ML17214A158

Control of Heavy Loads (C-10) St Lucie Unit 1, Draft Technical Evaluation Rept

ML17214A158
Person / Time
Site:	Saint Lucie
Issue date:	04/29/1983
From:	Ahmed N, Bomberger C FRANKLIN INSTITUTE
To:	Clemenson F NRC
Shared Package
ML17214A157	List: ML17214A158
References
CON-NRC-03-81-130, CON-NRC-3-81-130, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR TAC-08083, TAC-8083, TER-C5506-394, TER-C5506-394-DRFT, NUDOCS 8306080252
Download: ML17214A158 (38)

Text

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(DRAFT)

. Enclosure 1

~ TEcHNlcAL EVALUATIolIPEPCRT

'ONTROL OF HEAVY LOADS (c-1ol FLORIDA POh'ER AND LIGHT COj~iPANY ST.

LUCIE UNIT 1 NRC DOCKET NO. 50-335 NRC TAC NO.

08083 r

NRC CONTRACT NO. NRC43-81-130 FRC PROJECT C5505 FRC ASSIGNMENT 13 FRCTASK 394 Prepared by Franklin Research Center 20th and Race Streets Philadelphia, PA 19103 Author:

C. Bomberger, H. Ahmed FRC Group Leader:

T.. H. Sargent Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer:

P.

Clemenson Apri.l 29, 1)83 This repoa was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or re pcnsibility for any third party's use, or the results of such use, of any information, appa-ratus, product, or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.

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. ~ I TERM550 6-39 4 CONTENTS Se ction Title Pacae 1

INTRODlXTION.

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1 1.1 Purpose of Review 1.2 Generic

Background

1.3 Plant-Specific Background

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2 EVALUATION 4

CON LUSION

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3.1 General Provisions 3.2 Interim Protection for Load Handling 2.1 General Guidelines 2.2 Interim Protection Measures.

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4 17 20 20 21 L~ZERENCES

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0 TERM550 6-39 4 l.

INTRODUCTION 1.1 PURPOSE OF Rc&IBP This technical evaluation report documents a review of general load handling policy and procedures at Florida power and Light Company 's (Fp&L) St.

Lucie Unit 1.

This evaluation was performed with the following objectives:

o to assess conformance to the general load handling guidelines of NUBEG-0612, "Control of Heavy Loads at Nuclear Power Plants" [1],

Section 5.1.1 j

o

- to assess conformance to the interim protection measures of NUREG-0 612, Section 5.3.

l. 2 GENERIC EACKGROUND Generic Technical Activity Task A-36 was established by the Nuclear Regulatory Commission (NRC) staff to systematically examine staff licensing criteria and the adequacy of measures in'effect at operating nuclear power plants to ensure the safe handling of heavy loads and to recommend'necessary changes in these measures.

This activity was initiated by a letter issued by the NR staff on Yay 17, 1978

[2] to all power reactor licensees, requesting information concerning the control of heavy loads near spent fuel.

Tne results of Task A-36 were reported in NUREG-0612, "Control of Heavy Loacs at Nuclear Power Plants."

The staff's conclusion from this evaluation was that existing measures to control the handling of heavy loads at operating

plants, although providing protection from certain potential problems, do not adequately cover the major causes of load handling accidents and should be upgr aded o

In order to upgrade measures for'he control of heavy. loads, the staff developed a series of guidelines designed to achieve a two-part objective using an accepted approach or protection philosophy.

The first portion of the objective, achieved through a set of general guidelines identified in NUB=-G-0612, Section 5.1.1, is to ensure that all load handling systems at nuclear power plants are designed and operated so that their probability of

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TER-C5506-39 4 ailure is uniformly small and appropriate for the critical tasks in which they a

e employed.

The secona portion of the staff's objective, achieved through guidelines identi ied in NUREG-0612, Sections 5.1.2 through 5.1.5, 's to ensure that, for load hanaling systems in areas where their failure migh" result in significant consequences, either (1) features are provided, in addition to those required for all load handling systems, to ensure that the potential, for a load drop is extremely small (e.g.,

a single-failure-proo cr ane) or (2) conservative evaluations of load handling accidents 'indicate that the potential consequences of any load drop are acceptably small.

Acceptability of accident consequences is quantified in NUREG-0612 into four accident analysis evaluation criteria.

A defense-in-depth approach was used to develop the staff guidelines to ensure that all load handling systems are designed and operated so that their

,probability of failure is appropriately small.

The intent of the guidelines is to ensure tha't licensees of all operating nuclear power plants perform the following:

o define safe load travel paths through procedures and operator traininc so that, to the extent practical, heavy loads are not carried over or near irradiated fuel or safe shutdown equipment o

provide sufficient operator training, handling system design, load

'andling instructions, and equipment inspection to assure reliable operation of the handling system.

Staff guidelines resulting from the foregoing are tabulated in Section 5

of NUREG-0612.

Section 6 of NUREG-0612 recommended that a program be in'tia d

to ensure that these guidelines are implemented at operating plants.

1.3 PLA?K-SPECIFIC BACKGROUND On December 22, 1980, the NRC issuea a letter

[3) to Florida Power and.

Light Company, the Licensee for St. Lucie Unit 1, requesting that Fp&L rev ew provisions for handling and control of heavy loads, evaluate these provisions with respect to the guidelines of QJREG-0612, and provide certain additional info mation to be used for an independent determination of conformance to these guidelines.

On July 2,

1981, FP&L provided the initial response ['] tc

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TERM550 6-39 4 this request.

Additional information was provided on September 30, 1981 f5]

as pa t of the Phase II report for St.

Lu "ie Unit l.

In response to a telephone conference call on January 7,

1982 between the Licensee and NR",

aPGL provided additional information on July 28, 1982

[6] which has been incorporated into this technical evaluation.

ran'riin Research Center h 0~x,=o cf Th>> Free~ nlnv tu(e

0 TERM550 6-39 4 2.

EVF2 UATION This section presents a point-by-point evaluation of load handling provis'ons at St. Lucie Unit 1 with respecr. to NR" staff guidelines provided in NUR-G-0612.

Separate subsections are provided for both the general guidelines of NUREG-0612, Section 5.1.1 and the interim measures of NUREG-0612, Section 5.3.

In each

case, the guidelines or interim measure is presented, Licensee-provided information is summarized and evaluated, agd a

conclusion as to the extent of compliance, including recommended additional action where appropriate, is presented..

These conclusions are summarized in Table 2.1.

2. 1 GENERAL GUIDELINES The NBC has established seven general guidelines to provide the defense-in-depth appropriate for the safe handling of heavy loads.

They are identified under the following topics in Seption 5.1.1 of NUREG-0612:

o Guideline l Safe Load Paths o

Guideline 2 Load Handling Procedures o

Guideline 3 Crane Operator Training o

Guideline 4 Special Lifting Devices o

Guideline 5 Lifting Devices (Not Spdcially Designed) o Guideline 6 Cranes (Inspection,

Testing, and Maintenance) o Guideline 7 Crane Design.

