ML19344A894

Forwards Info Requested Re Control of Heavy Loads Near Spent Fuel

ML19344A894
Person / Time
Site:	Millstone
Issue date:	07/17/1978
From:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Reid R Office of Nuclear Reactor Regulation
Shared Package
ML19344A891	List: ML19344A890 ML19344A894
References
REF-GTECI-A-36, REF-GTECI-SF, TASK-A-36, TASK-OR TAC-08061, TAC-8061, NUDOCS 8008220487
Download: ML19344A894 (25)

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NORTHEAST IFrlLITIES

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P O BOX 270 HARTFOAo. CONNECTICU' 06101 j'..,.N... 2.s.'$

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July 17, 1978 Docket No. 50-336 Director of Nuclear Reactor Regulation Atta: Mr. R. Reid, Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Reference:

(1) V. Stello, Jr., letter to W. G. Counsil dated May 17, 1978.

Gentlemen:

Millt., tone Nuclear Power Station, Unit No. 2 Control of Heavy Loads Near Spent Fuel In Reference (1), Northeast Nuclear Energy Company (NNECO) vac requested to pro-vide information concerning the control of heavy loads near spent fuel. Accor-dingly, Attachment 1 is provided which addresses each of the requested items.

We trust this information is responsive to your request.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY A . NC W. G. Counsil l Vice President Attachment soon20bg7 l

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DOCKET NO. 50-336

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4 ATTACHMENT 1 1

r MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 CONTROL OF HEAVY LOADS NEAR SPENT FUEL i

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- JULY, 1978

Response 4 The following analyses have been provided to the NRC Staff:

Millstone Unit No. 2 Environmental Report Section 6.6 - Fuel Assembly Drop in Refueling Pool

- Heavy Object Drop onto Fuel in Core Section 6.7 - Fuel Assembly Drop into Spent Fuel Pool ,

- Heavy Object Drop onto the Spent Fuel Racks

- Spent Fuel Shipping Cask Drop Millstone Unit No. 2 FSAR Section 5.4.3.3.3 - Cask Drop Analysis Section 14.5 - Fuel Handling Incident D. C. Switzer letter to G. Lear dated March 21, 1977 Fuel Handling Accident in Containment Item 5 Identify any heavy loads that are carried over equipment requi.ed for the safe shutdown of a plant that is operating at the time the load is mcved. Identify what equipment could be affected in the event of a heavy load bandling accident (piping, cabling, pumps, etc.) and discuss the feasibility of such an accident affecting this equipment. Describe the basis for your conclusions.

Response 5 Due to physical arrangements, heavy loads are not carried over operating vital equipment.

Item 6 If heavy loads are required to be carried over the spent fuel storage pool or fuel' transfer canal at your facility, discuss the feasibility of a handling accident which could result in water leakage severe enough to uncover the spent fuel.

Describe the basis for your conclusions.

Response 6 A cask drop in the spent fuel pool represents the most limiting incident which could result in water leakage. This incident has been analyzed in FSAR, Section 5.4.3.3.3 and the results indicate that although some local damage to the liner plate and/or concrete may occur, the extent of the damage is small and will not result in any significant damage to the floor.

Item 7 Describe any design features of your facility which affect the potential for a heavy load handling accident involving spent fuel, e.g., utilization of a single failure-proof crane.

Response 7 These design features are described in FSAR, Section 9.8, " Fuel and Reactor Component Handling Equipment".

Item 8 Provide copiea of all procedures currently in effect at your freility for the movement of hesvy loads over the reactor core during refueling, the spent fuel storage pool, or equipment required for the safe shutdown of a plant that is operating at. the time the move occurs.

Response 8_

The only procedure which contains controls on movement of heavy loads is the attached operating procedure 2209A, Refueling Operations. Operating procedure 2211B, Spent Fuel Shipment has not been written pending the purchase of the shipment casks.

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Comparison of the Millstone Unit No. 2 Spent Fuel Storage

9. Facility to Regulatory Guide 1.13 The Millstone Unit No. 2 spent fuel storage facility has been compared with the guidelines set forth in Regulatory Guide 1.13 and has been found to be in complete compliance with this docu-ment. Brief descriptions of how the Millstone Unit No. 2 facility is in compliance with the eight regulatory positions in this guide are given below.

1. The spent fuel storage facility (including its structures and equipment except as noted in paragraph 6 below) should be designed to Category I seismic requirements.

The spent fuel pool is an integral part of the auxiliary

. building. The entire auxiliary building is a seismic Category I structure. The structural properties of the spent fuel pool are described in Millstone Unit No. 2 FSAR Sections 5.4.1.1.2. Seismic analyses were performed on the auxiliary building and hence on the spent' fuel pool in accordance with FSAR Section 5.8.

2. The facility should be designed (a) to keep tornadic winds and missiles generated by these winds from causing signifi-cant loss of watertight integrity of the fuel storage pool and (b) to keep missiles generated by tornadic winds from contr.cting fuel within the pool.

Tba spent fuel pool, as part of the auxiliary building, is designed to withstand tornadic winds and missiles without loss of watertight integrity. The tornado design of the auxiliary building and spent fuel pool are described in the Millstone Unit No. 2 FSAR Sections 5.4.3.1.6 and 5.4.3.3.2.

3. Interlocks should be provided to prevent cranes from passing over stored fuel (or near stored fuel in a manner such that if a crane failed, the load could tip over on stored fuel) when fuel handling is not in progress. During fuel handling operations, the interlocks may be bypassed and administrative control used to prevent the crane from carrying loads that are not necessary for fuel handling over the stored fuel or other prohibited areas. The facility should be designed to minimize the need for bypassing such interlocks.

Interlocks / physical stops are installed on the auxiliary building crane to prevent crane travel over irradiated fuel with loads in excess of 1800 pounds. The prohibition of lifting heavy loads over irradiated fuel is a requirement of Technical Specification 3.9.7. Surveillance requirements l to assure that the required interlocks / stops are operable prior to handling irradiated fuel are given in Technical Specification 4.9.7. j l

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4. A controlled leakage building should enclose the fuel pool.

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The building should be equipped with an appropriate ventila-tion and filtration system to limit the potential release of radioactive iodine and other radioactive materials. The building need not be designed to withstand extremely high winds, but leakage should be suitably controlled during refueling operations. The design of the ventilation and filtration system should be based on the assumption that the cladding of all of the fuel rods in one fuel bundle might be breached. The inventory of radioactive materials available for leakage from the building should be based on the assump-tions given in Regulatory Guide 1.25, " Assumptions Used for Evaluating the Potential Radiological Consequances of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors" (Safety Guide 25).

The potentially radioactive areas of the auxiliary building, such as the spent fuel pool area, are maintained at a nega-tive pressure relative to clean areas of the plant and the out of doors. This feature ensures that there will be no leakage from radioactive arcas.

During handling of spent fuel which was decayed for less than sixty (60) days, the spent fuel pool area is ventilated by the enclosure building filtration system (EBFS). The exhaust air processed through the EBFS passes through pre-filters, charcoal and HEPA filters before being exhausted to the atmos-phere via the Unit No. 1 stack. Inleakage is controlled by the administrative closure of all access doors to the spent fuel pool area as specified in Technical Specification 3.9.14.

Ventilation requirements for handling of spent fuel which has decayed less than sixty (60) days are described in the Millstone Unit No. 2 Technical Specificaticn 3.9.14.

During normal operation including handling of spent fuel de-cayed more than sixty (60) days, the exhaust air from the spent fuel pool area is passed through a particulate and a HEPA filter and exhausted up the Unit No. 2 stack. Outside makeup air is supplied at a lower flow rate than exhaust air thereby maintaining a negative pressure in the pool area.

