ML17341B332

Forwards Addl Info Re Schedular Commitments for Items in Draft Technical Evaluation Rept on Control of Heavy Loads

ML17341B332
Person / Time
Site:	Turkey Point
Issue date:	08/10/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR L-82-346, NUDOCS 8208170102
Download: ML17341B332 (25)

Text

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REGULATOR NFORMATION DISTRIBUTION 'EM (RIDS)

AOCE'SSION NBR: 8208170102 DOC ~ DATE: 82/08/10 NOTARIZED: NO DOCKET ¹ FACIL:50-250 Turkey Point P1 anti Uni t 3i Florida Power and Light C 05000250 50-251 Tur key Point Planti Unit 4i Florida, 'Power and Light BYNAME C 05000251 AUTH AUTHOR AFFILIATION UHRIGiR ~ E, Florida Power 8 Li'ght Co, GREC IP ~ NAME RECIPIENT AFFILIATION VARGAiS~A~ Operating Reactors Branch 1

SUBJECT:

Forwards addi info r e schedular commi'tments fot i tems in dr aft technical evaluation rept on control of heavy loads, DISTRIBUTION CODE: A033S COPIES RECEIVED:LTR ENCL . SIZE:,

TITLE: Conrtol of Heavy Loads Near Spent Fuel (USI A-36) Operating Reactor NOTES:

RECIPIENT iCOPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTiTR ENCL ORB ¹1 BC 7 7 NRR 'CLEMENSON01 INTERNAL: NRR REQUAiG 09 1 1 NRR/DL/ORAB 12 1 1 NRR/DSI/ADCCS11 1 1 AEB 1 1 NRR/DS I/RAB 10 1 1 0$ 1 RGN2 1 1 EXTERNAL: ACRS 13 10 10 L'P DR 03 1 1 NRC PDR 02 1 1 NSIC 06 1 1 NTIS 1 1 TOTAL NU~BER OF COPIES REQUIRED: LTTR 32 ENCL 32

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FLORIDA POWER & LIGHT COMPANY August 10, 1982 L-82-346 Office of Huclear Reactor Regulation Attention: ffr. Steven A. Varga, Chief Operating Reactors Branch II1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Nr. Varga:

Re: Turkey Point Units 3 8 4 Docket Hos. 50-250 and 50-251 Control of Heavy Loads Draft Technical Evaluation Report We have reviewed the HRC letter dated flay 10, 1982, which requested our understandi ng of the resolution of the items in the Draft Technical Evaluation Report (TER) on Control of Heavy Loads.

The attachment to this letter provides additional information on schedular commitments for the items in the TER. Because the review work for lifting rigs and crane design is being done by contractors, we have provided our oest estimate for completion dates. We will notify you if these projectea completion dates change.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems and Technology REU/PLP/mbd Attachment o3~

cc: J.P. O'Reilly, Region II Harold F. Reis, Esquire 820810 I 208170102 05000250, PDR ADOCK PDR~

P PEOPLE... SERVING PEOPLE

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ATTACHMENT Re: Turkey Point Units 3 5, 4 Docket Nos. 50-250 and 50-251 Control of Heav Loads INTRODUCTION On December 22, 1980, the NRC issued a generic Tetter to Florida Power 8 Light Company requesting that FP8L review provisions for handling and control of heavy loads at Turkey, point, evaluate .these provisions with respect to the guidelines of NUREG-0612, and provide certain additional information to be used for a determination of conformance to these guidelines. On September 4, 1981, Florida Power 5 Light Company provided its response to this, request. On December 29, 1981, Franklin Research Center (FRC) as a consultant for the NRC issued a draft Technical Evaluation Report (draft TER) on the FPSL response. This draft TER and a subsequent .telephone conversation with the NRC and FRC indicated some areas where additional information would assist in their eval'uation of

,the FP8L response. The intent'f the following report is to clarify ana supplement the initial response by FPSL.

2.1 GENERAL GUIDELINES 2.1.2 Safe Load Paths Guideline 1, NUREG 0612, Article 5.1.1 1

a. FRC Conclusions and Recommendations Turkey'Point Units 3 and 4 partially comply with Guideline

1. In order to comply with this guideline, the Licensee should perform the following:-

1. Define safe load paths wher e practical. The use of exclusion areas shoul'd be limited to miscellaneous maintenance areas'nd lifts where the designation of individual load paths is impractical.

2. Verify that heavy loads and their safeload paths have been identified in the plant procedure for controlling heavy loads.

3. Verify that the selection of load paths considers the location of structural members and beams.

4. Verify that safe load paths have been clearly marked on floors or structures.

5. Verify that devi ations from load paths require written alternatives approved by the plant's safety review committee (or equivalent).

b. FPL Position The safe load path areas as defined in the initial response to the NRC generic letter have been revised in a subsequent response to HRC addressing the specific requirements of HUREG-0612. These .safe load path areas and restricted zones were developed by the FPL Power Plant Engineering Oepartment.