These seven guidelines should be satisfied by all overhead handling

\\

systems and programs used to handle heavy loads in the vicinity of the reactor

vessel, near spent fuel in the spent fuel pool, or in other areas where a load drop r~y damage safe shutdown systems.

2.1.1 NUREG-06l2 Overhead Hea Load Handlin S stems a.

Summar of Licensee Statements and Conclusions he Licensee has stated that the ollowing overhead load handling systems at St. Lucie Unit 1 are subject to the general guidelines of NUREG-0612:

.'.. r"ran~Pin Research Center A Cies.=-. c! ~he Frank!.~ tns':~te

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Table 2.1.

St. Lucio Unit 3/HURSG"0612 Conpllance Hatrlx lfelght or Capacity

~t Guldellne 1

Guldellne Sa(e Imbed Paths rrncedurea Inter ln Inter In 2

Guldel Inc 3 Guldellne 4

Culdellne 5

Culdellne 6

Guldellne 7

Heasure 1

Heasure 6

Crane Operator Special I,IEtlng Crane - Test Technical Special

~TI D

I

~all

~dl tl c

D lg

~Gift tl Att. tl 1 ~ Cont a lnec nt Polar Crane 175 C

Reactor Vessel llead 119.7 P

Vlqmr Guide Structure 66ei p

Inser vlcc In-rpectlnn Tool Reactor Cool-ant Puwps Hl as l le Shields I 5 4 ~ 3 P

72' P

C C

~\\

C C

C

'i

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Crane load 0 lock 1.7 I'

C C

I'ressurlser Hiss lie Shields

2. Intake Structure Or ld9e Crane 45 C

C C

I.lcennee action conpllen with tlunl'4-0612 culdel lne.

P I.lcensee action Indicates part!el conpl lance with HUNG-0612 Culdellne.

RC I.lcensee action does not cosply with the HURSC-0612 Culdellne.

IG InVl VI C)

IW eli

~ Ql nt r-- ri c IeD nt Weight or Culdel Inc 1 Capacity

,Sa(e load

~t P tt 3

Iuel nulldlng Fuel Cask Dr Idge Crane 105 Table 2.1 (Cont.)

Interln Interlsd Culdellne 2

Ouldellne 3

Culdel lne 6

Guideline 5

Culdellne 6

Culdellne 1

IIeasure 1

IIeaaure 6

Crane Operator Special Ll(ting Crane - Test Technical Spec la 1 I

d

. ~TI I II I

~Sll

~dl tl

~CD I

S~ltl tl I Att tl C

Spent Fuel Shlpplng Cask.

25 W. Auxlllary Te 1 e scop Ing I

Jlb Crane 1.0 5 ~

ne reel lng Ilhchlne Ilolat ls0

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6. Fuel Fool Dulkhead Ilonori1 1 1 Fuel tel Dulkhead 3.0 2 5 C

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TERM"-50 6-39 4 o

reactor building polar crane o

intake structure bridge crane o

fuel cask bridge crane o

auxiliary telescoping jib crane o

refueling machine 1-ton hoist o

fuel pool bulkhead monorail.

The turbine building gantry crane has been excluded on the basis that exclusion areas have been developed for the two areas of concern (the steam I

trestle and'he intake cooling water piping); movement of other loads is not restrained outside of these areas..

Other load handling systems were excluded from the general guidelines of NUR"=G-0612 on the basis that sufficient physical separation exists between the potential load impact areas and systems or components required for plant shutdown or decay heat removal.

Further, the pump room, charging pump',

and diesel generator A and B monorails have been excluded because the function of these monorails involves a sole-purpose maintenance lift., %erefore, the equipment: which could possibly be damaged by a load drop will already be inoperative for maintenance.

b.

Evaluation The Licensee's evaluation of load handling systems subject to the general'uidelines is consistent with the intent of NUREG-0612, with the exception of the turbine building gantry crane.

Since this crane can potentially damage safety-related equipment, use of exclusion areas may, be adequate to preclude the need to develop safe load paths but is not adequate justification for excluding this crane from compliance with the general guidelines of NUREG-0612, Section 3.1.1.

c.

Conclusion and R commendation The Licensee should reevaluate the turbine building gantry crane for compliance with the general guidelines of NUREG-0612.

Evaluation of those oDer handling systems cuzrently subject to compliance is consistent with NUREG-0612 guidance.

"renMin Rese reh Center 4 Dissson o! The Frs~ nlnsesrree

TERM550 6-39 4 2.1.2 Safe Load Paths (Guideline 1, NUBEG-063.2, Section 5.1.1 1

"Safe load paths should be defined for the movement of heavy loads to minimize the potential for heavy loads, if dropped, to impact irradiated fuel in the reactor vessel and in the spent fuel pool, or to impact safe shutdown ecuipment.

Tne path should follow, to the extent practical, structural floor members, beams, etc.,

such that if the load is dropped, the structure is more likely to withstand the impact.

These load paths should be defined in procedures, shown on equipment layout drawings, and clearly marked on the floor in the area where the load is to be handled.

Deviations from defined load paths should require written alternative procedures approved by the plant safety review committee.'.

Surrana of Licensee Statements and Conclusions The Licensee has stated that safe load paths have been identified at St.

Lucie Unit 1 according to the guidelines of NUEKG-0612 in Administrative Procedure (AP) 0010438, "Control of Heavy Load Lifts."

Safe load paths have been defined for all load handling systems from which a load drop could conceivably result in damage to irradiated fuel or systems required for plant shutdown or decay heat removal, except for 'the special fuel handling equip-ment, since operation of this equipment is described in detail in existing plant procedures and in the FSAR.

St. Lucie Unit 1 procedure AP 0010438

.describes the measures to be taken to ensure that load handling operations

'remain, within safe load paths and defines these areas.

This procedure requires (1) that, a sign be posted at the controls of each affected crane stating that heavy loads are not to be carried out of the safe load path and (2) that a map of the safe load area be posted.

Safe load paths have been identified in applicable sketches showing arrangement of plant buildings.

Deviations from &is administrative procedure require prior approval by the Facility Review Group.

The bases for use of restricted areas are the different capabilities of the structures in the area to withstand a dropped load and the potential for damage to irradiated fuel and safe shutdown equipment.

Further, the Licensee does not feel that marking the safe load paths on building floors is a practical or necessary means of informing the operator of the safe area.

The sketches'which are readily available to the operator at the hoist controls are I 'ran~tin Research Center 4 Cws o-. cl The Frand.n lns'.:u<c

TERM550 6-39 4 easy to understand and serve the same purpose as floor markings.

Also, floor markings can be obstructed by equipment and are not feasible in certain areas.

b.

Evaluation Safe load paths at St. Lucie Unit 1 are not consistent with the criteria specified in Section 5.1.1(l) of NUREG-0612.

A review of the Licensee's response and sketches indicates that areas have been established in which the movement of heavy loads is restricted or excluded; however, specific pathways for the movement of loads, as specified in Guideline 1, have not been designated.