In the event of a fuel handling accident in the spent fuel pool area, high radiation signal automatically diverts flow to be exhausted through the EBFS. The same higher radiation signal would isolate the normal air supply and exhaust. The exhaust path for the EBFS is described above.-

The breaching of cladding integrity of a complete spent fuel assembly (176 rods) has been analyzed and the radiological consequences have been found to be well within the limits of 10 CFR part 100. Structural analyses of the fuel has shown that only the first row (14 rods) cculd be breached during a fuel drop accident.

The normal ventilation system for the spent fuel pool area is described in FSAR Sections 9.9.8 and 9.9.9. The EBFS is described in FSAR Section 6.7. The fuel handling incident is described in FSAR Section 14.5.

5. The spent fuel storage facility should have at least.one of the following provisions with respect to the handling of heavy loads, including the refueling cask:

(a) Cranes capable of carrying heavy loads should be prevented, preferably by design rather than by interlocks, from moving into the vicinity of the pool; or, (b) Cranes should be designed to provide single-failure-proof handling of heavy loads, so that a single failure will not result in loss of capability of the crane-handling system to perform its safety function; or, (c) The fuel pool should te designed to withstand, without leakage that could uncover the fuel, the impact of the heaviest load to be carried by the crane from the maximum height to which it can be lifted. If this approach is used, design provisions should be made to prevent the crane, when carrying heavy loads, from moving in the vicinity of stored fuel.

The spent fuel pool has been analyzed for a cask drop accident.

It has been concluded that although some ninor local damage to the 1/4 inch type 304 stainless steel liner plate would occur, no significant structural damage would result.- The res'11ts of the cask drop analysis are given in the Millstone Unit No. 2 FSAR Section 5.4.3.3.3.

In addition, the crane is interlocked so that it cannot pass over the spent fuel pool or cask loading pit. During instal-lation or removal of a cask into the cask loading pit, the interlock is partially disengaged to allow travel over the pit but still prevents travel over the remainder of the spent fuel pool. Technical Specification 4.9.7 ensures that the interlocks / stops which preclude crane travel with heavy laods over the spent fuel pool are operable / installed.

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6. -Drains, permanently connected mechanical or hydraulic systems, and other features that by maloperation or failure could cause loss of coolant that would uncover fuel should not be installed or included in the design. Systems for maintaining water quality and quantity should be designed so that any malopera-tion or failure of such systems (including failures resulting from the Safe Shutdown Earthquake) will not cause fuel to be uncovered. These systems need not otherwise meet Category I seismic requirements.

The spent fuel pool for Millstone Unit No. 2 does not 1: ave any low point drains. The suction to the spent fuel cooling i

system is taken just below normal water level. The return line which enters near the top of the pool and extends to

• near the bottom is equipped with a siphon breaker. Draining of the pool due to a break in the spent fuel pool cooling system is therefore not possible.

The only other connection which is near the bottom of the This tube is seismic Category pool is the fuel transfer tube.

I and except during refueling, is isolated on the spent fuel side by a gate valve and on the containment side by a blind flange.

The pool is equipped with a leak chase system so that small leaks in the pool liner can be detected and corrective action can be taken.

The spent fuel pool is described in FSAR Section 9.5

7. Reliable and frequently tested monitoring equipment should be provided to alarm both locally and in a continuously manned location if the water level in the fuel storage pool falls below a predetermined level or if high local-radiation levels are experienced. The high radiation level instrumentation should also actuate the filtration system.

The spent fuel pool is equipped with both high and low It level is alarms. These alarms sound in the main control room.

not necessary,for this alarm to sound locally since personnel in the area would either visually notice an abnormal pool level or be notified of the abnormal pool level by control room personnel. These alarms are tested at routine intervals under approved maintenance procedures. In addition, proper water level is verified once per seven (7) days in accordance with Technical Specification 4.9.12.

i The spent fuel pool area is equipped with high radiation monitors which sound both locally and in the main control room. As described in the answer to Regulatory Postion #4, a high radiation signal will automatically cause the EBFS to tako suction from~the. spent fuel pool area. The radiation

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monitoring system is tested in ,accordance with Technical Specification 4.3.3.1. A description of this system can be found in FSAR Section 7.3.2.1.

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8. A seismic Category I makeup system should be provided to add coolant to the pool. Appropriate redundancy or a backup system for filling the pool from a reliable source, such as a lake, river or onsite seismic Category I water-storage facility, should be provided. If a backup system is used, it need not be a permanently installed system. The capacity of the makeup systems should be such that water can be supplied at a rate determined by consideration of the leakage rate that would be expected as the result of damage to the fuel storage pool from the dropping of loads, from earthquake or from missiles originating in high winds.

Normally, makeup water is provided from the primary makeup water (PMW) tank through non-seismic lines. In an emergency makeup water can be supplied through seismic piping from either the refueling water storage tank or the condensate storage tank. Also, the fire protection system can be used for emergency makeup through temporary hose connections.

For a detailed description, see FSAR Section 9.5.2.1.

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- DOCKET NO. 50-336 1

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1 ATTACHMENT 2 i

y MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 4

1 OPERATING PROCEDURE 2209A, REFUELING OPERATIONS i

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2 JULY, 1978

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• SPR0VALU~~~' s Plant Superi dent ,

STATION PROCEDURE COVER SHEET . .

A. 1DENTIFICATION_

2 OP 2209A Rev.

Ittsuber '

REFUELING OPERATIONS Title '

William E.' Strong .

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Prepared By_ ,,

3. REVIEW ,

I have reviewed the above procedure and have found it to be sa.tisfacto'ry. -

TITLE , SIGNATURE DA'TE .

. ' DEPARTMENT HEAD "[g [gg '//zgh V.

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C. UNREVIEOED SAFETY QUESTION EVALUATION DOCUMENTATIGN REQUIRED: ,

(Significant change in procedure method or scope .

as described in FSAR) . YES [-] '

No B)0 (If yes, document in PORC/SORC meeting minutes) -

ENVIRONMENTAL IMPACT . ,

(Adverseenvironmentaiimpact) '

YES [ ] N O B y]

(If yes, document in PORC/50RC meeting minetes) ,

D.

• PORC/50RC APPROVAL , .

PORC/60RCX Meeting Number 77-133 ,

E.- APPROVAL AND IMPLEMENTATION

.The attached procedure is hereby approved, and effective on the dates below:

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' . , Plant Superintendent / Unit Superintendent Approved Date Effective Date

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SF-301 Rev.2l

OP 22 Page 1 Rev. 2 Date: 11/28/77 f'

REFUELING OPERATIONS Page No. . _. . ., _

Effective Revision -. -----

Date 1 - 2~ 11/28/77 2 2 11/28/77

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11/28/77 4 2 11/28/77 5 2 -

11/28/77.

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OP 220" Paga 2 Rev. 2 ' Date: 11/28/77 TABLE OF CONTENTS

- Page No. '

5.1 Preparing the reactor vessel and cavity for refueling. 9 5.2 Refueling operation - control room operating personnel. 10 j 4

5.3 Refueling operation - refueling area operating personnel. 11 ,

5.4 Refueling operation - fuel storage area operating 12 personnel.

5.5 ~ Refueling operation - reactor engin cering personnel. 13 5.6 Returning the tractor coolant system to a cold shutdown 13 condition.

OP 22 "* Pag 2 3 Rev. Date.:11/28/77

1. OBJECTIVE 1.1 To specify the plant requirements and steps necessary to place the plant in a refueling condition.

1.2 To delineate the necessary plant requirements and personnel -

responsibilities to ensure a safe and orderly refueling operation.

1.3 To specify the steps necessary to return the Reactor Coolant System to a cold shutdown condition.

2.' PREREQUISITES NOTE: Refer to Fonn 2209A-1, Prerequisite sign off sheet. ,

2.1 The reactor has been placed in a refueling shutdown condition inaccordancewithOP2207(PlantCooldown). .

2.2 Fuel assemblies required for refueling are verified to be stored in the spent fuel pool and/or the new fuel vault and all new fuel assemblies have been inspected in accordance with OP 2210A, New Fuel Assembly and Control Element Assembly Receipt and Inspection. .

