ML18046A783
| ML18046A783 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/06/1981 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0612, RTR-NUREG-612 GL-81-07, GL-81-7, NUDOCS 8107100247 | |
| Download: ML18046A783 (11) | |
Text
consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * (517).788-0550 July 6, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch.No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
CONTROL OF HEAVY LOADS (GENERIC LETTER 81-07)
NRC letters dated December 22, 1980 and February 3, 1981 requested Consumers Power Company review of the Palisades Plant controls associated with the handling of heavy loads.
These documents requested a determination of the extent to which the guidelines of Enclosure 1 (NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants") are presently satisfied at the Palisades Plant and the, identification of what changes and modifications would be required in order to fully satisfy these guidelines.
Specifically, they requested the implementation of interim actions provided by Enclosure 2 (Staff Position - Interim Actions for Control of Heavy Loads) and additional information identified by Enclosure 3 (Request for Additional Information on Control of lieavy Loads).
In addition:, they requested confirmation that implementation of those changes and modifications determined necessary to comply with the guidelines commence as soon as possible without waiting on staff review, so that all such changes, beyond the above interim action will be completed within two years of submittal of Section 2.3 of the above required report. If any changes or modifications that would be required to fully satisfy the guidelines of Enclosure 1 are considered not necessary, justification for such determinations was requested.
Consumers Power Company letter dated May 15, 1981 provided our confirmation that the intent of the five interim action items was presently being met at the Palisades Plant and that total implementation of these required actions will be achieved by the start of our 1981 refueling outage.
Until that time, Palisades will administratively control the use of all overhead handling systems to preclude.movement of "Heavy Loads", as defined in Section 1.2 of NUREG 0612, unless the interim actions for the particular case in question are met.
0107100247 010706 'I PDR ADOCK 0500025~ J
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Mr Dennis M Crutchfield, Chief Palisades Plant July 6' 1981 2
Attac.hment 1 of this submittal provides the results of our evaluation pursuant to Enclosure 3 Section 2.1.
Our evaluation to-date indicates that there is not a credible load path wherein safe shutdown equipment or decay heat removal equipment could be damaged as a result of a load drop.
As a result of the cask drop analysis dated July 1974, we have defined safe load paths to control the movement of heavy loads within the Fuel Pool Buildings.
The evaluation provided by Attachment 1 has not identified any changes to be necessary.
Consumers Power Company will identify any changes to plant structures, systems and components that result from a complete review and response to questions in Sections 2.2, 2.3 and 2.4 which will be provided on September 22, 1981.
Justification for excluding any changes or modifications required to fully satisfy the guidelines of Enclosure 1 will be provided on September 22, 1981.
Since a significant portion of the plant structures, systems and components are both directly and indirectly affected by the guidelines of NUREG-0612, Consumers Power Company will await completion of the integrated assessment of SEP modifications before making a final commitment to changes, modifications or implementation schedule.
David P Hoffman Nuclear Licensing Administrator CC Director, Region III, USNRC NRC Resident Inspector-Palisades
CONSUMERS POWER COMPANY Palisades Plant Response to NRC letters dated December 22, 1980 and February 3, 1981 Control of Heavy Loads (Generic Letter 81-07)
Docket No 50-255 License No DPR-20 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and.Regulations thereunder, Consumers Power Company submits our response to NRC letters dated December 22, 1980 and February 3, 1981 enti tle.d "Control of Heavy Loads (Generic Letter 81-07)".
Consumers Power Company's response is dated July 6, 1981.
CONSUMERS POWER COMPANY
~l)JµJ£tl R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 6th day of July 1981.
9f\\~I~sk~~
Jackson County, Michigan My commission expires December 14, 1983
2.1-1 Report the results of your review of plant arrangements to identify all overhead handling systems from which a load drop may result in damage to any system required for plant shutdown or decay heat removal (taking no credit for any interlocks, technical specifica-tions, operating procedures, or detailed structural. analysis).
RESPONSE
A review of the Palisades Plant arrangements has resulted in the identification of the Reactor Building Polar Crane, the Reactor Building Jib Crane and the Fuel Building Gantry Crane Main Hoist and Auxiliary Hoist and the Fuel Building Jib.Crane as the only permanent overhead load-handling systems capable of carrying loads which could, if dropped, damage systems required for plant shutdown or decay heat removal.
(1)
SAFE LOAD PATHS Because access to the 649'-0" level of the reactor building is not permitted during power operation, the Reactor Building Polar Crane and the Reactor Building Jib Crane are utilized only during plant shutdown conditions.
A review of plant arrangements in the Reactor Building has not identified that there is a credible load path wherein safe shutdown equipment or decay heat removal equipment could be damaged as a result of a load drop from either of the Reactor Building cranes.