.The use of exclusion areas is acceptable where the size of the restricted t

area is relatively small compared to the overall coverage of the handling device such as in the turbine building, the fuel handling building, and the intake structure. 'owever, inside of containment, it is not apparent that all

paths, other than the restricted areas noted, are equally desirable for heavy load movement considering the objective:

to minimize passage over safe shutdown equipment and to use structural members where feasible.

Further, the.

intent of NUREG-0612 is to provide the crane operator with load paths predetermined by engineering review.

In addition, load path visual aids should be provided to crane operators so that the operators can concentrate on movement of the. load.

These aids are used to clearly identify those areas where movement of heavy visual loads will occur.

Possible alternatives to floor markings are benchmarking the

crane, identifying physical boundaries, and the use of dedicated load handling supervisors (with duties delineated by procedure).

c.

Conclusion and Recommendations St. Lucie Unit 1 partially complies with Guideline 1 of NUREG-0612.

In order to comply fully, the Licensee should perform the following:

1.

Develop load paths for major heavy loads handled inside of containment

'2.

Provide visual aids to assist the crane operator in identifing safe load paths and exclusion areas.

bJ" Franklin Research Center h Division o! The Fssnlbn Insole

T=R-C550 6-39 4 2.3..3 Load Handlin Procedures

[Guideline 2, tlUEKG-0612, Section 5.1.1 2

"Procedures should be developed, to cover load handling operations for heavy loads that are or could be handled over or in proximity to irradiated fuel or safe shutdown equipment.

At a minimum, p ocedures should cover handling of those loads listed in Table 3-1 of NURBG-0612.

These procedures should include:

identification of required equipment; inspections and acceptance criteria required before movement of load; the steps and proper sequence to be followed in handling the load; defining the safe path; and other special precautions."

a.

Summar of Licensee Statements and Conclusions Procedures have been developed at St. Lucie Unit 1 to cover load handling operations for heavy loads that are or could be handled over or in proximity to irradiated fuels and safe shutdown equipment.

Administrative procedure AP

0010438, "Control of Heavy Load Lifts," describes the measures taken to ensure that load handling operations remain within safe load paths and defines these areas.

We procedure requires that a sign be placed at the controls of I

affected crane stating (1) that all heavy loads (defined as 1380 lb for Lucie Unit 1 in accordance with NUREG-0612) shall not be carried out of each St.

safe load path and (2) that a map of the safe load paths be posted on the crane.

Several plant procedures for carrying specific loads have been

',implemented, including the following:

M-0913/M-0022 Spent Fuel Shipping Cask-M-0020 MW015 M-0021 M&015 M-0015 Fuel Pool Bulkhead Reactor Missile Shields Pressurizer Missile Shields

. Reactor Vessel Head Upper Guide Structure.

A special procedure will be developed for the ZSX todl in accordance with NUREG-0612, Section 5.1.1(2) befor'e its next intended use.

For new and spent fuel elements, procedures have been developed which regulate use of the respective handling equip-ent:

(1)

OP 1630023 - Fuel

"'"."FrenlJin i?eseerch Cen!er A Oi~s4on d.he F>eo'~in Ins'u'.c

,-10>>

TER-C5506-394 Transfer Yachine; (2)

Op 1630022 - Spent Fuel Handling Y~chine; and (3)

OP 1630024 - Refueling Yeech ine.

Load handling procedures contain the information specified in NUB"-G-0612, Guideline 2.

b.

Evaluation The load handling procedures used at St. Lucie Unit 1 are consistent with the guidance of NUR G-0612 based on a verification by the Licensee that the procedures contain the information required by Section 5.1.1(2).

In addition to the load-specific procedures, procedure AP 0 010043 8 has been identified by the Licensee as providing general guidelines for conducting load handling operation for heavy loads that are lifted over or in proximity to irradiated fuel or safe shutdown equipment.

c.

Conclusion Load handling procedures at St. Lucie Unit 1-satisfy Guideline 2 of NUREGW 612

2. 1. 4 Crane 0 erator Traininct Guideline 3, NURHG-0 612, Section 5.1. 1 3) ]

"Crane operators should be trained, qualified and conduct themselves in accordance with Chapter 2-3 of ANSI B30.2-1976 'verhead and Gantry Cranes'7]

a.

Suttrnar of Licensee Statements and Conclusions The Licensee has stated that a program for crane operator training, qua 1ification, and conduct, in accordance with ANSI B3 0 ~ 2-197 6, Chapter 2-3 g will be implemented with the following exceptions:

l.

Eye test of 20/40 in both eyes for new employees willbe'equired.

2 ~

The cr ane deadman switch instead of the main line disconnect will be used to secure power because of the power requirhments of the crane motor heaters.

3.

Only controls n'ecessary for cr ane operation will be tested before beginning a new shift.

'"' Franklin Research Center A Dn.s:oa e! The FrcnVin Ir ~ JNllc

TZRM550 6-39 4 4.

At shift change, the upper limit device will be tested under no load unless the hook is loaded at shift change or unless no crane operation in the area of the upper limit is anticipated.

b.

evaluation Crane operator training at St. Lucie Unit 1 substantially satisfies Section 5.1.1(3) of NUREG-0612 because the Licensee will implement a program in accordance with ANSI B30.2-1976, Chapter 2-3 ~

Tne exceptions in eye testing and crane power disconnecting meet the intent of NUREG-0612.

The eye testing requirements of ANSI B30.2 are intended to provide a baseline for all operators which is satisfied by FPaL eye testing requirements.

Further, disconnecting power at the deadman switch so that main power willstill be available to the motor heaters while crane motion is secured is reasonable.

Shift testing of only those crane controls necessary for crane operation is satisfactory with the understanding that all crane motions will-be tested unless a unicue condition at shift change prohibits such testing.

Similarly, although it is reasonable that upper limit,switch testing is inappropriate with an attached load or when lifts at the lower extreme of hook travel are planned, specific definition is required as to when upper limit switch testing

..may be deferred.

c.

Conclusion and Recommendations Crane operation at St. Lucie Unit 1 partially complies with Guideline 3.

Tne Licensee should make the following modifications to the existing training program and crane operating procedures:

1..Crane motion controls should be tested prior to initial load movements on each shift unless unicue conditions at shift change prohibit..the testing of certain controls.

2.

Specific criteria should be established for deferring upper limit switch testing and should include consideration of operator response I

time necessary to deenergize the crane in the event of a control system malfunction.

'."ranrJin Research Center I'lVS~~O Cf 7ht ClCh~ 'flSMVIC

0 TER-C550 6-39 4 2.1.5 Soecial Liftina Devices

[Guideline 4, HUNG-0612, Section 5.1.1 4

"Special lifting devices should satisfy the guidelines of ANSI ¹4.6-1978,

'Standard for Special Lifting Devices for Shipping Containers Neighing 10,000 Pounds (4500 kg) or More for Nuclear Materials'6].

This standard should apply to all special lifting devices which carry heavy loads in areas as defined above.

For operating plants certain inspections and load tests may be accepted in lieu of certain material rec(uirements in the standard.

In addition, the stress design factor stated in Section 3.2.1.1 of ANSI N14.6 should be based on the combined maximum static and dynamic loads that could be imparted. on the handling device based on characteristics of the crane which will be used.