2.3 The following systems are capable of supporting refueling operations.

1 2.3.1 Reactor Coolant System OP 2301 2.3.2 Shutdown Cooling System OP 2310 2.3.3 Low Pressure Safety Injection OP 2307 ,

2.3.4 High Pressure Safety Injection OP 2308 2.3.5 Refueling Water Storage Tank OP 2350 OP 2312 h 2.3.6 Containment CP 2303 T 2.3.7 Fuel Handling 2.3.8 Chemical Volume control OP 2304 2.3.9 Reactor Building Closed Cooling Water OP 2330A 2.3.10 Service Water OP 2326 l

2.3.11 Instrument Air OP 2332B

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Station Air OP 2332A

,2.3.12 Clean Liquid Radwaste OP 2335 l 2.3.13 2.3.14 Aerated Liquid Radwaste OP 2336 Makeup Water OP 2340

!2.3.15 .

Fire Protection OP 2341 l 2.3.16 l

OP 22 M Page 4 Rev. c Date: 11/28/77 2.3.17 Spent Fuel Pool Cooling 0P 2305 2.3.18 Sampling System OP 2311 2.3.19 Plant Communications OP 2348 2.3.20 Station Electrical 4.16KV ~ Bus.24C or D OP 2343 2.3.21 Station Electrical 480V Bus 22E or F OP 2344 2.3.22 120V Regulated Instrument AC OP 2345A 2.3.23 120V Vital Instrument AC OP 2345B 2.3.24 125 'VDC UP 2345C 2.3.25 Emergency Diesel Generator A or B OP 2346 g 2.3.26 Nuclear Instrumentation Wide Ra.nge OP 2401 .

F Log Channels 2.3.27 Process & Area Radiation Monitoring OP 2404A & B V 2.3.28 Engineered Safeguards Actuation .OP 2405 2.3.29 Containment Recirculation, Cooli.ng & OP 2313 Yentilation Systems 2.3.30 Main Exhaust OP 2314A 2.3.31 Containment & Enclosure Building Purge OP 23148 -

2.3.32 Radwaste(Aux. Bldg.) OP 2314C 2.3.33 Fuel Handling Area OP 2314F 2.3.34 Enclosure Bldg. Filtration OP 2314G 2.3.35 Control Room Air Conditioning OP 2315 2.4 The containment area radiation and airborne radiation monitors shall be operable during the refueling operation. (Tech.

Spec.3.9.9)  !

2.5 The containment purge valve isolation system shall be operable I duri.ng refueling operations. (Tech. Spec. 3.9.10) l 2.6 Containment penetrations shall be in the following status:

2.6.1 Equipment door in place and bolted.

2.6.2 At least one door in the personnel airlock secured.

2.6.3 Each penetration providing direct access from the contair. ment atmosphere shall be:

1. Closed by an isolation valve, blind flange or a manual valve; or l l 2. ' Be capable of being closed by an operable l containment purge valve.

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OP 22 Pag 2 5 Rev. Date: 11/28/77 2.7 The containment evacuation alarm shall be satisfactorily ,

tested from panel C04 within one day prior to refueling.

2.8 Prior to initiating fuel movement ensure proper operation and interlock operability of the followfng refueling equipment is

• verified:

2.8.1 Refueling Machine (Preoperational Check List OPS Form 2303-1) .

2.8.2 Transfer System (Preoperational Check List OPS Form 2303-2) '

2.8.3 CEA Change Machine (Preoperational Check List .

OPS Fonn 2303-3) 2.8.4 Spent Fuel Pool Platform Crane (Preoperational Check List OPS Form 2303-4) 2.8.5 New Fuel Elevator (Preoperational Check . List OPS Fonn 2303-5) 2.8.6 Communications Circuit 2.8.7 Alignment of T.V. Camera (OPS Form 2303-7) 2.8.8 Alignment of Refueling Machine (OPS Form 2303-8) 2.8.9 Spent Fuel Cask Crane (Preoperational Check List OPS Fonn 2303-9) 2.8.10 Spent Fuel Inspection Equipment (Preoperational j 1

Check List OPS Form 2303-10) 2.9 All personnel who will participate in the refueli.ng operation have been briefed and are thorougMy familiar with this, procedure, and the Fuel Handling Procedure, OP 2303.

2.10 Refueling work list has been properly initiated.

g4 311 A complete checkout, includi.ng a load test (Sury. Proc. 2637A),

()N shall be conducted on the refueling machine crane with 3 days

' prior to the start of moving fuel assemblie3. (Tech. Spec. I 3.9.6) 2.12 Auxiliary building doors specified in Tech. Spec. Table 3.9-1 shall be closed and the spent fuel area shall be exhausted through the EBFAS in the auxiliary exhaust mode. (Tech. Spec.

3.9.14and3.9.15) .

OP 220ca Page 6 ,

Rev. Date:11/28/77 2.13 One off-site power supply and are emergency diesel shall be operational during ref ueling operati6ns. (Tech. Spec.

3.8.1.2) 2.14 The minimum AC and DC electrical distribution (inplant) specified in Tech. Specs. 3.8.2.2 and 3.8.2.4 shall be maintained during the refueling operation.

2.15 At least one charging pump or one HpSI pump shall be operational during the refueling operation. (Tech. Spec. 3.1.2.3) 2.16 A minimum of one shutdown cooling loop shall be operable duri.ng refueling operations. (Tech. Spec. 3.9.8) .

2.17 At least one flow path to the core for boric acid injection and its associated heat tracing shall be maintained during the refueling operation. (Tech. Spec. 3.1.2.1) 2.18 At least two spent fuel storage pool area radiation monitors and b'o th the gaseous and particulate spent fuel storage pool ventilation monitors shall be operable. (Tech. Spec. 3.9.13)

3. ' INITIAL CONDITIONS 3.1 Reactor coolant boron concentration is being maintained uniform and of sufficient concentration to ensure keff is less than 0.90 with all rods inserted.

3.2 Reactor coolant system temperature is maintained greater than 82*F by the shutdown cooling system.

3.3 The chemical volume control system is lined up for nomal operationin-accordancewithOP2304(CVCS)withthefollowing exceptions: ,

3.3.1 Charging pumps secured. Handswitches in the off position on CO-2 and green stripe caution tagged.

3.3.2 System filled with borated water at a concentration equal to or greater than the concentration of the reactor coolant system.

3.3.3 Volume control tank at normal operating level. I 3.3.4 Let down flow secured. 2-CH-515 and 2-CH-516 shut l and red t.agged.

Page 7 OP22g

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. Rev. 2 Date:11/28/77 3.3.5 Reactor coolant pump controlled bleed off isolated.

2-CH-505 and 2-CH-506 shut and red tagged.

3.3.6 VCT is pressurized to 5 PSIG with nitrogen.

3.4 To prevent the addition of unborated water to the reactor coolant system, the follow kg valves are shut and red tagged.

1) 2-CS-10A PMW to RWST

2) 2-CH-195, PMW TO RCS Makeup

3) 2-CH-422 PMW to CVCS Demin.

4) 2-CH-080 ,

PMW to CVCS Flush ,

5) 2-PMW-167 PMW to Spent Fuel Pool 6

6) 2-RW-77 PMW to SEP Demin.

3.5 Reactor coolant pump breakers are racked out and red tagged.

3.6 Pressurizer heater breakers are racked out and red tagged.

3.7 RCS hot leg drain valves 2-RC-215 and 040 are shut and caut.on tagged. Inaccurate refueling level will result if opened.

3.8 Spent fuel pool and transfer canal filled with borated water with a concentration equal to or greater than reactor coolant system concentration and spent fuel pool cooling system in operation.

