ML19295F531
| ML19295F531 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/02/2019 |
| From: | Lochbaum D Union of Concerned Scientists |
| To: | Sujata Goetz NRC/NRR/DORL/LPL1 |
| References | |
| Download: ML19295F531 (32) | |
Text
NRR-DRMAPEm Resource From: David Lochbaum <davelochbaum@gmail.com>
Sent: Wednesday, October 2, 2019 8:52 AM To: Goetz, Sujata
Subject:
[External_Sender] Reactor building crane design rating - Fermi Unit 2 Attachments: 20191000-f2-lochbaum-crane-rating.pdf Follow Up Flag: Follow up Flag Status: Flagged
Dear Ms. Goetz:
Attached is a digital copy of a letter requesting that the NRC pinpoint the design and licensing basis for the reactor building crane at Fermi Unit 2.
As the letter explains, there are several documents, both originating from the licensee as well as from the NRC, that refer to a 125-ton rating. But the only documents I can find of a legal nature (i.e., 50.91, 50.59, NRC SER, etc.) establishing the rating date back to 1999 and 2001 where the licensee and NRC explicitly state the rating to be 117 tons. If the crane were subsequently legally re-rated to 125 tons, I was unable to find such documents in ADAMS despite many hours spent searching for them.
- Thanks, Dave Lochbaum 423-488-8318, mobile 1
Hearing Identifier: NRR_DRMA Email Number: 278 Mail Envelope Properties (CAKUfAtec=JpNccF6xZeogS_cf7xFGUsJYmhiFSk-=qDiZnBsUQ)
Subject:
[External_Sender] Reactor building crane design rating - Fermi Unit 2 Sent Date: 10/2/2019 8:52:20 AM Received Date: 10/2/2019 8:53:16 AM From: David Lochbaum Created By: davelochbaum@gmail.com Recipients:
"Goetz, Sujata" <Sujata.Goetz@nrc.gov>
Tracking Status: None Post Office: mail.gmail.com Files Size Date & Time MESSAGE 732 10/2/2019 8:53:16 AM 20191000-f2-lochbaum-crane-rating.pdf 2897862 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received: Follow up
October 2, 2019 Sujata Goetz Project Manager, Fermi Unit 2 U.S. Nuclear Regulatory Commission
SUBJECT:
Rating of Reactor Building Crane
Dear Ms. Goetz:
While reviewing documents about spent fuel cask transfers at Fermi Unit 2, I was unable to determine the design and licensing basis rating for the reactor building crane. As described in the attachment, the documents revealed both a 117-ton rating and a 125-ton rating. Recognizing that ratings can change, I searched ADAMS for either a 50.91 amendment or a 50.59 safety evaluation that explained how a 117-ton rating was upgraded to a 125-ton rating. I found neither explanation. Best I can tell from the documents found, the most recent NRC-approved rating is for 117 tons.
Hopefully, the reactor building crane is designed, tested, and maintained for the 125-ton HI-TRAC casks it will be handling and an NRC-approved process can be found to legally support that rating.
I respectfully request that the NRC establish the current licensing basis for the rating of the reactor building crane at Fermi Unit 2 and verify that all applicable testing, training, and maintenance procedures at Fermi are consistent with this basis. I also ask that the NRC make the documents that define the cranes licensing basis be made publicly available, if they are not already so.
Please note that I am not alleging that crane lacks the required rating pedigree, unless activating the NRCs allegations process is the most suitable means for the NRC to resolve this matter. Likewise, I am not petitioning under 10 CFR 2.206 for enforcement action against this licensee.
Sincerely, David Lochbaum 423-488-8318, mobile davelochbaum@gmail.com
Reviewed Safety Question The NRC-approved design and licensing basis for the rating of the reactor building crane used to move spent fuel casks at Fermi Unit 2 is:
A. 117 tons B. 125 tons C. Clearly confusing October 2019
The evidence in the case supporting the approved design and licensing basis rating of the Fermi Unit 2 reactor building crane being 117 tons (or, Answer A is the right answer to the non-rhetorical question posed.)
On November 19, 1999, Fermi-2s owner submitted a license amendment request to the NRC.
Source: ML993440109 to the submittal to the NRC was a non-proprietary version of a licensing report supporting the installation of new racks in the spent fuel pool at Fermi Unit 2.
Source ML993440246
Section 10.2 of this non-proprietary licensing report explicitly stated that the new racks would be installed using the 117-ton single failure-proof cask handling crane (defined elsewhere in the report as being the reactor building crane.)
Source ML993440246
On January 25, 2001, the NRC issued an amendment approving the installation of the new spent fuel racks.
Source ML010310205
Section 3.6.2.1 of the safety evaluation prepared by the NRC to support its approval explicitly stated that the 117-ton single-failure proof cask handling crane (defined as being the reactor building overhead crane, RBOC) will be used to install the new racks.
Source ML010310205
Thus, the owner and the NRC seem to agree - at least in the 1999-2001 time-frame - that the reactor building crane at Fermi Unit 2 has a 117-ton rating.
The evidence in the case supporting the approved design and licensing basis rating of the Fermi Unit 2 reactor building crane being 125 tons (or, Answer B is the right answer to the non-rhetorical question posed.)
On November 15, 2000, (between the owners license amendment request and the NRCs approval) the owner submitted Revision 10 to the Fermi Unit 2 Updated Final Safety Analysis Report (UFSAR) to the NRC.
Source ML003772047
§50.34 of Title 10 to the Code of Federal Regulations requires owners to submit UFSARs to the NRC. UFSARs describe the plants design and the safety studies explaining how the design and operation will conform to all applicable safety requirements.
§50.71 requires owners to periodically update the UFSARs and provide the NRC with the latest revision.