This is in lieu of the guideline in Section 3.2.1.1 of ANSI N14.6 which bases the stress design factor on only the weight (static -load) of the load and of the intervening components of the special handling device."

a.

Summar of Licensee Statements and Conclusions The Licensee is presently conducting discussions with the special lifting device supplier to determine compliance with ANSI N14.6-1978.

b.

Evaluation The Licensee has provided no information to enable an independent evaluation of the special lifting devices used at St. Lucie Unit 1.

As a minimum, the Licensee should evaluate special lifting devices and verify that the following items concerning design, fabrication, and testing have been satisfied:

1.

The stress design factor for all special lifting devices co.plies with that identified in this guideline.

2.

Design of special lifting devices complies with those paragraphs of Section 3 (Design) of ANSI N14.6-1978 which are relevant to prevention of a load drop, specifically Sections 3.1 (Designer's Responsibilities),

3.2 (Design Criteria), and 3.3 (Design Considerations) 3.

Fabrication was performed in accordance with Section 4 (Fabrication) of ANSI N14.6-1978.

4Property "ANSI code" (as page type) with input value "ANSI N14.6-1978.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. ~

Testing, maintenance, and inspections are performed in accordance with Section 5 (Acceptance Testing, Maintenance, and Assurance o

Continued Compliance) of ANSI N14.6-1978.

I"FranrJin Research Center Ams'f Tnt F<ensin Inss:ut>>

0 TER-C550 6-39 4 c.

Conclus ion Compliance with Guideline 4 cannot be determined-from the information provided by the Licensee.

2.1.6 Liftin Devices Not Soeciall Designed)

[Guideline 5, NUREG-06l2, Section 5.1.1(5

]

"Lifting devices that are not specially designed should be installed and used in accordance with the guidelines of ANSI B30.9-1971,.'Slings'7j.

However, in selecting;the proper sling, the load used should be the sum of the static and maximum dynamic load.

The rating identified on the sling should. be in terms of the 'static load'hich produces the maximum static and dynamic load.

Nhere this restricts slings to use on only certain cranes, the slings should be clearly marked as to the cranes with which they may be used."

a.

Surraar of Licensee Statements and Conclusions The Licensee has stated that the program for sling use and maintenance at St. Lucie Unit 1 meets the requirements of ANSI B30.9.

Purther, the rated capacities are marked on each sling.

Since crane hoisting speeds at St. Lucie Unit 1 are relatively slow (main hoists less than 8 fpm; auxiliary hoists

,less than 30 fpm), any contribution from a dynamic effect would not be significant and sling ratings do not consider dynamic loading.

b.

Evalua tion Tne use, maintenance, and marking of slings at St. Lucie Unit 1 are consistent with the guidance of Section 5.1.1(5) of NUR=-G-0612.

c.

Conclusion 1

St. Lucie Unit 1 complies with Guideline 5 of NUREG-0612.

2. 1.7 Cranes Inspection, Testin, and Maintenance)

[Guiheline 6, NUREG-0612, Section 5.1.1(6) )

e crane should be inspected,

tested, and maintained in accordance with Chapt,er 2-2 of ANSI B30.2-1975,

'Overhead and Gantry Cranes, 'ith the exception that tests and inspections should be performed prior to use Franc'-'.n Research Center

> Des - 8 The Fr@1i4nlnsteute

0 TER-C550 6-39 4 where it is not practical to meet the frequencies of ANSI B30.2 for periodic-inspection and test, or where frequency of crane'use is less

&an the specified inspection and test frequency (e.g.,

the polar crane inside a

PWR containment may only be used every 12 to 18 months during refueling operations, and is generally not accessible during power operation.

ANSI B30.2, however, calls for certain inspections to be performed daily or monthly.

For such cranes having limited usage, the inspections,

test, and maintenance should be performed prior to their use)."

a.

Summa of Licensee Statements and Conclusions J

I The Licensee has stated that the crane inspection, testing, and main-tenance.program at St. Lucie Unit 1 complies with the requirements of ANSI B30.2-1976 with the exception that tests and inspections are performed prior to use where it is not practical to meet the frequencies of ANSI B30.2 for periodic inspection and testing, or where the frequency of crane use is less than the specified inspection and test frequency.

b.

Evalua tion St. Lucie Unit 1 satisfies the criteria of this guideline based on the Licensee's verification that existing programs comply with Section 5.1.1(6) of

.NUREG-0 612 ~

c.

Conclusion St. Lucie Unit 1 complies with Guideline 6 of NUREG-0612.

2.1.8 Crane Desi n [Guideline 7, NURSE-0612, Section 5.1.1 7

"The crane should be designed to meet, the applicable criteria and guidelines of Chapter 2-1 of ANSI B30.2>>1976<

'Overhead and Gantry Cranes, 'nd of CMAA-70< 'Specifications for Electric Overhead Traveling Cranes'8].

An alternative to a specification in ANSI B30.2 or CKA-70 may be accepted in lieu of specific compliance if the intent of the specification is satisfied."

.0 Fren'.iin Reseerch Center A~~,S w5 C eilC FICAk,ihlnSOtVtt TER&550 6-39 4 a.

Surfer of Licensee Statements and Conclusions The Licensee has evaluated handling systems in use at St. Lucie Unit 1 and identified the following systems which fall within the scope of the CMAA-70 specification and the ANSI B30.2-1976 standard:

o reactor building polar crane o

fuel cask crane o

intake structure crane.

The Licensee states thrat these cranes were designed to EOCZ-61, "Speci-fications for E1ectric Overhead Traveling Cranes,"

and ANSI B30.2-1967, which were the predecessors to CMAA-70 and ANSI B30.2-1976, respectively, and in effect at the time of manufacture.

Specifications in the earlier standards are ecruivalent to those now in effect.

The Licensee also states that the primary differences between the ECCI-61 and CMAA-70 specifications are in advancement in girder design practice and higher allowable stresses in CMAA-70.

Although the St. Lucie Unit 1 cranes are designed to EOCI-61, which specifies ASTM-A7 steel, the higher grade ASTM-A36 steel has been used, which is in.conformance with CMAA-70 retirements.

Further, although the new telescoping jib crane inside containment does not fall within the scope of CMAA-70, the design was specified to conform to CMAA-70 CMAA-74, and ANSI B30.2, as applicable.

b.

Evaluation Overhead cranes at St. Lucie Unit 1 substantially comply with Section 5.1.1(7) of NUREG-0612 on the basis of design to ECCI-61 and the design data provioed by the Licensee.

The Licensee is still evaluating crane design in the following areas:

l.

longitudinal stiffeners 2.

allowable compressive stress (reactor polar crane only) 3.

d um design 4.

hoist brake design 5.

bumper and stop design 6.

static control system design.

Fran'rJin Research Center A Drv.'s.c". c( The Fee c~.'.n h.s'.tu:e

~

~

TERM5506-394

Further, the Licensee has not provided sufficient information to eva]uate hoist rope requirements per CMAA-70, Article 4.2.1.

c.

Conclusion Compliance with Guideline 6 cannot be determined from the information provided by the" Licensee.