The safe load path for heavy loads within the Reactor Building is defined as any area within the structure except for the space within a concentric cylinder 38 feet in diam-eter centered over the reactor vessel at the 649'-0" elevation and thence vertically upward to the top of the dome.
Specific procedures applicable to the load to be handled are written for each heavy load moved within the 38 foot cylinder.
In addition, heavy loads are restricted to a height of six inches during movement, except as required to clear obst.ructions.
As a result of the cask drop analysis dated July, 1974, Consumers Power Company has defined safe load paths to control the movement of heavy loads within the Fuel Pool Building.
(2)
PROCEDURES The movement of any object weighing more than 1,300 pounds within the Reactor Building and Fuel Pool Building is controlled by at least one detailed written procedure that as a minimum includes:
- a.
Identification of required equipment;
- b.
Inspections and acceptance criteria required before movement of the load;
- c.
The steps and proper sequence to be followed in handling the load.
- d.
Define the safe load path; and
- e.
Other special precautions or instructions.
2 2.1-1 (Contd)
Additionally~ certain heavy loads, such as the missle shield, reactor vessel head and others tYIJically handled during refueling, have specific procedures governing their handling.
Individual procedures are also prepared, if not already in existence, for the movement of any heavy load within 19 feet from the centerline of the reactor vessel.J (3)
CRANE OPERATORS The CP Co program for training and qualification of crane operators meets the intent of Chapter 2-3 of ANSI B30.2-1976, "Overhead and Gantry Cranes."
The CP Co program also meets the requirements of the Michigan Occupational* Safety.and Hazards Act (Chapter 18).
(4)
SPECIAL LIFTING DEVICES There are no special lifting devices utilized for transporting loads.
of 1,300 lbs or more and containing Nuclear Material at the Palisades Plant.
The fuel shipping cask, if used, would potentially involve a special lifting device or yoke.
Inasmuch as fuel shipments are not presently being undertaken at Palisades, this device is not in use.
Certain other special li~ing devices not used for transporting of Nuclear Materials, but are used for transporting loads weighing 1,300 lbs or more in the Reactor Building.
These. include the yoke and slings used in transporting the reactor vessel head and the missile shield.
(5)
LIFTING DEVICES -
NOT SPECIFICALLY DESIGNED
- Lifting devices (slings).are load rated and selected for. use in accor-dance with the load to be transported.
Slings are utilized at Palisades in accordance with the guidelines ANSI B30.9-1971, "Slings" and standard
'industry rigging guidelines.
(6)
CRANE INSPECTION, TESTING AND MAINTENANCE The cranes identified in Item (1) above are tested, inspected and main-tained in accordance with written *procedures that meet the intent of the guidelines provided in ANSI B30.2-1976.
In the event that it is impractical to meet.ANSI B30.2 periodic inspection and test recommenda-tions or where the frequency of use is less than the specified inspec-tion and frequency, the crane is appropriately inspec~d and tested by qualified individuals prior to use.
(7)
CRANE - DESIGN CRITERIA The Reactor Building Polar Crane and Reactor Building Gantry Crane were designed and manufactured by Dresser, Inc in accordance with the requirements of the Electric Overhead Crane Institute, Specification
- 61.
Consumers Power Company has reviewed the specification require-ments of this document with respect to the requirements of ANSI B30.2-1976 and CMAA-70 and believe that the Reactor Building Polar Crane and Fuel Building Gantry Crane designs meet the intent of the requirements of NUREG-0612.
2.1-2 Justify the exclusion of any overhead handling system from the above category by verifying that there is sufficient physical separation from i;my load-impact point and any safety-related component to permit a determination by inspection that no heavy load drop can result in damage to any system or component required for plant shutdown or decay heat removal.
RESPONSE
The Turbine Building Service Crane is considered to be an exception to the NUREG-0612 requirements for overhead handling systems because there is no equipment required for safe shutdown or decay heat removal within the load path of this crane.
The Reactor Building Jib Crane and Fuel Building Jib Crane are excluded because they are each limited to loads less than the 1,300 lb heavy load threshold limit and their respective load paths are restricted to prevent movement of loads over irradiated fuel or equipment required for safe shutdown or decay heat removal.
Also excluded from consideration are any and all small chainfalls and hoists not permanently located or affixed to plant structures.
In addition, these small lifting devices typically do not carry loads in excess of the heavy load criteria.
2.1-3 With respect to the design and operation of heavy-load-handling systems in the containment and the spent-fuel-pool area and those load-handling systems identified in 2.1-1, above, provide your evaluation concerning compliance with the guidelines of NUREG 0612, Section 5.1.1.