Copies of these safe load path drawings are attached. These drawings indicate certain areas where the handling of loads greater than 1760 pounds is restricted. In some areas the handling of loads greater than 5 tons is restricted. The bases for these restrictions 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.

Florida Power 5 Light Company does not concur that marking the safe load paths on the floors or structures is a practical or necessary means of informing the operator of the safe areas.

The sketches which are readily available to the operator at the hoist controls, are 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 (e.g. the refueling pool).

The- plant Maintenance Procedure 0736""Keavy Load Handling" requires written alternatives for deviations from the safe load paths. These alternatives are approved by the Haintenance Superintendent. The Plant Nuclear Safety Review Committee (PNSC) approved this procedure and has delegated this authority to the Maintenance Superintendent. The Maintenance Superintendent is a member of the PHSC and is responsible for all. maintenance activities at the nuclear power plant. It is our judgment that the individual filling this senior maintenance position can determine when a safe load path variation requi res full review by the. PHSC, and as a member of that group he would bring the situation to the attention of that group.'he NRC reviewer found this position acceptable during our phone conference.

2.1.3 Load Kandlin Procedure Guideline 2 NUREG-0612, Article 5.1.1 2

a. FRC Conclusions and Recommendations FPL partially complies with Guideline 2. The following is required for full compliance.

1. identify all loads which are or could be (i.e., without .

credit for interlocks, technical specifications, operating procedures or detailed structure analysis) carried in the vicinity of irradiated fuel or safe shutdown equipment.

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2. prepare procedures containing the information identified in Guideline 2 for those loads not identified in 2.1.3.a above {i.e., Reference 4, Table 2).

b. FPL Position Florida Power 8. Light Company's Power Plant Engineering Department has analyzed the potential consequences of load drops in the vi ci nity of i rradi ated fuel and safe shutdown equipment. The analysis:has enveloped all possible;,

configurations, sizes and weights of potential dropped loads. The safeload path areas and restricted zones have been developed as a result of this analysis and consider the capabilities of the structures beneath the load. The plant Maintenance Procedure 0736 "Heavy Load Handling" r equi res the operators to confine the loads within these areas. Compliance with this procedur e assures compliance with Gui'deli ne 2.

A complete listing of loads which could be carried in these areas is not pr act'ical. Almost every plant component within the reach of each crane would have to be listed. Since Engineering's analysis envelopes all loads such a listing is not necessary.

A li sti'ng of significant heavy loads which are periodically handled in the vicinity of i rradiated'uel has been prepared along with the procedures used for handling of these loads and is given in Table 2 of the FPL report (3).

2.1.4 Crane 0 erator Training Guideline 3 NOREG '0612, Article 5. 1.1 3

a. FRC Conclusions 8 Recommendations Conclusions and recommendations covering Guideline 3 must be deferred until a comprehensive response is received. The Licensee should ensure that the response addresses operator selection and conduct as well as training.

b. FPL Position The final response to NUREG-0612 Request for Information (4) was submitted, on November 12, 1981. This report states tnat:

"A training program in accordance with ANSI 830.2-1976 has been developed and our standard company physical for new employees meets or exceeds the physical requirements of the ANSI standard. Some minor exceptions to the ANSI standard have been taken and are listed in the attachment at the end of .this report. These training programs and procedures will be ava'i-lable at the site for review."

The exceptions. to ANSI B30.2-1976 are also listed at the end of this report.

2.1.5 Special Lifting Devices Guideline 4, NUREG-0612, Article 5.1.1 4 a ~ FRC Conclusions,and Recommendations Insufficient information has been provided to allow a determination of compliance with respect to Guideline 4. The Licensee should provide an evaluation concerning compliance with ANSI 14.6 for all special lifting devices (e.g., reactor vessel head and internal lifting rigs, fuel cask lifting device). Further, in performing their evaluation, the

'Licensee should address the imposition, of static and dynamic loads when assessing design stresses.

b. FPL Position We have contracted with our NSSS vendor to review the design of the reactor vessel internals and head lifting rigs, load cell, load cell linkage and reactor coolant pump motor lifting rig, to determine.the acceptability of these components to the criteria of ANSI 14.6 - 1978 as supplemented by NUREG 0612, section 5.11.4. We expect to receive .the results of these evaluations by the end of September 1982.

