from 0.25 FPM to 5 FPM via provided by step less controls or inching the flux vector frequency drive. The auxiliary hoist speed is motor drive. variable from 0.5 FPM to 20 FPM.

None If jogging or plugging is to be used, the The frequency drives provided for crane motions, control the Drift points are 6.4 control circuit should include features to acceleration and deceleration of the motor and eliminate not provided in prevent abrupt change in motion. abrupt motion changes. the electrical Slow Speed Drives power system for the bridge or trolley motion.

Drift point in the electric power system for Drift points were not provided in the electrical power system for bridge or trolley movement should be the bridge or trolley motion.

provided only for the lowest speeds.

Serial No. 07-0352 Attachment 6 Page 26 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

Safety devices such as limit-type Bridge and trolley travel limit switches, both slow-down and switches provided for malfunction, end of travel, are provided as safety devices, in addition to the 6.5 inadvertent operator action, or failure end stops and bumpers. The switches are not intended for None Safety Devices should be in addition to and separate control of the bridge and trolley during normal crane from the limiting means or control operations. Hoist limit switches are provided as safety devices devices provided for operation. and are not to be tripped during normal hoisting operations.

The complete operating control system A complete control system was provided with the radio remote and provisions for emergency controls for radio transmitter. A back-up pendant station located in the the overhead crane handling system bridge mounted skeleton cab is utilized for emergency should preferably be located in a cab on controls.

the bridge.

When additional operator stations are The back-up pendant station was provided with controls similar considered, they should have control to those on the remote radio transmitter.

systems similar to the main station.

6.6 Manual controls for hoisting and trolley None The manual lowering controls for the main and auxiliary hoist Control Stations movement provided on the trolley, and were located on the trolley.

for the bridge provided on the bridge.

The main hoist, auxiliary hoist, trolley and bridge motions were Remote control for any of these motions infinitely variable (analog) control from the remote radio should be identical to those on the bridge transmitter and 5-step speed control from the back-up cab control panel.

pendant.

Cranes that use more than one control An electrical interlock was provided between the radio and station ... pendant control.

Serial No. 07-0352 Attachment 6 Page 27 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

Main and auxiliary hoist manual control is available on the In the design of control systems, trolley. Manual movement of the bridge and trolley is possible 6.6 provision for and locations of devices for from the runway and bridge endties, respectively. Emergency None Control Stations control during emergency conditions stop buttons are available on the radio transmitter and back-up should be provided. pendant. A floor mounted conductor bar disconnect switch is provided to remove all crane power.

Installation instructions were developed by ACECO, included Installation instructions should be in site installation work order package and utilized by ACECO provided by the manufacturer.

for the installation of the new trolley.

Include a full explanation of the crane 7.1 The operation and maintenance manual provided includes a handling system, its controls and full description of the crane control system. None General limitations for the system.

Instructions should cover ... The factory and site test procedures covered all testing Requirements for installation, testing, and requirements while the operation and maintenance manual preparations for operation. provided contains crane operating instructions.

Is the permanent plant crane to be used The new trolley and existing bridge was not used during for construction?

construction.

7.2 During and after installation of the crane, the proper assembly of electrical and After functional and load testing at the factory, the trolley was None Construction and Operating Periods structural components should be verified. shipped to KPS. After installation at the plant, the new trolley The integrity of all control, operating and and crane control system will be inspected and tested to an safety systems should be verified as to ACECO designed procedure, which verifies the integrity of all satisfaction of installation and design control, operating and safety systems.

requirement.

Serial No. 07-0352 Attachment 6 Page 28 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

In order to verify the crane's mechanical and electrical systems were properly installed, the requirements of NOG 7500 "Qualification for Permanent Plant Service", as they apply to A complete check ... Crane's mechanical the new trolley, will be used. These requirements include and electrical systems to verify the Section 7520 "Inspection Prior to Performance Testing", NOG proper installation and to prepare the 7521.2 "Mechanical Inspection", NOG 7521.3 "Electrical 8.1 crane for testing. Inspection (Visual) While Crane is Immobile", and NOG 7530 which invokes the requirements of NOG 7420 "Pre-operational None General Testing and Inspection" and NOG 7421 "No load Test".

These requirements exceed those required in ASME 830.2.

Information concerning proof testing on components and subsystems ...