Further information is required to complete the inoependent evaluation of crane design.

2.2 XNTERXM PROTECTXON MEASURES The NRC has established six interim protection measures to be implemented at operating nuclear power plants to provide reasonable assurance that no II heavy loads will be handled over the spent fuel pool and that measures exist to reduce the potential for accidental load drops to impact on fuel in the core or spent fuel pool.

Four of the six interim measures of the report "consist of general 'Guideline 1, Safe Load Paths; Guideline 2< Load Handling Procedures; Guideline 3< Crane Operator Training; and Guideline 6< Cranes (Xnspecti<>n, Testing, and Maintenance).

The two remaining interim measures cover the following criteria:

1.

heavy load technical specifications 2.

special review for heavy loads handled over the core.

Licensee implementation and evaluation of'these two interim protection measures are contained in the succeeding paragraphs of this section.

2.2.1 Technical Srecifications

[Xnterim Protection Measure 1, NUREG-0612, Section 5.3 1 j "Licenses foi, all operating reactors not having a single-failure-proof overhead crane in the fuel storage pool area should be revised to include a specification comparable to Standard Technical Specification 3.9.7,

'Crane Travel - Spent Fuel Storage Pool Building,'or PWR's and Standard Technical Specification 3.9.6.2,

'Crane Travel,'or 'BWR's, to prohibit handling of heavy loads ov'er fuel in the storage pool until implemen-tation of measures which satisfy the guidelines of Section 5.1.

'ranMin Research Center h &vs.on of The Fcen4n Insure 0

TERM550 6-39 4 a.

Suer of Licensee Statements and Conclusions The Licensee has stated that St; Lucie Unit 1 Technical Specification

3. 9.7 prohibits t"avel of loads in excess of 2000 lb over irradiated fuel a ssemb 1ies in the storage pool.

b.

=valuation and Conclusion St. Lucie Unit 1 complies with Interim Protection Measure l.

2.2.2 Administrative Controls [Interim Protection Measures 2

3 4

and 5

NUREG-0 612, Section 5. 3 2)-5 ~ 3 5 ]

"Procedural or administr ative measures

[including safe load paths, load handling procedures, crane operator training, and crane inspection]

~ ~.

can be accomplished in a short time period and need not be delayed for completion of evaluations and modifications to satisfy the guidelines of Section 5. 1 of fNUREG-0 612]."

a.

Summary of Licensee Statements and Conclusions Summaries of Licensee statements and conclusions are contained 'n discussions of the respective general guidelines in Sections 2 ~ 1.2, 2 ~ 1.3, 2.1 ~ 4, and 2.1.7.

b.

Evaluations, Conclusions, and Recommendations aluations, conclusions, and recommendations are contained in discussions of the respective general guidelines in Sections 2 ~ 1 ~ 2, 2 ~ 1.3, 2.1.4, and 2.1.7.

2. 2.3 Special Review for Hea Loads Handled over the Core (Interim Protection Measure 6,

NUREG-0 612, Section 5 ~ 3. 6 ]

"Special attention should be given to procedures, equipment, and personnel for the handling of heavy loads over the cdre, such as vessel internals or vessel inspection tools.

This special review.should include the following for these loads:

(1) review of p ocedures for instal lation of rigging or 1ifting devices and movement of the load to assure that sufficient detail is prov'ed and that ins tructions are clear and concise; (2) visual inspections of load bearing components of cranes, rani Jin Research Cen!er A ~s.c;w c' Freeman bc'u'e

0 TERM550 6-39 4

slings, and special lifting devices to identify flaws or deficiencies that could lead to ailure of the component; (3) appropriate repair and replacement of defective components; and (4) verify that the crane operators have been properly trained and are familiar with specific procedures used in handling these loads, e.g.,

hand signals, conduct of operations, and content of procedures."

a.

Summar of Licensee Statements and Conclusions The Licensee has.stated that a review of heavy load handling over the core included all of the items in Interim Protection Measure 6.

~ As a result of this review, some revisions to specific load handling procedures were made and have been implemented.

b.

Evaluation and Conclusion St. Lucie Unit 1 complies with Interim Protection Measure 6.

ranMin Research Center A

~s.on o! Tre Fun~sn Ins'u'.e

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TER-C550 6-39 4 3 ~

CON"LUSION This summary is provided to consolidate the results of the evaluation contained in Section 2 concerning individual NRC staff guidelines into an overall evaluation of heavy load handling at St. Lucie Unit l.

Overall conclusions and recommended Licensee actions, where appropriate, are provided with respect to both general provisions for load handling (NUREG-0612, Section 5.1.1) and completion 'of the staff recommendations for interim protection (NUREG-0612, Section 5.3).

3 1 GENERAL PRVTESIONS FOR LOAD HANDLING The NR: staff has established seven guidelines concerning provisions for handling heavy loads in the area of the reactor vessel, near stored spent fuel, or in other areas where an accidental load drop could damage equipment required for safe shutdown or decay heat removal.

The intent of these guidelines is twofold.

A plant conforming to these guidelines will have developed and implemented, through procedures and operator training, safe load travel paths such that, 'to the maximum extent practical, heavy loads are not carried over or near irradiated fuel or safe shutdown equipment.

A plant conforming to these guidelines will also have provided sufficient operator training, handling system design,'load handling instructions, and equipment inspection to ensure reliable operation of the handling system.

As detailed in Section 2, it has been found that load handling operations at St. Lucie Unit 1 can be expected to be conducted in a highly reliable manner consistent with the staff 's objectives as expressed in these guidelines.

A need for further Licensee action,

however, was identified in the following areas:

o FpaL should reevaluate the turbine building gantry crane for compliance with general guidelines of NUREG-0612.

o To comply with the criteria for safe load paths, (PGL should develop load paths for major heavy loads handled inside of containment and provide suitable visual aids to assist the crane operator in identifying safe.load paths and exclusion areas.

>s " Frzn'rJin Resezreh Center h Wsicn c(The Frana!n Inscsute

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T~M550 6-3&4 o

Regarding crane operator

conduct, FPGL should ensure that (1) crane motion controls are tested prior to initial load movements on each shift and (2) specific criteria should be. established for aeferring upper limit switch testing and should include consideration of operato response time necessary to deenergize the crane in the event of a control system malfunction.

o rPGL should complete their evaluation of special lifting aevices to determine compliance with the design criteria and testing programs of ANSI N14. 6-197 8.

o FPaL should complete the design review of cranes subject to compliance with NUREG-0.612.

3 ~ 2 INTERIM PROTECTION The NEC staff has established certain measures (NUREG-0612, Section 5.3) that should be initiated to provide reasonable assurance that handling of heavy loads will be performed in a safe manner until final implementation of the general guidelines of NUREG-0612, Section 5.1 is complete.

Specified measures include:

the implementation of a technical specification to prohibit the handling of heavy loads over fuel in the storage pool; compliance with Guidelines 1, 2, 3, and 6 of NUREG-0612, Section 5.1.1; a review of load handling procedures and operator training; and a visual inspection program, including component repair or replacement as necessary of cranes,

slings, and J

special lifting devices to eliminate deficiencies that could lead to component failure.