3.9 Minimum shift complement during refueling is four (4) persons.

A licensed Unit 2 SR0 shall be in direct charge of refueling operations in the reactor fueling area. In addition, there -

shall be at least one licensed RO in the control room and one licensed Unit 2 SRO in the station not directly involved in supervising fuel loading. ,

4. PRECAUTIONS 4.1 Whenever core geometry is being changed, neutron flux shall be continuously renitored by at least two source range neutron monitors, with each monitor providing continuous visual indication l

.in the control room, and one with audible indication in containment.

(Tech. Spec.3.9.2) 4.2 During reactor vessel head removal and while refueling operations are being performed in the reactor, the reactor coolant system t

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OP 22 Par,e 8 Rev. .

Dete: 11/28/71 boron concentration must be maintained uniform and of a sufficient concentration to ensure k'eff is less than 0.90 with all rods inseited. (Tech. Spec.3.9.1) 4.3 Direct communication between personitel in the control room and

, at the refueling machine shall be maintained during fuel movement within the reactor pressure vessel. (Tech. Spec.

3.9.5) 4.4 A minimum of 23 feet of water shall be maintained above the top of the fuel in the core whenever irradiated fuel is being handled in the core area. A minimum of 23 feet of water shall be maintained above the top of'the fuel in the spent fuel storage racks whenever irradiated fuel is being handled in the spent fu 1 pool.

4.5 To ensure proper fuel positioning, the refueli.ng machine must be realigned prior to loading fuel if the core support barrel had been moved.

4.6 l. cads greater than that of a fuel assembly and CEA shall be prohibited from travel over irradiated fuel in the spent fuel pool. (Tech. Spec.3.9.7) 4.7 Movement of irradiated fuel in the core shall not be initiated

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before the reactor core has decayed hr a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(Tech. Spec.3.9.3) ,

4.8 If an excessive or unanticipated counts rate multiplication, i.e., doubli.ng, is indicated at any tiim, fuel handling will cease until the situation has been evaluated by the shift supervisor and reactor engineering perso.1,nel.

4.9 Movement of fuel assemblies, control'elem' int assemblies or i sources is not allowed without knowledge ahd approval of the control room licensed operator. I, 4.10 If a fuel assembly . CEA or source is belieked to be damaged,

.the fuel handling will cease. The reactor { engineer will be notified and an inspection and evaluation i{; to be made on the

, component.

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OP 22 a Pag 2 9 Rev. -

Date: 11/28/77 l 4.11 Throughout fueling operations the refueling machine operator l must be extremely careful to prevent an inadvertent driving of

. .the TV camera or hoist box into the core support barrel. To.

. minimize the possibility of such an occurrence, tne refueling work list indicates allowable refueling mast positions.

4.12 Health Physics procedures must be strictly adhered to at all

. times.

4'.13 Loa'ds greater than that of a fuel assembly and CEA shall be prohibited from travel over irradiated fuel in the vessel with the head removed, without approval of higher management. ,

5. PROCEDURE 5.1 Preparing the reactor vessel and cavity for refueling.

5.1.1 Purge the containment in accordance with OP 23145 (ContainmentandEnclosureBuil'dingPurge).

5.1.2 Enter the containment in accordance with HPP 2920 (ContainmentEntrance).

NOTE: Steps 5.1.3 through 5.1.5 may be done concurrently with only restrictions as per MP 2704.

5.1.3 Drain the reactor vessel toil 2" below the vessel' flange in accordance with OP1301E 2 (Draining the RCS). \

5.1.4 Prepare the reactor vessel hea for removal in accordance with MP 2704A (Preparation for Reactor Vessel Head Removal).

5.1.5 Install refueling pool seal in ac ordance with MP 2704B (Installation of Refueling P ol Seal). ,  !

5.1.6 Remove reactor vessel head in accor(ance with MP  !

2704C (Reactor Vessel Head Removal). l 5.1.7 Remove blind flange from transfer tu 3

. 5.1.8 Fill the reactor cavity to 31'6" leve in accordance

.' ' with OP 2307 (Low Pressure Safety Injdction).

i 5.1.9 Uncouple the CEA extension shafts in 2:cordance with  !

MP 2704D (Uncoupling CEA Extension Shaj f ts).

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. OP 2 Rev.

Page 10 Date: 11/28/77

, 5.1.10 Prepare to remove the upper guide structure i.7 accordance with MP 2704F, Steps 5.1 thivugh 5.11 (Removal of Upper Guide Structure).

5.1.11 Remove incore instrument assembly in accordance with -

MP 2704E (Removal of 1C1 Assembly).

5.1.12 Fill reactor cavity to 36'6" level in accordance with OP 2307 (Low Pressure Safety Injection).

5.1.13 Complete removal of upper guide structure in accordance with MP 2704F _ (Removal of Upper Guide Structure).

5.1.14 Place the refueling pool skimer system in operation.

in accordance with OP 2305 Section 7.7 (Spent Fuel Pool Cooling and Purification System).

NOTE: The following step is optional, depending on water clarity.

5.1.15 Place the spent fuel pool purification system in service on the refueling pool in accordance with OP 2305 Section 7.8 (Spent Fuel Pool Cooling and -

Purification).

5.1.16 Verify spent fuel pool level and refueling pool level are at the same level and greater than 35'6",

then open the transfer tube. isolation valve.

5.1.17 If not .already operating, place the spent fuel pool skimer system in operation in accordance with OP 2305 (Spent Fuel Pool Cooling and Purification).

5.1.18 Handle all core components in accordance with OP 2303 (Fuel Handling) and the refueling worklist.

5.2 Refueling operation - control room operating personnel.

5.2.1 Direct and approve all core component movement during the refueling operation.

NOTE: The refueling worklist contains a step by step l ,

refueling sequence (material transfer forms).

l 5.2.2 Receive notification of core component movement and l acknowle.dge sJch notification by, step No., component serial numbers, originating loca' tion, present location and orientation of the refueling nachine mast, if applicable. {

g ,

OP22g Rev. 2 Paga 11 Date: 11/28/7:

5.2.3 Maintain an up to date status of material transfer foms Initial and note date and time (as executor) after each completed step. (Refueling Worklist) 5.2.4 Maintain the count rate data log (OPS Form 2209A-2).

Log counts hourly, even during periods when refueling operations have been interrupted.

5.2.5 Stop.any fuel handling movement immediately if any discrepancy is noted or for reasons of safety and immediately nottfy shift supervisor.

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5.2.6 Maintain direct communications with refueling area and fuel storage area at all times while handling fuel.

5.2.7 Ensure Chemistry Dept, samples the reactor coolant system boron concentration at least daily.

5.3 Refueling operation - refueling area operating personnel.

5.3.1 Move all components under the direction of the control room and in accordance with material transfer

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forms. (Refueling Worklist) 5.3.2 Operate all fuel handling equipment in accordance with OP 2303 (Fuel Handling System).

5.3.3 Notify control. room of completion of each applicable step, including step No., component serial number, originating location, present location and orientation

. of refueling machine mast, if applicable.

5.3.4 Notify control room of the following:

5.3.4.1 Receipt of a fuel bundle from spent fuel storage area via transfer carriage.

5.3.4.2 Holding a fuel bundle over a core location prior to insertion into the core.

~

.  :. 5.3.4'.3 Full insertion of the fuel bundle into the Core.

5.3.4.4 Unlatching the fuel bundle.

5.3.4.5 Initiating transfer of fuel bundle to spent fuel area.

l 2209A Page 12

.2 Date: 11/28/77 5.3.5 Obtain permission from control room prior to transporting fuel from containment to spent fuel area via transfer l carriage. l 5.3.6 Initial and note date and time after completion of I each applicable step on the material transfer form (refueling aachine operator will sign as Executor, SRO or RE as SNM checker).