A complete functional and load test report was supplied to performed at the manufacturer's plant ...

DEK after testing was completed.

available for the checking and testing performed at the place of installation.

The crane system should be static load tested at 125% of MCl, ... including all The replacement trolley was load tested to 125% of MCl at positions generating maximum strain in the factory. load testing will be completed on site to verify the bridge and trolley structures and proper operation and structural integrity of existing bridge and positions recommended by the designer runway support structure, respectively.

and manufacturer 8.2 After making required adjustments resulting from 125% static load test, Complete 100% and 125% performance and load tests were None Static and Dynamic 100% MCl performance test for all performed at ACECO's facility. The 100% and 125%

Load Tests speeds and motions for which designed. performance and load tests will be also performed on site. All All safety and limiting control devices will limits will be verified during site testing.

be verified.

Emergency manual lowering of the load Emergency lowering of the MCl for the main and auxiliary and manual movement of the bridge and hoist was demonstrated during factory load testing. Manual trolley should be tested with the MCl release of trolley and bridge brakes was demonstrated during attached. factory tests and site tests, respectively.

Serial No. 07-0352 Attachment 6 Page 29 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

When equipped with an energy-controlling device between load and head blocks the complete hoisting machinery is allowed to two-block (load block limit and safety devices bypassed). Test, at slow speed and no load, to provide A two-block test of the main and auxiliary hoist was performed assurance of design, controls and during factory functional testing.

overload protective devices.

Demonstrate that the maximum torque 8.3 developed by the driving system, None Two-Block Test including inertia of the rotating parts at the over torque condition, will be absorbed or controlled.

The complete hoisting machinery tested for ability to sustain a load hang-up The overweight limits on the main and auxiliary hoists were condition ... load block attaching points calibrated and tested during factory load testing. The proper are secure to a fixed anchor or an operation of the mechanical slip clutch, which was present to excessive load. Crane manufacturer ... mitigate the effects of a two-blocking or load hang-up event, ensure proper functioning of protective was verified for each hoist during factory testing.

overload devices.

Operational tests of crane systems The crane systems were operated to verify the proper performed to verify the proper functioning functionality of all limit switches and other safety devices in of limit switches and other safety devices accordance with the requirements of NaG 7421 "No Load and the ability to perform as designed. Test", as well as the additional requirements contained in NOG 8.4 7421.1.

Special arrangements may have to be The hoist overload sensors were tested during the 125% load None Operational Test made to test overload and overspeed tests on the main and auxiliary hoists. The overspeed sensing sensing devices. devices were tested by reprogramming the frequency drive to cause the motor to overspeed. Actuation of the overspeed detection circuit was verified to occur at 115% of the critical load rated speed.

Serial No. 07-0352 Attachment 6 Page 30 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AS CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

With good maintenance practice, degradation is not expected to exceed ACECO included inspection and maintenance procedures in 15% of the design load rating, and the operation and maintenance manual. The inspections periodic inspection coupled with a encompassed the requirements necessary to assure maintenance program should ensure that degradation of the critical wearing components does not affect the crane is restored to the design the crane's MCl rating.

condition if such degradation is found.

8.5 The MCl and DRl rating of the crane were 125 tons. An The MCl rating of the crane should be approximate 15% additional design factor was included for the None Maintenance established as the rated load capacity, mechanical components subject to wear, including wire rope, and the design rating for the degradable hooks, sheave and drum bearings, and brakes. If degradation portion of the handling system should be of the handling system is discovered, it will be handled in identified to obtain the margin available. accordance with KPS condition reporting system (CRS) procedures.

The MCl should be plainly marked on The MCl rating was marked on the bridge and each side of each side of the crane for each hoisting each lower blocks.

unit.

ACECO provided a manual of information to use for checking, Crane designer and manufacturer should testing, and operating the trolley. Information obtained during provide a manual of information and testing was also provided in the manual. The manual also procedures for use in checking, testing described a preventive maintenance program based upon the and operating the crane. Manual to 9 requirements of OSHA 1910.179, ASME 830.2 and ASME describe a preventive maintenance NOG-1. The preventive maintenance program provided the None Operating Manual program based on the approved test information required to service, repair, and replace all major results and information obtained during trolley and hoist components. Additionally, where applicable, testing. Include such items as ...

visual examinations, equipment diagnostics, and Operating requirements for all travel nondestructive examinations were described in the manual.

movements ... Clearly defined ...