UFSAR pages 9.1-29 to 9.1.31 described the reactor building crane and explicitly stated it as having a 125-ton design rating.
The Fermi Unit 2 UFSAR was updated in October 2017 to Revision 21.
UFSAR page 9.1-29 describes the reactor building crane and explicitly stated it to have a 125-ton design rating.
In July 2016, the NRC issued its Safety Evaluation Report supporting its approval of the License Renewal Application (LRA) for Fermi Unit 2.
Section 4.7.7.1 addressed the reactor building crane, explicitly stated to have a 125 ton capacity.
Thus, the owner and the NRC seem to agree - at least in the 2000, 2016 and 2017 time-frames - that the reactor building crane at Fermi Unit 2 has a 125-ton rating.
The evidence in the case supporting the approved design and licensing basis rating of the Fermi Unit 2 reactor building crane being clearly confusing (or, Answer C is the right answer to the non-rhetorical question posed.)
11-19-1999 Owner informed NRC in writing about a 117-ton crane.
11-15-2000 Owner provided NRC with UFSAR Rev. 10 specifying a 125-ton rated crane.
01-25-2001 NRC issued amendment based on using a 117-ton crane 07-2016 NRC issued license renewal Safety Evaluation Report, including a 125-ton crane
Thus, the owner and the NRC seem to agree that the reactor building crane at Fermi Unit 2 has a 117-ton, or a 125-ton rating - somewhere in that ballpark
The NRC-approved design and licensing basis for the rating of the reactor building crane used to move spent fuel casks at Fermi Unit 2 is:
A. 117 tons B. 125 tons C. Clearly confusing
In November 1999, the owner told the NRC that it wanted to use a 117-ton crane to install new storage racks in the spent fuel pool.
In November 2000, the owner submitted a UFSAR revision to the NRC that stated the crane had a design rating of 125-tons.
In January 2001, the NRC approved the installation of new spent fuel storage racks based on its written understanding that a 117-ton crane would be used.
In July 2016, the NRC approved license renewal of the reactor based on its written understanding that the crane has a 125-ton capacity.
While the difference is small (if an 8-ton variation can be considered small), the implications are big.
§ 54.3 of Title 10 of the Code of Federal Regulations states:
Current licensing basis (CLB) is the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations contained in 10 CFR parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 52, 54, 55, 70, 72, 73, 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications. It also includes the plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent final safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports. [underlining added for emphasis]
The Current Licensing Basis (CLB) is not merely an archival exercise blazing paper trails.
Workers follow the CLB paper trail to ensure the reactor is being operated within safety bounds approved by the NRC, thus managing the risk to an acceptably low, but not zero, level.
Similarly, the NRCs inspectors and reviewers follow the CLB paper trail to independently verify that the reactors inherent risk is being adequately managed.
Neither workers nor the NRC can do their jobs properly when they encounter forks in the paper trail.
As implied by the requirement to periodically revise the UFSARs, the CLB is not static but frequently changing.
Under §50.91, owners can apply to the NRC to amend the CLB, as the owner did in November 1999 to rerack the spent fuel pool.
Under §50.59, owners can also change the CLB without prior NRC approval as long as the change are formally evaluated to remain within safety boundaries previously approved by the NRC.
Speaking of paper trails, use of §50.91 and §50.59 are supposed to leave publicly available paper trails. ADAMS, the NRCs online digital library, was searched extensively for a §50.91 or §50.59 paper trail for the reactor building cranes 117-ton rating being legally upgraded to 125-tons.
§50.91 paper trails entail at least two documents per approved change (i.e., the request by the owner and the approval by the NRC) and often entail several other documents (e.g., requests by the NRC for additional information about the proposed change and the responses from the owner providing the requested information.)
Other than the January 2001 amendment citing a 117-ton crane, no §50.91 paper trail involving the reactor building cranes rating was found.
Literally thousands of summaries, like this typical example, by the owner per §50.59 were reviewed, but none were explaining the upgraded crane.
Source ML003771657 Others reviewed include:
ML003771303 (11-17-2000)
ML003768518 (10-30-2000)
ML003762039 (10-11-2000)
ML003757861 (09-26-2000)
ML003757854 (09-25-2000)
ML003753202 (09-15-2000)
ML003747333 (08-28-2000)
ML003740851 (08-04-2000)
ML003736225 (07-20-2000)
ML003734885 (07-14-2000)
ML003731360 (06-29-2000)
ML003727856 (06-16-2000)
ML003722975 (06-01-2000)
ML003710350 (04-20-2000)
ML003704259 (04-10-2000)
ML003701348 (04-03-2000)
ML003701402 (03-30-2000)
ML003695157 (03-15-2000)
ML003686342 (02-08-2000)
ML003680855 (01-27-2000)
ML003678950 (01-19-2000)
ML003670758 (12-15-1999) and so yawn
The NRC-approved design and licensing basis for the rating of the reactor building crane used to move spent fuel casks at Fermi Unit 2 is:
A. 117 tons B. 125 tons C. Clearly confusing As described above, strong cases can be made for any of these three answers being right.
The NRC-approved design and licensing basis for the rating of the reactor building crane used to move spent fuel casks at Fermi Unit 2 is:
A. 117 tons B. 125 tons C. Clearly confusing But public health and the law demand that this safety question have but one right answer - and that answer must NOT be C.
Before the next load weighing more than 115 tons is lifted by the reactor building crane at Fermi Unit 2, the NRC should determine whether the cranes design and licensing basis is a 117-ton rating, a 125-ton rating, or some other value.
Determining the right rating should identify the paper trail followed to establish it.
If the NRC discovers that the owner did a little off-roading to create a rating without following an NRC-approved path, appropriate sanctions should be imposed.