5.3.7

• Immediately notify control room if any discrepancies are discovered.

5.4 Refueling operation - fuel storage area operating personnel.

5.4.1 Move all components under the direction of the control room and in accordance with the material transfer forms. (Refueli.ngWorklist) 5.4.2 Operate all fuel handling equipment in accordance with Op 2303 (Fuel Handling System). ,

5.4.3 Notify control room of the following:

5.4.3.1 When over a fue1. assembly in the spent )

fuel storage /new fuel storage racks, prior j to latching, stating step number, component )

serial number and fuel storage rack location. )

5.4.3.2 After the completion of each applicable

. step (Refueling Worklist) by step number, component serial number, originating location and present location.  ;

5.4.3.3 Receipt of a fuel bundle from refueling-cavity area via transfer carriage. I 5.4.4 Obtain permission from control room to transfer a '

core component to the refueling cavity via transfer ,

carri. age. Notify control room when transfer is complete and receive acknowledgement.

5.4.5 Immediately notify control room if any discrepancy is discovered.

5.4.6 Initial and note date and time after completion of

' each applicable step on the material transfer form (spent fuel machine operator will sign as Executor, REasSNMchecker). -

Page 13 OP22g Rev. 2 Date: 11/28/77 5.5 Refueling operation - react.or engineerg personnel.

5.5.1 Monitor count rate activity.

5.5.2 Maintain current entries in reactor engineers log.

5.5.3 Monitor entire refueling operation to include spot checks of each area and review of all data.

, 5.5.4 Resolve any questions of discrepancies concerning refuelir.g.

5.5.5 Keep the unit reactor engineer apprised of the status of refueling. ,

5.5.6 Stop refueling operations at any time for reasons of' .

safety.

5.5.7 Maintain the tag board to reflect status of all' fuel assemblies, control element assemblies and sources.

5.6 Returning the reactor coolant system to a cold shutdown condition.

5.6.1 Verify the post refueling verification check has been completed. (Refueling Worklist) 5.6.2 Transfer the transfer carriage to the spent fuel pool transfer canal for storage.

CAUTION: If the spent fuel purification system is to remain in operation on refueling pool, ensure it is lined up for operation with the transfer tube isolation valve shut. Ensure spent fuel pool cooling system is lined up for operation with transfer tube isolation valve shut. (Refr.r to OP 2305, Spent Fuel Cooling andPurification.) . .

5.6.3 Install spent fuel pool. gate. .

5.6.4 Shut fuel transfer tube isolation valve.

5.6.5 Install the upper guide structure in accordance with l MP 2704I (Installation of UGS) Steps 5.1 through 5.5. .

,5.6.6 Secure the refuel pool skimmer syatem OP 2305 (Spent

. Fuel Pool Cooling and Purification).

5.6.7 Drain the refuel pool to the 31'6" level (to clear the operating platform of the UGS lift, assembly) i.n

Page 14 Og09A Rev. 2 Date: 11/28/77 accordance with OP 2305 Section 7.9 (Spent Fuel' Pool Cooling and Purification). For an alternate method

.of draining refer to OP 2307 Section 7.3 (Low Pressure Safety Injection). -

5.6.8 Install the incore instrument assembly in accordance with MP 2704J (Installation of I.C.I. Assembly).

5.6.9 Complete installation of upper guide structure in accordance witi MP 2704I (Installation of UGS).

5.6.10 couple the CEA extension shafts in accordance with MP 2704K (Coupling the CEA Extension Shafts). ,

5.6.11 Drain the refuel pool in accordance with OP 230S Section 7.9 (Spent Fuel Pool Cooling and Purification).

For alternate method of draining, refer to OP 2307 Section 7.3 (Low Pressure Safety ~ Injection).

5.6.12 Install blind flange on transfer tube. Perform leak detection test on fuel transfer tube in accordance with Surveillance Procedure 26098 (Local Leak Detection Test). i

-5.6.13 Drain the reactor vessel to 12 inches below the reactor vessel flange in accordance with OP 2301E (DrainingtheRCS).

5.6.14 Install the reactor vessel head in accordance with MP 2704L (Reactor Vessel Head Installation).

5.6.15 Remove the refueling pool seal in accordance with MP 2704M (Removal of Refueling Pool Seal).

S.6.16 Complete the reactor vessel head installation in accordancewithMP2704N(CompletionofReactor YesselHeadInstallation).

5.6.17. Fill and vent the reactor coolant system in accordance with OP 2301D (Reactor Coolant System Fill and Vent).

5.6.18 Perform the reactor coolant system 1 ak rate test in accordance w'ith OP 2301B (Reactor Coolant System i LeakRateTest).

i i 6. CHECK OFF LISTS 6.1 None l . . .

Noimirawr imi.mus "l ,[, Ab ONNECT' CUT 06101 e c .a v.r:s= =

July 31, 1978 Docket No. 50-336 Director of Nuclear Reactor Regulation Atta: Mr. R. Reid, Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Con: mission Washington, D. C. 20555

References:

(1) W. G. Counsil letter to R. Reid dated July 17. 1978.

(2) W. G. Counsil letter to R. Reid dated June 6,1978.

(3) E. J. Brunner letter to D. C. Switzer dated September 13, 1976.

(4) D. C. Switzer le.ter ts R. Reid dated March 14, 1978.

(5) E. C. McCabe lette.r tr, D. C. Switzer dated April 6,1978.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Loads Near Soent Fuel, Neutron Shielding, and Containment Leak Rate Testine In Reference (1), Northeast Nuclear Energy Company (NNECO) p ovided the requested information concerning the control of heavy loads near spent fuel. However, due to a collating error, it appears that page one of the attachment, responding to items one through three, was not included. Please find the responses to those items on the attached page.

In Reference (2), NNECO provided preliminary information regarding the proposed neutron shield design. In that letter, NNECO inadvertently neglected to address 10CFR170 considerations. NNECO had previously reviewed the proposal pursuant to the requirements of 10CFR170, and had determined that no fee was required.

This basis for this determination is that the Reference (2) material is merely the continuation of an issue initiated prior to the effective date of 10CFR170.

In Reference (3), Inspection Item 76-14-1 discusses a discrepancy between the Millstone Unit No. 2 Technical Specifications and the literal requirements of l 10CFR50, Appendix J, concerning Type 3 and C containment leak rate testing.

To resolve this item, NNECO proposed a change to the Technical Specifications

- in Reference (4). Following inspector review of the change request, unresolved item 76-14-1 was reported as closed in Reference (5). Since that ti=e, however, the Staff has verbally indicated that the proposed Technical Specification is 732150106 d-40

_2-overly restrictive and that the leak rate testing requirements as they are currently written adequately address the intent of Appendix J. Therefore, NNECO hereby withdraws this change request, with the understanding that this withdrawal will not result in any further action in this matter by the Office of Inspection and Enforcement.

Very truly yours, NORTHEAST NUCLEAR ETERGY COMPANY

/b i 17! ^

- W. G. Counsil Vice President Attachment

Item 1 Provide a diagram which illustrates the physical relation between the reactor core, the fuel transfer canal, the spent fuel storage pool and the set down, receiving or storage areas for any heavy loads moved on the refueling floor.

Response 1 This information is provided in FSAR Figures 1.2-6, 9.8-2, and 9.8-3.

Item 2 Provide a list of all obj ects that are required to be oved m over the reactor core (during refueling), or the spent fuel storage pool. For each abject listed, provide its approximate weight and size, a diagram of the movement path  !

utilized (including carrying height) and the frequency of movement.