The manual also described operating features and limitations.

Serial No. 07-0352 Attachment 6 Page 31 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG-0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

The allowed rope degradation margin was per ASME 830.2.

The designer should establish the MCl The allowed hook degradation margin was per ASME 830.10.

rating and the margin for degradation of The allowed brake degradation was per the brake wear susceptible component parts. manufacturer's recommendations, included with the operation and maintenance manual.

A quality assurance program should be ACECO's approved 10CFR 50 Appendix 8 quality plan established to include the established the requirements and responsibilities for control of recommendations of this report for the the design, fabrication, and factory testing of the replacement design, fabrication, installation, testing trolley and controls.

and operation of crane handling systems for safe handling of critical load. ACECO provided site installation and test plans that were incorporated in the site work order management system for the 10 implementation of field activities. ACECO's approved 10CFR None Quality Assurance 50 Appendix 8 quality plan and DEK's 10CFR50, Appendix 8 program established the requirements and responsibilities for control of the field installation and field testing of the replacement trolley and controls.

DEK's 10CFR50, Appendix 8 program addressed the requirements for continued operation of the upgraded crane at the site.

Applicable procurement documents should require the crane manufacturer to ACECO's quality program was accepted by DEK and met the provide a quality assurance program applicable requirements of NUREG-0554 and 10CFR50, consistent with the pertinent provisions of Appendix B. The applicable requirements were invoked in the Regulator Guide 1.28, to the extent procurement documents.

necessary. Program to address NUREG-0554.

Program should address all The quality assurance plan addressed all areas of concern recommendations in this report. includinq the critical components of the trolley system.

Serial No. 07-0352 Attachment 6 Page 32 of 32 NUREG-0554 COMPLIANCE MATRIX FOR UPGRADED KPS AB CRANE NUREG*0554 NUREG REQUIREMENT KPS COMPLIANCE EXCEPTIONS SEC#

General qualification requirements for crane operators, including the requirements of ASME 830.2, were included in Include qualification requirements for the operation and maintenance manual to assist the customer crane operators.

in developing operator standards. Additionally, operator and maintenance traininq was provided by ACECO on-site.

Serial No. 07-0352 ATTACHMENT 7 LICENSE AMENDMENT REQUEST 227 RELOCATION OF SPENT FUEL POOL CRANE TECHNICAL SPECIFICATION TO TECHNICAL REQUIREMENTS MANUAL COMMITMENTS IN THIS LAR KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0352 License Amendment Request 227 Attachment 7 Page 1 of 1 List of Regulatory Commitments This table identifies actions discussed in this letter for which DEK commits to perform.

Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

TYPE (Check One)

COMMITMENT ONE-TIME CONTINUING ACTION COMPLIANCE Notify the NRC when the modifications to the Auxiliary x

8uilding crane to make it single-failure-proof are complete All heavy load lifts in or around the spent fuel pool made using the upgraded AB crane lifting system will meet the guidance in NUREG-0612, Section 5.1.6, as follows:

• Special lifting devices, as defined in ANSI N14.6 will meet the guidance in NUREG-0612, Section 5.1.6(1 )(a) and ANSI N14.6-1993, as clarified in Attachment 5 to this LAR.

• Lifting devices not specially designed will meet the x

guidance in NUREG-0612, Section 5.1.6(1 )(b) and ASME B30.9-2003, as clarified in Attachment 5 to this LAR.

• The AB crane will meet the guidance in NUREG-0612, Section 5.1.6(2) and NUREG-0554 as clarified in Attachments 5 and 6 to this LAR.

• Interfacing lift points will meet the guidance in NUREG-0612, Section 5.1.6(3), as clarified in Attachment 5 to this LAR.

Crane operator training will meet the guidance in ASME x

830.2-2005.

Crane maintenance and inspections will meet the guidance in x

ASME 830.2-1976.

Revise USAR Section 9.5.2 to remove the dropped cask x

analysis from the USAR.

After LAR approval and relocation of TS 3.8.a.7 to the TRM is authorized, add to the TRM required actions to take if the A8 x

crane lifting system is found not to meet the TRM requirements during a heavy load lift.