ML18065A719
| ML18065A719 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/13/1996 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-96-002, IEB-96-2, NUDOCS 9605200372 | |
| Download: ML18065A719 (8) | |
Text
Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 May 13, 1996 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 e*
DOCKET 50-255 - LICENSE DPR PALISADES PLANT RESPONSE TO NRC BULLETIN 96-02: MOVEMENT OF HEAVY LOADS OVER SPENT FUEL, OVER FUEL IN THE REACTOR CORE, OR OVER SAFETY RELATED EQUIPMENT On April 11, 1996, the NRC issued Bulletin 96-02, "Movement of Heavy Loads over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment." This bulletin requested the licensee to perform a review of their plans and capabilities to handle heavy loads while the reactor is at power in accordance with existing regulatory requirements. It further requests that if any planned activities are determined to be outside the plant licensing basis, then changes to the operating license and/or technical specifications are to be identified and subsequently processed for reviews and approvals. This submittal provides the requested 30 day response to NRC Bulletin 96-02.
- The control of heavy load movements at Palisades, when the reactor is at power, was reviewed to determine the compliance to licensing basis requirements. Based on that review, we have determined that no previous occurrence or future plan to handle heavy lo-ads *is inconsistent with the established licensing basis. The attachment to this letter:
contains specific responses to the NRC Bulletin 96-02 requested information.
9605200372 960513 PDR ADOCK 05000255 G
PDR A G¥.S 11/CRGY COMPANY
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
µ Ui::s.s:2-::t Richard W. Smedley-Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 2
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this response to NRC Bulletin 96-02, which required that Palisades review their plans and capabilities to move heavy loads over spent fuel, over fuel in the reactor core, or over safety related equipment when the reactor is at power, are truthful and complete.
By Richard W. Smedley Manager, Licensing Sworn and subscribed to before me this 13"' day of ~
1996.
Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires August 26, 1999
[SEAL]
ATTACHMENT CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 CONSUMERS POWER COMPANY'S RESPONSE TO NRC BULLETIN 96-02 MOVEMENT OF HEAVY LOADS OVER SPENT FUEL, OVER FUEL IN THE REACTOR CORE, OR OVER SAFETY-RELATED EQUIPMENT
NRG BULLETIN 96-02 MOVEMENT OF HEAVY LOADS OVER SPENT FUEL. OVER FUEL IN THE REACTOR CORE. OR OVER SAFETY-RELATED EQUIPMENT NRG Requested Action:
Pursuant to Section 182a, the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f), all addresses must submit the following written information:
(1)
For licensees planning to implement activities involving the handling of heavy loads over spent fuel, fuel in the reactor core, or safety-related equipment within the next two years from the date of this bulletin, provide the following:
A report, within 30 days of the date of this bulletin, 'that addresses the licensee's review if its plans and capabilities to handle heavy loads while
- the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) in accordance with existing guidelines. The report should also indicate whether the activities are within the licensing basis and should include, if necessary, a schedule for submission of a license amendment request. Additionally, the report should indicate whether cha*nges to Technical Specifications will be required.
Consumers Power Company Response:
The control and handling of heavy loads at Palisades, with the reactor at power, was reviewed to determine compliance with licensing basis requirements. Based on that review, we have determined that no previous occurrence or future plan to handle heavy loads would be inconsistent with established licensing basis.
The movement of heavy loads in the containment building area is restricted by Technical Specification 3.21.1 to periods when the Primary Coolant System temperature is below 225°F. There are no plans to change this restriction. However, there is a submittal under NRC review at this time that would remove the Heavy Loads Requirements from Palisades Technical Specifications and transfer the requirements to a Palisades administrative document.. Heavy Loads requirements do not meet the criteria of 10 CFR 50.36 and are not addressed in Standard Technical Specifications, NUREG 1432.
The movement of heavy loads in the Spent Fuel Pool Area is restricted by Technical Specification 3.21.2, which includes the following requirements:
- a.
Heavy loads shall not be moved over fuel stored in the main pool zone.
- b.
Heavy loads shall not be moved over areas of the main pool _zone which do not contain fuel unless the fuel stored in the main pool zone has decayed a minimum of 30 days when the charcoal filter is operating; or, the fuel stored in the main pool zone has decayed a minimum of 90 days when the charcoal filter is not operating.
2
- c.
Heavy loads shall not be moved over the north tilt pit zone unless the fuel stored in the north tilt pit zone has decayed a minimum of 22 days when the charcoal filter is operating; or, the fuel in the north tilt pit zone has decayed a minimum of 77 days when the charcoal filter is not operating.