The evaluation of information provide'd by the Licensee indicates that St. Lucie Unit 1 complies with the staff 's measures for interim protection.

P

.'.. Freni'Jin Reseerch Center 4 ~~sr~ c!

ne Fscnc;w!ns"..~te

0 TER-C550 6-39 4 4.

REFERENCES l.

"Con""ol of Heavy Loads at Nuclear Power Plants" N~, July 1980 hOREG& 612 2.

V. Stello, Jr.

(NRC)

Letter to all Licensees

Subject:

Request for Additional Information on Control of Heavy Loads Near Spent Fuel-NRCg May 17'978 1

3 NRC Le.tter to FP&L

Subject:

Request for Review of Heavy Load Handling at St. Lucie Unit 3.

December 22, 1980 4 ~

R E. Uhrig (FP &L)

Letter to D. G. Eisenhut (NRC)

Subject:

Interim Actions for Control of Heavy Loads July 2, 3981 R. E. Uhrig (FP&L)

Letter to D. G. Eisenhut (NRC)

Subject:

Control of Heavy Loads September 30, 3981'.

R. E. Uhrig (FP&L)

Letter to R. A. Clar k (NRC)

Subject:

Control of Heavy Loads (TER)

July 28, 1982 7 ~

ANSI B30.2-1976 "Overhead and Gantry Cranes" 8.

ANSI N14.6-1978 "Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More for Nuclear Materials" 9.

ANSI B30.9-1971 "Slings" 10 ~

Cr~&A-70 1

"Specifications for Electric Overhead Traveling Cranes" r.ran~'

Research Center As.'~s.=- ~! The Ftan"..h lnsÃvte

~.

INFORMAL TECHNICAL COMMUNICATION Da te To'

~

From:

U. S.. Nuclear Regulatory Commission Wa hington, D. C.

20555 Franklin Research Center Philadelphia, PA 19103

('IQ BE OPENED BY ADDRESSEE ONLY)

Reference:

NRC Contract NRC-03-81-130 NRC TA No Plant FRC Project C5506 FRC Generic Topic FRC Task(s)

Titie:

Attachment:

Message:

Copy of message form only:

M. Carrington NOTE TO SENDER:

Include attachments if information is pertinent to program management.

pnc Distribution:

spc, sp,+4f, f/5, Revised 4/4/83 I

ill 5J FranlJIn Research Center ADrs~~ er The Fred n hintbsic

a~

I ENCLOSURE 2

SYNOPSIS OF ISSUES ASSOCIATED WITH NUREG 0612 The following information is provided to identify exceptions or interpretations related to verbatim compliance with NUREG 0612 Guidelines that have occurred during the course of this review. For each of the major Guidelines specific exceptions are identified, a discussion concerning the underlying objective of that Guideline is provided, and approaches felt to be consistent and inconsistent with that guideline are identified. While each such exception has been handled on a case by case basis, and has been considered in light of overall compliance with NUREG 0612 at a particular plant, the topics are of a nature general enough to be of interest to other plants.

GUIDELINE 1 SAFEMADPATHS Exce tion 1 In the opinion of the licensee, development of individual load paths is impractical since there are a significant number of loads for which the pickup and laydown areas vary from outage to outage.

Further, in some cases the Jocation of safety related equipment combined with the design of the floor over which heavy loads are carried indicates that for a number of lifts there is no preferred load path.

Discussion The purpose of this portion of Guideline 1 is to ensure that the paths over which heavy loads are carried have been developed and approved in advance of the liftand are based on considerations of safety. In particular it is provided to avoid the ad hoc selection of load paths by maintenance personnel since such a situation could result in the use of a load path which has been established by a process wherein considerations other than safety have taken precedence.

It is recognized that there are a cJass of loads which, although in excess of the weight specified for classification as a heavy load, are actually miscellan-eous or maintenance related loads for which it is impractical to identify a specific laydown area which can be fixed from outage to outage.

Conversely there are a number of loads for which specific Jaydown areas have been allocated in the original plant design and which should reasonably be expected to be carried over the same load paths during every outage.

A tabulation of loads in this latter category, generally applicable to P WR's and BWR's, was provided in NUREG 0612 as Table 3-1.

A fundamental principal of NUREG 0612 is protection through defense in depth. Specifically, the first line of protection from an acci4ent which,could result in damage to spent fuel or equipment required for safe shutdown or decay heat removal

's to avoid or minimize the exposure of such equipment to crane borne loads overhead.

Where such exposure is minimized, rather than avoided, a second line of defense can then be provided by intervening barriers such as floors or the provision of ad4itional liftingdevice redundancy or safety factors.

Considering the foregoing, the use of exclusion areas, rather than safe loa4 paths, is consistent with this guideline only under circumstances where there is no safety related equipment located beneath the area accessible to the crane hook but outside of the exclusion area.

This situation has been found in buildings such as the turbine hall or screen house where safety related equipment is concentrated in a specific area within the crane path. It is unlikely to occur within containment due to the numerous safety related piping and electrical systems provided to support decay heat removal.

A roaches Consistent With This Gui4eline Specific safe load paths are prepared and approved for major components for which hazardous areas are well established.

For miscellaneous lifts load corridors are established such that any movement within that corridor cannot result in carrying a heavy Joad over spent fuel or systems required for safe shutdown or decay heat removal (regardless of intervening floors). Movement within these corridors is at the discretion of the load handling party.

Specific safe load paths are prepared and approved for major components for which hazardous areas are well established.

For miscellaneous lifts detailed direct-ions are prepared and approved for developing safe load paths which include floor plans showing the location of safety related equipment and instructions to avoid such equipment.

Specific safe load paths are then prepared each time a miscellaneous liftqualifying as a heavy load is made.

These individual load paths are temporary an4 may change from outage to outage.

~ ~

~

. A roaches I sistent %'ith this Guideline.

Use of ited exclusion areas in containme~hich merely prohibited

'he carrying of heavy loads directly over the core or specific components and allow full load handling party discretion in other areas.

F~i In the opinion of the licensee marking of load paths on the floor is impractical. This may be caused by the general use of temporary floor coverings which woul4 cover the load path markings, or, due to the number of loa4s involved, a requirement for multiple markings which could confuse the crane operator.

Discussion The purpose of this feature of Guideline I is to provide visual aids to assist the operator and supervisor in ensuring that designated safe load paths are actually followed. In the case of the operator it has the additional function of avoiding undesirable distractions while handling suspended loads (e.g., trying to read procedural steps or drawings while controlling the crane).

This feature should also be seen as a provision necessary to complete a plan for the implementation of safe load paths.

Specifically it provides'ome additional assurance that, having spent the time and effort to develop safe load paths, those paths willbe followed.

A roaches Consistent With this Guideline Rather than mark load paths a second member of the load handling party (that is, other than the crane operator) is made responsible for assuring that the designate4 safe load path is followed. This second person, a signalman is typically use4 on cab operated cranes, checks out the safe load path prior'to the liftto ensure that it is dear, refers to the safe load path guidance during the liftand provides direct-ion to the operator and that the load path is followed. To support this approach the duties and responsibilities of each member of the load handling party should be clearly defined.