2.1.6 Liftin Devices Not S ecially Designed Guideline 5.f NUREG-0612, Artie e 5;1.1 5 a ~ FRC Conclusions & Recommendations FPL partially complies with Guideline 5. The Licensee.

selection and marking of slings should .be evaluate'd.

b. FPL Position The program for sling use and maintenance at Turkey point Units 3 and 4 meets the requirements of ANSI 830.9. The ANSI standard requires a 5:1 safety factor for sling strength based upon the breaking strength of the sling divided by the rated capacity.'ccording to the standard', the sling is selected based upon the weight of the load; i.e. the rated capacity

.should be greater than the actual load weight. There is no requirement for consideration of a "dynamic load factor" ana it is presumed that sufficient margin is present from the 5:1 safety factor.

FP8L does not feel that it is practical in tne field to account for a dynamic load factor or that such a factor is necessary. Presumably if such a factor was a real safety concern the universally accepted ANSI standard would require one. In any event, the hoisting speeds at Turkey Point are relatively slow and any contribution from a dynamic effect would not be significant. Also, any'ritical lifts {e.g.

reactor head lift, reactor missile shield, etc.,) are always done at very slow speeds.

Superimposing a dynamic load factor in addition to the 5:1 existing safety factor for the slings would not be consistent with other safety factors used in crane design. for example, the hoisting rope requires on a 5:1 safety factor with no dynamic contribution. (Crane Nanufacturers Association of America, Specification f70, Section 4.2).

The rated capacity is marked on the slings. These slings are inspected yearly by an outside contractor, and worn slings are replaced. New slings are tagged with their capacity. prior to receipt by FPL.

2.1.7 Cranes, Inspection, Testing and Maintenance Guideline 6, NUREG-0612, Article 5.1.1 6

a. FRC Conclusions and Recommendation FPL will comply with Guideline 6. Associated procedures

-should be readily available for NRC staff review when completed.

b. FPL Position The Turkey Point crane inspection, testi:ng and maintenance program complies with the requirements of ANSI 830.2-1976 with the exception that tests and inspections are performed prior to use where it is not practical to meet that frequencies of ANSI B30.2 for periodic inspetion and test, or where frequency of crane use is less than the specified inspection and test frequency (e.g. the polar crane i.s used every 12 to 18 months during refueling operations and is generally not accessible during,power operation).

2.1.8. Crane Desi n Guideline 7, .NUREG-0612, Article 5.1.1(7))

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a. FRC Conclusion Turkey Point Units 3 and 4 comply with Guideline 7, to a substantial degree, on the basis'f compliance with EOCI-61 criteria. However, insufficient, information has been made available to verify that the following CMAA-70 requirements have been satisfied for cranes subject to this review. The Licensee should make this information available or provide suitable justification for concluding that the requirements.of CHAA-70 have been satsisfied by equivalent means.

1. Hoist lifting speeds do not exceed 30 feet per minute;

2. Nonsymmetrical girder secti'ons were not, used in crane construction.

3. Any longitudinal stiffeners in use conform to the requirements of CtlAA-70, and allowable h/t rations in box girders using these stiffeners do not exceed ratios specifi ed in CMAA-70.

4~ Girders with b/c ratios in excess of 38 were not used.

Fatigue failure was considered in crane design and the number of design loading, cycles at or near rated load is less than 20,000 cycles.

6. 'Maximum crane load weight, plus the weight of the, bottom block, divided by the number of parts of rope does not exceed 205 of the manufacturer's published breaking strength.

7. Drum design calculations were based on the combination of crushing and bending loads.

8. Drum groove depth and pitch conform to the recommendations of CMAA-70.

Gear horsepower ratings were based on design allowables and calculation methodology equivalent to the incorporated in CMAA-70.

10. A cab-control, cab-on trolley configuration was not used.

Mechanical load brakes or hoist holding brakes with torque ratings of appr oximtely 125$ of the hoist motor torque were used..

12. Crane operation under load near the end of bridge or troll'ey travel is not allowed or is compensated for by bumpers and stops which satisfy the .intent of CMAA-70.

13. Any static control -systems in use conform to the requirements of CMAA-70.

14. Controllers in use are the spring-return or.momentary-contact pushbutton type or are equipped with a device which, disconnects all motors on power failure and will not permit restart until controller handle is brought to the OFF position.

b. FPL Position lie are reviewing the comments of the reviewers concerning crane design. We expect to provide a response to this item by the end of September, 1982.