Resoonse 2 During refueling operation, administrative controls prevent movenant cf equip-ment which weighs more than a fuel bundle and CEA (appr ximately 1400 pounds) ever either the spent fuel pool or reactor vessel. These precautions are noted in steps 4.6 and 4.13 of attached operating procedure 2209A, Refuel Operations (see Attachment 2). During the refuel operations, the only loads suspended over the irradiated fuel in either locations were the fuel and CIA's moved in the fuel shuffle and special tools used for CEA guide tube sleeving. The list of objects 3 includes:

Fuel Assembly: 8" x 8" x 157",1280 pounds  :

CEA: 161" long, 195/299' pounds (single / dual) l Fuel Handling Tool: 31' long, 365 pounds Guide Tube Sleeving Tools: < 100 pounds Item 3 What are the dimensions and weights of the spent fuel casks that are or will be used at your facility?

Response 3 The purchase specifications have not been formulated for the spent fuel casks which will be used at this facility. Cask drop analyses have assumed a cask 19 feet long, 8 feet in diameter, and weighing 200,000 pounds (see FSAR, Section 5.4.3.1.9).

Item 4 l I

Identify any heavy load or cask drop analyses performed to date for your facility. l Provide a copy of all such analyses not previously submitted to the NRC Staff.

47 Y REGULf.TUR( INFORMATION DISTRIBUTION SYSTEM (RIDS) 50-336 DI5TRIBUTION FOR INCOMING MATERIAL ORG: COUNSIL W G DOCDATE: 07/17/72 (C: REID R W DATE RCVD: 07/24/'s lNRC NE NUC ENERGY NOTARIZED: NO COPIES RECEIVED

~.' TYPE : LETTER LTR I ENCL 40 DJECT:

SPOfJSE TO NRC REQUEST OF 05/17/78... FORWARDING INFO CONCERNING THE CONTROL HEAVY LOADS NEAR SPENT FUEL OF SUBJECT FACILIT4 REVIEWER INITI AL: XJM bANT NAME: MILLSTONE M2 DISTRIBUTOR INITI AL:b(

3*************** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************

OENERAL DISTRIBUTION FOR AFTER ISSUANCE OF OPERATING LICENSE.

(DISTRIBUTION CODE A001)

< FOR ACT ION: DR CHIEF ORB #4 DC**W/7 ENCL INTERNAL: REG FILE **W/ ENCL NRC PDR**W/ ENCL 1 & E**W/2 ENCL OELD**LTR ONLY 4 ER.htW/ ENCL ~% CORE PERFORMANCE BR**W/ ENCL

' AD FOR SYS L PROJ**W/END) ENGINEERING BR**W/ ENCL REACTOR SAtt e y E.n wWfENUL PLANT SYSTEMS BR**W/ ENCL EEB**W/ ENCL EFFLUENT TREAT SYS**W/ ENCL J. MCGOUGH**W/ ENCL EXTERNAL: LPDR'S WATERFORD. CN**W/ ENCL TERA **W/ ENCL NSIC**W/ ENCL ACRS CAT B**W/16 ENCL LTR 40 ENCL 39 CONTROL NBR: 782060010 DISTRIBUTION:

SIZE: 1P425P

• • o4-**o*************e+************* THE END *********************+****++*****

NORTHEAST tmLMES tw un's, . e n ., n os., cwe ,

P o Box 270

] m gi.. ..uu w ,w . n.. g HARTFORD. CONNECTICUT 06101 (2e men g- g  ; .".C'.'.,'ll.C%"/,,'.7,'?.'..

- . . . ..,_,m....-.,.

July 17, 1978 Docket No. 50-336 Director of Nuclear Reactor Regulation Attn: Mr. R. Reid , Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Reference:

(1) V. Stello, Jr., letter to W. G. Counsil dated May 17, 1978.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Control of Heavy Loads Near Spent Fuel In Reference (1), Northeast Nuclear Energy Company (NNECO) was requested to pro-vide information concerning the control of heavy loads near spent fuel. Accor-dingly, Attachment 1 is provided which addresses each of the requested items.

We trust this information is responsive to your request.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

/ Mb W. G. Counsil Vice President Attachment

DOCKE~ NO. 50-336 ATTACHMENT 1 MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 CONTROL OF HEAVY LOADS NEAR SPENT FUEL 1

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JULY, 1978 l

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Response 4 The following analyses have been provided to the NRC Staff:

Millstone Unit No. 2 Environmental Report Section 6.6 - Fuel Assembly Drop in Refueling Pool

- Heavy Object Drop onto Fuel in Core Section 6.7 - Fuel Assembly Drop into Spent Fuel Pool

- Heavy Object Drop onto the Spent Fuel Racks

- Spent Fuel Shipping Cask Drop Millstone Unit No. 2 FSAR Section 5.4.3.3.3 - Cask Drop Analysis Section 14.5 - Fuel Handling Incident D. C. Switzer letter to G. Lear dated March 21, 1977 Fuel Handling Accident in Containment Item 5 Identify any heavy loads that are carried over equipment required for the safe shutdown of a plant that is operating at the time the load is moved. Identify what equipment could be affected in the event of a heavy load handling accident (piping, cabling, pumps, etc.) and discuss the feasibility of such an accident affecting this equipment. Describe the basis for your conclusions.

Response 5 Due to physical arrangements, heavy loads are not carried over operating vital equipment.

Item 6 l If heavy loads are required to be carried over the spent fuel storage pool or fuel ,

transfer canal at your facility, discuss the feasibility of a landling accident 1 which could result in water leakage severe enough to uncover the spent fuel.

Describe the basis for your conclusions. j l

Response 6 A cask drop in the spent fuel pool represents the most limiting incident which could result in water leakage. This incident has been analyzed in FSAR, Section 5.4.3.3.3 and the results indicate that although some local damage to the liner plate and/or concrete may occur, the extent of the damage is small and will not result in any significant damage to the floor.

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Item 7 Describe any design features of your facility which affect the potential for a heavy load handling accident involving spent fuel, e.g., utilization of a single failure-proof crane.

Response 7 These design features are described in FSAR, Section 9.8, " Fuel and Reactor Component Handling Equipment".

Item 8 Provide copies of all procedures currently in effect at your facility for the movement of heavy loads over the reactor core during refueling, the spent fuel storage pool, or equipment required for the safe shutdown of a plant that is operating at the time the move occurs.

Response 8, The only procedure which contains controls on movement,of heavy loads is the attached operating procedure 2209A, Refueling Operations. Operating procedure

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2211B, Spent Fuel Shipment has not beEE written pending the purchase of the shipment casks.

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Comparison of the Millstone Unit No. 2 Spent Fuel Storage

9. Facility to Regulatory Guide 1.13 The Millstone Unit No. 2 spent fuel storage facility has been compared with the guidelines set forth in Regulatory Guide 1.13 and has been found to be in complete compliance with this docu-ment. Brief descriptions of how the Millstone Unit No. 2 facility is in compliance with the eight regulatory positions in this guide are given below.

1. The spent fuel storage facility (including its structures and equipment except as noted in paragraph 6 below) should be designed to Category I seismic requirements.

Thespentfuelpoolisani$ntegralpartoftheauxiliary building. The entire auxiliary building is a seismic Category I structure. The structural properties of the spent fuel pool are described in Millstone Unit No. 2 FSAR Sections 5.4.1.1.2. Seismic analyses were performed on the auxiliary building and hence on the spent fuel pool in accordance with FSAR Section 5.8.

2. The facility should be designed (a) to keep tornadic winds and missiles generated by these winds from causing signifi-cant loss of watertight integrity of the fuel storage pool and (b) to keep missiles generated by tornadic w.nds from contacting fuel within the pool.

The spent fuel pool, as part of the auxiliary building, is designed to withstand tornadic winds and missiles without loss of watertight integrity. The tornado design of the auxiliary building and spent fuel pool are described in the Millstone Unit No. 2 FSAR Sections 5.4.3.1.6 and 5.4.3.3.2.