Prior to a liftthe appropriate load path is temporarily marked (rope, pylons, etc.) to provide a visual reference for the crane operator.

In cases where the load path cannot be marked (e.g., transfer of the upper internals in a PWR) temporary

, or permanent match marks can be employed to assist in positioning the bridge and/or

,trolley during the lift.

In either case reasonable engineering judgement would indicate

'that in certain specific lifts marking of safe load paths is unnecessary due to physical constraints on the load handling operation (e.g., simple hoists, monorails, or very short lifts where movement is limited to one coordinate axis in addition to the vertical).

A roaches Inconsistent W'ith this Guideline Positions which in effect do not recognize the need for realistically providing visual aids to the crane operator and imply that, for all lifts, the operator.

willremember the load path from review of procedures or by reference to a drawing.

Exce tion 3 Obtaining written alternative procedures approved by the plant safety review committee for any deviations from a safe load path is considered too cumbersome to accommodate the handling of maintenance loads where lay4own areas may have to change or loa4 paths altered as a result of unanticipated maintenance requirements.

~

~

Discussion ~

The ~se of this portion of this guidelin to ensure that deviations from established safe load paths receive a level of review appropriate to their safety significance.

In general it is highly desirable that once safe load paths are established the'y are retained and kept clear of interference rather than routinely deviated from.

It is recognized, however, that issues associated with plant safety are the responsibility of an individual licensee plant safety review committee (or equivalent) and the details of their excercizing this responsibility should be within their jurisdiction.

A roach Consistent With this Guideline A plant safety review committee (or equivalent) delegates the respon-sibilityfor approving temporary changes to safe load paths to a person, who may or may not be a member of that committee, with appropriate training and education in the area of plant safety.

Such changes are reviewed by the safety review committee in the normal course of events.

Any permanent alteration to a safe load path is approved by the plant safety review committee.

A roach Inconsistent With this Guideline Activities which in effect allow decisions as to deviations from safe load paths to be made by persons not specifically designated by the plant safety review committee.

~

~

GUIDELINE 2 LOAD DLING PROCEDURES No significant exceptions to this guideHne have been encountered.

Occasionally a question arises concerning the need for individual procedures for each lift. In general, it a'as not the purpose of this guideline to require separate procedures for each lift. A reasonable approach is to provide separate procedures for each major lift(e.g., RV>ead, core internals, fuel cask) and use a general procedure for handling other heavy loads as long as load specific details (e.g., load paths, equipment requirements) are provided in an attachments or enclosures.

/

GUIDELINE 3.

CRAIOPERATOR TRAINING

~Exec tIen The only exception occassionally encountered with respect to this Guideline other than fairly minor, site unique, exceptions has been a desire to deviate from the requirement of ANSI B30.2-3.1.7.o for testing of all controls before beginning a new shift. In some cases a licensee has qualified a commitment in this area by I-.oting that only crane controls "necessary for crane operation" willbe tested at the start of a shift.

Discussion This requirement (ie. not a recommendation) of ANSI B30.2 is important since crane control system failures are relatively significant contributors to load handling incidents.

The only reason that can be seen for an exception in this area is a general aversion to the word "all". Specifically, it appears that some licensees fear that a commitment to this requirement willforce them to test all control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those features generally known as controls (ie. hoist, bridge, and trolley motion controllers).

A roaches Consistent With this Guideline Exceptions that clearly indicate that all normal controls (hoist, bridge, and trolley motion controllers) willbe tested at the start of each shift and that the purpose of not committing to "all"controls is to avoid a misunderstanding concerning other control devices.

A roaches Inconsistent With This Guideline A response that implies that a decision to test or not test a normal control willbe made by the crane operator on the basis of what type of liftor direction of motion he expects for the forthcoming shift.

GUIDELINE'0 SPE LIFTING DEVICES H~t Some licensees have indicated that their special liftingdevices were designed and procured prior to the publication of ANSI N10.6 and therefore are not designed in accordance with that standard.

This fact is sometimes combined with a reference to the title of thai standard to reach a conclusion that the standard is not applicable.

Discussion The purpose of this section is to ensure that special liftingdevices were designed and constructed under controlled conditions and that sufficient document-ation is available to establish existing design stress margins and support future mainten-ance and repair requirements.

ANSI N10.6 is an existing standard that provides require-ments supporting this goal for liftingdevice applications where the consequence of a failure could be similar to that which could be expected in the event of the failure of a special liftingdevice carrying a load within the jurisdiction of NUREG 0612.

Consequently it seems appropriate that for special liftingdevices subject to NUREG 0612 it should be able to be demonstrated that, from a design standpoint, they are as reliable as a device for which ANSI N10.6 was developed.

A roaches Consistent With This Guideline Although not originally specified to be designed in accordance with ANSI NI0.6 the special liftingdevice in question was provided by a reactor vendor, in accordance with appropriate quality assurance and quality control procedures, for a specific application associated with power plant components provided by that vendor.

Based on either the review of the original stress report or, ifsuch a stress report is unavailable, the preparation of a new stress report, the licensee has determined that margins to material yield and ultimate strength are comparable to those specified in ANSI N10.6. Although not required of the liftingdevice vendor, the licensee has reviewed the design of the liftingdevice and prepared a list of critical components whose repair or replacement should be performed under controlled conditions.

A roaches Inconsistent With This Guideline No information is available concerning the original design but it

'is probably allright because the device has been used for ten years and never failed.

The device was built before the publication of ANSI N10.6, does not carry shipping containers of nuclear material weighing more than 10,000 pounds, and thus need not comply with ANSI N10.6.

~Ei 2

No 150% overload test has been performed and, in the opiniori of the licensee, such a test is impractical.

Discussion The performance of a load test in excess of. the load subject to NUREG 0612 is an important contributor to the ability to asses" the overall reliability of a device.

Such a test supplements design reliability by demonstrating that the

,device was properly fabricated or assembled and that a portion of the design safety margin has been demonstrated.

Such proof of workmanship is particularly important for a fairly complicated device. It is recognized, however, that the specification of a 15096 overload test is somewhat arbitrary and that, in some cases, the nature of the device is such that the liklihood of workmanship shortcomings is remote.

o A

roaches sistent With This Guideline The licensee has evaluated the liftingdevice in question and has determined that design stress margins are substantial.

Further it has been established that the device itself is uncomplicated and principally put together with mechanical joints such that an assembly error is highly unlikely. The use of welded joints is severly limited and where employed were performed in accordance with substantial quality controls (eg AWS Dl.l)including NDE. The device has been tested to 10096 of rated load.

Although a 15096 overload test has not been performed the lifting device has been subjecte4 to a manufacturer recommended overload to demonstrate proof of workmanship (typically 120-12596).

A roaches Inconsistent With This Guideline See t is topic or xception 1 above.

~Ei 3

The requirement of ANSI N10.6 for an annual 15096 load test or full NDE is excessive.

Both the load test (due to the inability to make the test lift within containment) and the NDE (due to the need to remove protective coatings) are impractical and not justified by the infrequent use of these devices.