~ 2.2 INTERIM PROTECTION MEASURES" 2.2. 1 Technical Specifications ( Interim Protection Measure 1 NUREG-0612, Artcc e 5.3 1

a. FRC Conclusions 8 Recommendations The Licensee made no statements or conclusions regarding this interim protection measure..

b. FPL Positi'on This interim measure was not included in the NRC letter dated December 22, 1980 {Control of Heavy Loads) 2.2.3 Special Reviews for Heavy Loads Over the Core Interim Protection Measure 6 NUR G-0612, Artcc e 5.3. 6

a. FRC Conclusions 8t Recommendations c%

Insufficient information has been provided for Turkey Point Units 3 and 4 to evaluate compliance with interim Protection Measure 6. The intent of this interim mesure was to provide, on the basis of a one-time detailed inspection, assurance of a high degree of load handling system reliability during the peri od when certain hardware-associated guidelines (Guidelines 4., 5, and 7) were being .evaluated. A general review of crane operations to establish procedure improvements may not meet the intent of tni s i nterim measur e. In oroer to allow a finding of compliance, the Licensee should provide sufficient information for FRC to verify that the extent of this review',

was comparable to that identified for this interim protection measur e.

b. There was no request for a written response to this Interim Action item in- the December 22, 1980 NRC letter. Me did however, provide a brief response saying that the requested review had been conducted and that operations over the core were addressed in the plant, maintenance procedure.

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

2. NRC Letter to all Licensees

Subject:

Contro'1 of Heavy Loads, December 22, 1980

3. R.E. Uhrig (FPL) letter to D.G. Eisenhut (NRC)

Subject:

Control of Heavy, Loads, Turkey Point Units 3 5 4 4~ R. E. Uhrig (FPL) letter to D.G. Ei senhut (NRC)

Subject:

Control of Heavy Loads {L-81-473), November 12, 1981 Draft Technical Evaluation Report Control of Heavy Loads, Turkey Point Units 3 5 4 FRC, December 29, 1981 ATTACHMENTS E

Safe Load Paths {as revised in final response) 24 Exceptions to ANSI 830.2-1976 for Crane Operator Training

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Attachment to PPL Letter

~ L-,81-.473< dated November 12, *1981 A 1:,TACill:iE.V r Re: Turkey l'oint Units No. 3 and No. 4 interim) Actions for Control of )leavy Loads Tlie IIRC letter date.l December 22, I980 (subj< "t: Control o. Heavy Loads) r!~quested im:,)':erne!!tation of interiim ac'ions fur tl',. trodi)ii>>g, quahification, arid conduct of crane operators. Florid~ Powe) 5 l.ight wii i):.pie;;; nt at 1

Turkey Point Unit ho.. 3 and 4), S<<cti<<n 2-3.1 (I;ual il'icatio>>s for and conduct of Operators) of Cha,)ter 2-3 of MSI Standard B 30.2-I)75 wi th the.al'lowing exceptions to the re-erenced paragraplis:

Paragraph 2-'3.1.2. he ilail 1'equire an eye t<<st of 2U/4U in both eyes for oew employees.

Paragraph 2-3.1.7.f, g and h. Because or tiie l)ower requireinents ot tlie crane motor li aters, we will meet the intent ot these .requireiments by using tiie crane dead mian switch instead ot the miain line disconnect devices.

Paragraph 2-3.'..7. He wi 11 test tliose controls necessary for the crane .

operations to bu conducted.

Paragraph 2-3. 1.7.n. Safety dur ing inaintenance work on cranes wi 1'1 be ln accordance witli tlie plant clearance proceduie.

The remainder of Chapter 2-3 o tlie ANSI Standard (i.e.: llandl ing the Load, Attaching the Load, Yioving the Load, 'rloist Limit 0 vicl., Signals, f~iscellaneous) w',l l be met in a gener 1 imanner in procedures or in crane operator tra Ill llg wi th tlie f o 1 1 1'owl ilg excl.",)' 0'1:

Paragrapli 2-3.2.4.a. At stiilt cliangu, we wi l l try out tiie upper limit device uiider no load unless a load is nanging tron the hook at shift change or Unless io era)le Oper tiuil 1n th.'rea of tile ul)Per l.imit is antici oated.

0 RFCElQED FLORIOA POWER & LIGHT COMPANY AUG 6 8@

!NTER-OFFICE CORRESPONDENCE Nuclear Licensing LOCATION Nuclear Energy TO R.E. Uhrig DATE AUG 5 i982 FROM J.W. Williams, Jr. COPIES TO R.J. Acosta D.W. Jones

SUBJECT:

TURKEY POINT UNITS 3 8 4 C.S. Kent CONTROL OF HEAVY LOADS H.N. Paduano/910.27 TP DRAFT TER H.E. Yaeger/J.K. Hays J.A. Yespica PNS-LI-S2-237 The subject information is attached for your review and forwarding to the NRC. The attachment was prepared in accordance with the requi rements of iiP 2. 13 for a submittal not ~re ui ri n an affidavit.

Except for the following, the attachment is fully responsive to the NRC requirements or differences are clearly noted in the attached: None The information- in the attachment, except for a few minor items, was provided by EPP.

J.W. Williams, Jr.

PLP/mbd Attachment PEOPLE... SERVING PEOPLE Form 1008 (Stoclsed) Rev.

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