3. Interlocks should be provided to prevent cranes from passing 1 over stored fuel (or near stored fuel in a manner such that if a crane failed, the load could tip over on stored fuel) when fuel handling is not in progress. During fuel hardling operations, the interlocks may be bypassed and administrative control used to prevent the crane from carrying loads trat are not necessary for fuel handling over the stored fuel or other prohibited areas. The facility should be designed to minimize the need for bypassing such interlocks.

Interlocks / physical stops are installed on the auxiliary building crane to prevent crane travel over irradiated fuel with loads in excess of 1800 pounds. The prohibition of lifting heavy loads over irradiated fuel is a requirement of Technical Specification 3.9.7. Surveillance requirements  ;

to assure that the required interlocks / stops are operable i prior to handling irradiated fuel are given in Technical j Specification 4.9.7. ,

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4. A' controlled leakage building should enclose the fuel pool.

The building should be equipped with an appropriate ventila-tion and filtration system to limit the potential release of radioactive iodine and other radioactive materials. The building need not be designed to withstand extremely high winds, but leakage should be suitably controlled during refueling operations. The design of the ventilation and filtration system should be based on the assumption that the cladding of all of the fuel rods in one fuel bundle might be breached. The inventory of radioactive materials available for leakage from the building should be based on the assump-tions given in Regulatory Guide 1.25, " Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors" (Safety Guide 25) .

1 ***

The potentially radioactive areas of the auxiliary building, such as the spent fuel pool area, are maintained at a nega-j tive pressure relative to cican areas of the plant and the j out of doors. This feature ensures that there will be no 3 leakage from r'adioactive areas.

During handling of spent fuel which was decayed for less than sixty (60) days, the spent fuel pool area is ventilated by the enclosure building filtration system (EBFS). The exhaust air processed through the EBFS passes through pre-filters, charcoal and HEDA filters before being exhausted to the atmos-i phere via the Unit No. I stack. Inleakage is controlled by the administrative closure of all access doors to the spent feel pool area as specified in Technical Specification 3.9.14.

Ve.tilation requirements for handling of spent fuel which has decayed less than sixty (60) days are described in the Millstone Unit No. 2 Technical Specification 3.9.14.

T During normal operation including handling of spent fuel de-cayed more than sixty (60) days, the exhaust air from the spent fuel pool area .is passed through a particulate and a HEPA filter and exhausted up the Unit No. 2 stack. Outside makeup air is supplied at a lower flow rate than exhaust air thereby maintaining a negative pressure in the pool area.

In the event of a fuel handling accident in the spent fuel .

pool area, high radiation signal automatically diverts flow l to be exhausted through the EBFS. The same higher radiation signal would isolate the normal air supply and exhaust. The exhaust path for the EBFS is described above.

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The breaching of cladding integrity of a complete spent fuel assembly (176 rods) has been analyzed and the radiological consequences have been found to be well within the limits of 10 CFR part 100. Structural analyses of the fuel has shown that only the first row (14 rods) could be breached during a fuel drop accident.

The normal ventilation system for the spent fuel pool area is described in FSAR Sections 9.9.8 and 9.9.9. The EBFS is described in FSAR Section 6.7. The fuel handling incident is described in FSAR Section 14.5.

5. The spent fuel storage facility should have at least one of the following provisions with respect to the handling of heavy loads, including the refueling cask:

(a) Cranes capable of carrying heavy loads should be prevented, preferably by design rather than by interlocks, from moving into the vicinity of the pool; or, (b) Cranes should be designed to provide single-failure-proof handling of heavy loads, so that a single failure will not result in loss of capability of the crane-handling system to perform its safety funcU.on; or, (c) The fuel pool should be designed to withstand, without leakage that could uncover the fuel, the impact of the heaviest load to be carried by the crane from the maximum height to which it can be lifted. If this approach is used, design provisions should be made to prevent the crane, when carrying heavy loads, from moving in the vicinity of stored fuel.

The spent fuel pool has been analyzed for a cask drop accident.

It has been concluded that although some ninor local damage to the 1/4 inch type 304 stainless steel liner plate would occur, no significant structural damage would result. The results of the cask drop analysis are given in the Millstone Unit No. 2 FSAR Section 5.4.3.3.3.

In addition, the crane is interlocked so that it cannot pass over the spent fuel pool or cask loading pit. During instal-lation or removal of a cask into the cask loading pit, the interlock is partially disengaged to allow travel over the pit but still prevents travel over the remainder of the spent fuel pool. Technical Specification 4.9.7 ensures that the interlocks / stops which preclude crane travel with heavy laods over the spent fuel pool are operable / installed.

i

6. Drains, permanently connected mechanical or hydraulic systems, and other features that by maloperation or failure could cause loss of coolant that would uncover fuel should not be installed or included in the design. Systems for maintaining water quality and quantity should be designed so that any malopera-tion or failure of such systems (including failures resulting from the Safe Shutdown Esrthquake) will not cause fuel to be uncovered. These systems need not otherwise meet Category I seismic requirements.

The spent fuel pool for Millstone Unit No. 2 does not have any low point drains. The suction to the spent fuel cooling system is taken just below normal water level. The return line which enters near the top of the pool and extends to near the bottom is equipped with a siphon breaker. Draining of the pool due to a break in the spent fuel pool cooling system is therefore not possible.

The only other connection which is near the bottom of the pool is the fuel transfer tube. This tube is seismic Category I and except during refueling, is isolated on the spent fuel side by a gate valve and on the containment side by a blind flange.

The pool is equipped with a leak chase system so that small leaks in the pool liner can be detected and corrective action can be taken.

The spent fuel pool is described in FSAR Section 9.5

7. Reliable and frequently tested monitoring equipment should be provided to alarm both locally and in a continuously manned location if the water level in the fuel storage pool falls below a predetermined level or if high local-radiation levels are experienced. The high radiat.on level instrumentation should also actuate the filtration system.

The spent fuel pool is equipped with both high and low It level is alarms. These alarms sound in the main control rova.

not necessary for this alarm to sound locally since personnel in the area would either visually notice an abnormal pool level or be notified of the abnormal pool level by control room personnel. These alarms are tested at routine intervals under approved maintenance procedures. In addition, proper water level is verified once per seven (7) days in accordance with Technical Specification 4.9.12.

The spent fuel pool area is equipped with high radiation monitors which sound both locally and in the main control room. As described in the answer to Regulatory postion #4, a high radiation signal will automatically cause the EBFS to'take suction fitom the spent fuel pool area. The radiation monitoring system is tested in .accordance with Technical Specification 4.3.3.1. A description of this system can be found in FSAR Section 7.3.2.1.

~- . . . __ _ _ _

8. A seismic Category I makeup system should be provided to add coolant to the pool. Appropriate redundancy or a backup system for filling the pool from a reliable source, such as a lake, river or onsite seismic Category I water-storage facility, should be provided. If a backup system is used, it need not be a permanently installed system. The capacity of the nakeup systems should be such that water can be supplied at a rate determined by consideration of the Icakage rate that would be enpected as the result of damage to the fuel storage pool from the dropping of loads, from earthquake or from missiles originating in high winds. ,

Normally, makeup water is provided from the primary makeup water (pMW) tank through non-seismic lines. In an emergency makeup water can be supplied through seismic piping from either the refueling water storage tank or the condensate storage tank. Also, the fire protection system can be used for emergency makeup through temporary hose connections.

For a detailed description, see FSAR Section 9.5.2.1.

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I DOCKET NO. 50-336 ATTACHMENT 2 MILLSTONE NUCLEAR POWER f,TATION, UNIT NO. 2 OPERATING PROCEDURE 2209A, PIFUELING OPERATIONS JULY, 1978

1 VPROVAL;W '

= W M_ DATE: 7-1-77 ~ '

Plant Superi dent ,

STATION PROCEDURE COVER SHEET .. ..