Discussion A continuing inspection program to assure the continued maintenance of safety margins incorporated in the original design of the device is important to demonstrate the reliabilityof special liftingdevices. It is recognized, however, that some devices employed in a nuclear power plant, particularly those associated with refueling, are use4 under conditions of control an4 at frequencies of use that are substant-ially less severe than that possible for the type of liftingdevice for which ANSI N10.6 was originally prepared.

Consequently a reasonable relaxation of the inspection interval seems appropriate.

A roaches Consistent With This Guideline Overload tests willbe con4ucted but at a longer interval, 5 years,

between tests to be consistent with the number of operational lifts required.

NDE of load bearing welds willbe. conducted at 5 year intervals or, alternatively, load bearing welds willbe examined through a program that ensures that all welds willbe examined over a normal inservice inspection interval of 10 years in a manner similar to that specified in the BRPY Code for Class 2 Component Supports.

A roach Inconsistent With This Guideline Continuing inspection will be limited to an annual visual examination of the device.

GUIDELINE 5 LIFTING

=ViCES NOT SPECIALLY DESIG

'Exce tion Licensees have taken exception to the requirement to select slings in accordance with the maximum working load tables of ANSI B30.9 considering the sum of static and dynamic loads.

Most commonly it is the licensees position that the approximate factor of safety of five on rope breaking strength inherent in these tables adequately accomodates dynamic loading.

Discussion The intent of this portion of this Guideline, which also applies to special liftingdevices un4er Guideline 0, is to reserve the ANSI B30.9 safety factors for accomodating sling wear and unanticipated overloads and avoid a reduction of this safety factor as a result of the routine dynamic loads inherent in hook/load accel-eration and deceleration.

While it is acknowledged that, for operating characteristics typical of cranes employed at nuclear power plants, these dynamic loads are unlikely to be substantial, such a determination cannot be ma4e generically. Typically the actual dynamic load dye to hook/loa4 acceleration or deceleration is a function of design hook speeds and the type of hoist control system employed. It should also be recalled that ANSI B30.9 is a general industrial standard which applies to all load handling devices and does not in itself provide for any additional conservatism in consid-eration of the potential consequences of a load handling accident at a nuclear power plant. Based on this, it is considered reasonable that individual licensees evaluate the potential contribution of dynamic loading in their operations and if such dynamic loading is indeed significant accomodate it in their procedures for sling selection.

A roach Consistent With This Guideline The licensee has evaluated the potential routine dynamic loading for liftingdevices not specially designed and found them to be a relatively small fraction (typically 5-1596) of static load. This estimate has been made on the basis of either calculated acceleration and deceleration rates or through use.of the industrial standard for impact loading of cranes specified in CMAA-70. In either case having verified that routine dynamic loading of a specific hoist is indee4 small the licensee has drawn the conclusion that revised selection criteria to accomodate such minor additional loads willnot have a substantial effect on overall load handling reliability.

A roach Inconsistent V/ith This Guideline Statement to the effect that dynamic loa4s are accomo4ated in the tables of ANSI B30.9 with no indication that the licensee has assessed the actual dynamic loading imposed on cranes subject to NUREG 0612.

GUIDELINE 6 CRANE PECTION TESTING AND MAINT NCE.

~ >

e

~Exce tice The only exception occasionally encountered with respect to this Guideline other than fairly minor and site-unique exceptions has been a desire to deviate from the requirement of ANSI B30.2-1.1.2.a.2 and 3.2.0 for testing of hoist limit devices before beginning a new shift. In some cases a licensee has qualified a commitment in this area by noting that this limitswitch willbe tested only ifoperations in the vicinityof the limitswitch are anticipated.

Discussion While this issue is treated somewhat ambigously in ANSI B30.2 (it is a recommendation in article 1.1.2 and a requirement in article 3.2.0) it is important since two-blocking incidents are relatively significant contributors to load han4ling incidents.

Further it should be noted that this test has been incorporated as a require-ment of OSHA in 29 CFR 1910.179.(n).(0).(i). It is recognized, however, that there may be circumstances where such a test is not prudent. First, such a test clearly should not be ma4e with the hook under load. Consequently if a shift change is made with the hook loaded (this, by the way, is not a desireable practice an4 could be preclud-ed through strict compliance with ANSI B30.2-3.2.3.j) a hoist limitswitch test should not be performed.

Second, there may be circumstances where the nature of forthcoming load handling operations indicates that the time (and minor risk) associated with this test is not justified. In particular ifit is known that a hoist willnot be used or used only in an area substantially removed from the upper travel limit,it would seem reason-able to defer the limitswitch test until the start of the next shift. If such an approach is taken, however, it should be approached with care.

Requirements for deferring an upper limitswitch test should accomo4ate the uncertainty associated with maintenance plans and establish unambiguous criteria concerning what operations can be determined to be remote from upper travel limits. Such criteria should recognize that the need for upper travel limitswitch. protection may be preceeded by a control system failure and consequently should conservatively allow for operater response time and potential delays associated with emergency shutdown of the crane.

A roach Consistent With This Guideline General compliance with this requirement.

Certain specific provisions made for deferring upper limitswitch testing under conditions that are not subject to operater interpretation.

A roaches Inconsistent With This Guideline An approach that implies that a decision to test or not is left to the discretion of the operator or implies that such a test willbe required only if operat-ions are planned in close proximity to the hook upper travel limit.

10

, '"'<UIDELINE7 CRANE~IGN

~Exec tion Occasionally a licensee has indicated that the overhea4 electric travening cranes employed at a site were purchased prior to the publication of CMAA-70 or ANSI 830.2-1976 and thus these stan4ards should not be applied.

Discussion The purpose of this Guideline is to ensure that all cranes carrying heavy loads in nuclear power plants meet certain minimum criteria in their design and, consequently, can be assumed to provide an acceptable standard of mechanical, electrical, and structural reliability. It is also recognized, however, that cranes in operating plants may have been designed an4 procured prior to the publication of current stan4ards and, thus, not strictly comply with some details of these standards.

In general, though, current standards have evolved from predecesor standards in existence at the time of crane procurement (EOCI 61, ANSI B30.2-1967) and, since the later standards are not revolutionary, it is likely that cranes at nuclear power plants will provide a degree of reliability equivalent to that provided by the current standards.

Such a general determination canot be ma4e, however, by the staff since nuclear power plant cranes are usually unique and provided with site specific design features.

It is up to the licensee then to make a systematic comparison of their crane design with the requirements of current stan4ards and determine ifad4itional design features are appropriate.

A roach Consistent With This Guideline The licensee has compared original crane procurement specifications or exi'sting crane designs with the requirements of-the referenced standards in areas effecting loa4 handling reliability. In instances where the current standard provides additional protection against the consequences of operater error or component failure the licensee has proposed modifications which willresult in a degree of load handling reliability similar to that provided in the current standard.

A roach Inconsistent With This Guideline Positions to the effect that the cranes satisfied standards in existence

a. the time of procurement and what was good enough then is good enough now.

0

&'4 Il t

e I