- d.
Heavy Loads shall not be moved over the 649' level of the auxiliary building unless:
- 1.
The fuel storage building crane interlocks are operable or they are bypassed and the crane is in administrative control of a supervisor, and
- 2.
No fuel handling operations are in progress.
- e.
Loads weighing more than 25 tons shall not be moved over the main pool zone unless an evaluation in compliance with section 5.1 of NUREG-0612 has been completed.
- f.
Heavy loads shall not be moved unless the potential for a load drop is
- extremely small, as defined by Generic Letter 85-11, or an evaluation in compliance with section 5.1 of NUREG-0612 has been completed.
- g.
The Fuel Pool Building Crane shall not be used to move material past the fuel storage pool when its interlocks are inoperable.
The following heavy loads are moved in accordance with the existing licensing requirements over the main fuel pool zone that does not contain fuel:
- a.
Dry Fuel Storage (DFS) Transfer Cask
- b.
DFS Transfer Cask Lifting Rig
- c.
DFS Multi-Assembly Sealed Basket (MSB)
- d. -
MSB Shield Cover.
- e.
MSB Structural Cover
- f.
Ultrasonic Fuel Inspection Rig During the loading of dry fuel storage casks at Palisades, there are three heavy loads, the DFS Shield Cover, Structural Cover and MSBff ransfer Cask Lifting Rig, that must
be moved over the fuel that has been placed into the DFS MSB!Transfer Cask during transport activities. Based on several Palisades-NRG conversations in November of 1992, the fuel in the MSB was determined to not be subject to the requirements of Technical Specification 3.21.2. The rationale for this interpretation was agreed to at that time by the Palisades NRC Project Manager, NRC Legal Department, and the Senior Resident Inspector. The rationale included the following factors:
- a.
Technical Specification 3.21.2.a is applicable only to fuel stored in the main pool zone. Fuel in the MSB is not being stored in the main pool zone but is in transit.
3
- b.
As required by the Palisades Technical Specifications, fuel stored in the main pool zone is required to be stored in either Region I or Region II racks under conditions (minimum burn up and boron concentration levels) which do not apply to fuel in the MSB.
- c..
Fuel placed in the MSB is subject to the requirements of Attachment A to the Certificate of Compliance.
NRG BULLETIN 96-02 (2)
For licensees planning to perform activities involving the handling of heavy loads over the spent fuel,. fuel in the reactor core, or safety-related equipment while the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) and that involve a potential load drop accident that has not previously been evaluated in the FSAR, submit a license amendment request in advance (6-9 months) of the planned movement of the loads so as to afford the staff sufficient time to perform an appropriate review.
Consumers Power Company Response:
No heavy load movements over spent fuel, fuel in the reactor core, or safety related equipment while the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) are planned that have not been previously evaluated. The process of placing spent fuel into dry storage casks is.described in the FSAR. The heavy load activities associated with the cask loading process are not specifically
- addressed in the FSAR; however, the heavy load activities-have-been evaluated as part of the spent fuel loading process.
'.)'"
4 NRG BULLETIN 96-02 (3)
For licensees planning to move dry storage casks over spent fuel, fuel in the reactor core, or safety related equipment while the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) include in item 2 above, a statement of the capability of performing the actions necessary for safe
. shutdown in the presence of radiological source term that may result from a breach of the dry storage cask, damage to the fuel, and damage to safety related equipment as a result of a load drop inside the facility.
Consumers Power Company Response:
Reference the reply to item 2 above.
NRG BULLETIN 96-02 (4)
For licensees planning to perform activities involving the handling of heavy loads over spent fuel, fuel in the reactor core, or safety-related equipment while the reactor is at power (in all modes other than cold shutdown, refueling, and defueled), determine whether changes to Technical Specifications will be required in order to allow the handling of heavy loads (e.g., the dry storage canister shield plug) over fuel assemblies in the spent fuel pool and submit the
- appropriate information in advance (6-9 months) of the planned movement of the loads for NRG review and approval..
Consumers Power Company Response:
There are no plans to handle heavy loads over spent fuel, fuel in the reactor core, or safety related equipment while the reactor is at power which require changes to Technical Specifications. Refer to the reply to items 1 and 2 for identification of heavy loads that are moved over the main fuel pool zond areas which do not contain spent fuel and the three heavy loads that are moved over fuel that is in transit and contained in the MSB/Transfer Cask.