The following specific information should be included in your reply:
(a)
Drawings or sketches sufficient to clearly identify the loca-tion of safe load paths, spent fuel, and safety-related equipment.
(b)
A discussion of measures taken to ensure that load-handling. -
operations remain within safe load paths, including procedures, if any, for deviation from these paths.
(c)
A tabulation of heavy loads to be handled by each crane which includes the load identification, load weight, its designated lifting device, and verification that the handling of such load is governed by a written procedure containing, as a I1Un1mum, the information identified in NUREG 0612, Section 5.1.1(2).
(d)
Verification that lifting devices identified in 2.1.3-c, above, comply with the requirements of ANSI Nl4.6-1978, or ANSI B30.9-1971 as appropriate.
For lifting devices where these standards, as supplemented by NUREG 0612, Section 5.1.1(4) or 5.1.1(5), are not met, describe any proposed alternatives and demonstrate their equivalency in terms of load-handling reliability.
(e)
Verification that ANSI B30.2-1976, Chapter 2-2, has been invoked with respect to crane inspection., testing, and maintenance.
Where any exception is taken to this standard, sufficient infor-mation should be provided to demonstrate the equivalency of pro-posed alternatives.
( f)
Verification that crane design complies with the guidelines of CMAA Specification 70 and Chapter 2-1 of ANSI B30.2-1976, including the demonstration of equivalency of actual design requirements for instances where specific compliance with these standards is not provided.
(g)
Exceptions, if any, taken to ANSI B30.2-1976 with respect to operator training, qualification, and conduct.
RESPONSE
(a)
The attached drawings identify the location of safe load paths, spent fuel and plant equipment.
(b)
CP Co will utilize operator training and qualifications, crane maintenance and inspection procedures and administrative proce-dures and controls to ensure that load handling operations remain within safe load paths.
Refer to the discussion in response to Question 2.1-1 Item (2) regarding procedures.
( c.)
Refer to attached Table 2.1-*3 for load identification, load weight, the designated lifting device an:d verification that the handling of such loads is governed by written procedures.
2 2.1-3 (Contd)
(d)
The requirements of ANSI Nl4.6~1978 have been reviewed and there is not presently in use at Palisades a special lifting device for shipping containers weighing 10,000 lbs or more for nuclear material.
The requirements of ANSI B30.9-1971, "Slings" has been reviewed and the use of slings for handling of heavy loads at Palisades meets the intent of this standard.
Slings suitable for use only on certain cranes or with certain loads are appropriately marked and identified.
All slings are load rated for the maximum static load only and marked according to their rating.
The NUREG-0612, Section 5.1.1(5) requirement for load rating slings in accordance with the sum of both the static and maximum dynamic_ loads is under review.
We will provide the results of this review and appropriate commitments in the scheduled September 22, 1981 response to Enclosure 3, Questions 2.2, 2.3, and 2.4.
(e)
Crane inspection testing and maintenance is undertaken with written procedures that meet the intent of ANSI B30.2-1976 as discussed in the response provided to Question 2.1-1(6).
(f)
Consumers Power Company has reviewed the original design speci-
- fication for the Reactor Building Polar C~ane and Reactor Build-ing Gantry Crane arid believe their design meets the intent of ANSI B30.2-1976 and CMAA-70.
(g)
The Consumers Power Company program and procedures for operator training, qualification and conduct have'ibeen reviewed and are in compliance with and meet the intent of ANSI B30.2-1976.
TABLE2.l-3 TABULATION OF HEAVY LOADS Load Identification Incore Shipping Cask New Fuel Assembly Equipment Hatch-Shield Blocks Primary Coolant Pump Rotor Primary Coolant Pump Impeller Tilt Pit Gate Spent Fuel Rack Reactor Vessel Head Load Weight (Lbs)(l) 20,500 1,300 5,300 32,500 1,700 2,300 88,ooo' 100,000 (l)All weights are approximate.
( 2)Both RB Polar Crane and FP Gantry Crane
( 3) s
. f.
d l '
t th.
h l
d pec1 ic proce ure app ies o
is eavy oa Designated Lifting Device FP FP FP Both( 2 )
Both( 2 )
Gantry Crane :
Both( 2 )
Both( 2 )
Gant:r:y Crane Gantry Crane RB Polar Crane Procedure
( 3)
( 3)
( 3)
( 3)
( 3)
( 3)
( 3)
Remarks
LEGEND HEAVY LOAD AREA REACTOR BUILDING HEAVY LOAD AREA PALISADES PLANT
I HATCH
- Q r--,nn I
I I
I
- 0NTL_JOLJ L D
CJ CJ c
c LE<;END FUEL BUILDING HEAVY LOAD PATH PALISADES PLANT