A. IDENTIFICATION _ .,

OP 2209A 2 Nunber hv.

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REFUELING OPERATIONS Title Prepared By_ William E. Strong 3.

REVIEW _ -

. 1 I have reviewed the above pro'cedure and have found it to be satisftctory. -

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TITLE .

SIGNATURE DATE . j

. 'DEPARTt!ENT HEAD .[g gg // ggg

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f- y'  :

I C.' UNREVIEWED SAFETY OUESTION EVALUATION DOCUMENTATION REQUIRED: .

(Significant change in procedure method or scope as described in FSAR) .

YES[-] No B)0 1

(If yes, document in PORC/SORC meeting minutes)

• ENVIRONMENTAL IMPACT -

(Adverse environmental impact) YES [ ] No h)0 (If yes, document in PORC/SORC meeti,ng minutes) ,

l D, ' PORC/SORC APPROVAL .

PORC/60R(X Meeting Number 77-133 .

E.- APPROVAL AND IMPLEMENTATION The attached procedure is hereby approved, and effective on the dates below:

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_ .' // 22 n // z)/?y

. Plant Superintendent / Unit Superintendent Approv6d Date Effective Date j

SF-301 '

Rev. 2l

OP 22 Page 1

. Rev. 2 Date: 11/28/77

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REFUELING OPERATIONS Page No. . _ . __

Effective Revision , _ __

Date 1 2- 11/28/77 2 2 11/28/77 3 2 .11/28/77 4 2 11/28/77 5 2 -

11/28/77.

__ _ 6 . _ . .. __ 2 11/28/77 . _

7 2 11/28/77

~ ~ ~ ~ ~ ~

8 2 11/28/77

-- - 9 --

11/28/77.. .-

~~ -- ~

__] O __.

2 .

11/28/77 11 2 11/28/77 12 2 .

11/28/77

-13 2 -

11/28/77 14 2 11/28/77 hhh eee  %-

OP 2200* Pag: 2 g ,

V Rev. 2 Date: 11/28/77 TABLE OF CONTENTS

- Page No.

5.1 Preparing the reactor vessel and cavity for refueling. 9 5.2 Refueling operation - control room operating personnel. 10 5

5.3 Refueli.ng operation - refueling area operating personnel. 11 5.4 Refueling operation - fuel storage area operating 12 personnel.

5.5 Refueling operation - reactor engineering personnel. 13 5.6 Returning the reactor coolant system to a cold shutdown 13 condition.

OP 22 na Page 3 Rev. Date.:11/28/77

1. OBJECTIVE 1.1 To specify the plant requirements and steps necessary to place the plant in a refueling condition.

's .2 To delineate the necessary plant requirements and personnel .

responsibilities to ensure a safe and orderly refueling operation.

1.3 To specify the steps necessary to return the Reactor Coolant System to a cold shutdown condition.

2. PREREQUISITES NOTE: Refer to Form 2209A-1, Prerequisite sign off sheet. ,

2.1 The reactor has been placed in a refueling shutdown condition in accordance with OP 2207 (Plant Cooldown). .

2.2 Fuel assemblies required for refueling are verified to be stored in the spent fuel pool and/or the new fuel vault and all new fuel assemblies have been inspected in accordance with OP 2210A, New Fuel Assembly and Control Element Assembly Receipt and Inspection. -

2.3 The following systems are capable of supporting refueling operations.

2.3.1 Reactor Coolant System OP 2301 2.3.2 Shutdown Cooling System OP 2310 2.3.3 Low Pressure Safety Injection OP 2307 i 2.3.4 High Pressure Safety Injection OP 2308 2.3.5 Refueling Water Storage Tank OP 2350 OP 2312 YJ 2.3.6 Containment i

'T 2.3.7 Fuel Handling OP 2303 2.3.8 Chemical Volume Control OP 2304 2.3e9 Reactor Building Closed Cooling Water OP 2330A 2.3.10 Service Water OP 2326 2.3.11 Instrument Air OP 2332B

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2.3.12 Station Air OP 2332A 2.3.13 Clean Liquid Radwaste OP 2335 l 2.3.14 Aerated Liquid Radwaste OP 2336 l Makeup Water OP 2340

!2.3.15 .

2.3.16 Fire Protection OP 2341

OP 22 Page 4 Rev. c Date: 11/28/77 2.3.17 Spent Fuel Pool Cooling OP 2305 2.3.18 Sampling System OP 2311 2.3.19 Plant Communications OP 2348 2.3.20 Station Electrical 4.16KV' Bus.24C er D OP 2343 2.3.21 Station Electrical 480V Bus 22E or F OP 2344 2.3.22 120V Regulated Instrument AC OP 2345A 2.3.23 120V Vital Instrument AC OP 2345B 2.3.24 125 'VDC OP 2345C 2.3.25 Emergency Diesel Generator A or B OP 2346 g 2.3.26 Nuclear Instrumentation Wide Range OP 2401 .

l (r Log Channels 2.3.27 Process & Area Radiation Monitoring OP 2404A & B V 2.3.28 Engineered Safeguards Actuation .OP 2405 2.3.29 Containment Recirculation, Cooling & OP 2313 Ventilation Systems 2.3.30 Main Exhaust OP 2314A 2.3.31 Containment & Enclosure Building Purge OP 2314B '

2.3.32 Radwaste(Aux. Bldg.) OP 2314C 2.3.33 Fuel Handling Area OP 2314F 2.3.34 Enclosure Bldg. Filtration OP 2314G 2.3.35 06ntrol Room Air Conditioning OP 2315 2.4 The cor.:sinment area radiation and airborne radiation monitors l shall be operable during the refueling operation. (Tech.

Spec.3.9.9)  ;

2.5 The containment purge valve isolation system shall be operable duri.ng refueling operations. (Tech. Spec. 3.9.10) l 2.6 Containment penetrations shall be in the following status:

2.6.1 Equipment door in plam ed bolted.

2.6.2 At least one door *'4 e a personnel airlock secured.

l 2.6.3 Each penetratiet p'w ing direct access from the j containment ata spne.w chall be:

1. Closed by an isolation valve, blind flange or a manual valve; or j 2. ' Be capable of being closed by an operable l containment purge valve.

OP 22 Page 5 Rev. Date: 11/28/77 2.7 .The containment evacuation alaic shall be satisfactorily tested from panel C04 within one day prior to refueling.

2.8 Prior to initiating fuel movemerit ensure proper operation and interlock operability of the followi~ng refueling equipment is -

verified:

2.8.1 Refueling Machine (Preoperational Check List OPSForm2303-1) 2.8.2 Transfer System (Preoperational Check List OPS Fom 2303-2) 2.8.3 CEA Change Machine (Preoperational Check List .

OPS Fonn 2303-3) 2.8.4 Spent Fuel Pool Platform Crane (Preoperational Check List OPS Fonn 2303-4) 2.8.5 New Fuel Elevator (Preoperational Check List OPS Form 2303-5) 2.8.6 Communications Circuit 2.8.7 AlignmentofT.V. Camera (OPSForm2303-7)  :

2.8.8 Alignent of Refueling Machine (OPS Form 2303-8) I 2.8.9 Spent Fuel Cask Crane (Preoperational Check List y OPS Form 2303-9) l 2.8.10 Spent Fuel Inspection Ecuipment (Preoperational Check List OPS Form 2303-10) i 2.9 All personnel who will participate in the refueling operation have been briefed and are thoroughly familiar with this, procedure, j and the Fuel Handling Procedure, OP 2303.

2.10 Refuelitig work list has been properly initiated. l g4 311 A complete checkout, includi.ng a load test (Sury. Proc. 2637A), I

()+b shall be conducted on the refueling machine crane with 3 days prior to the start of moving fuel assemblies. (Tech. Spec.

3.9.6) 2.12 Auxiliary building doors specified in Tech. Spec. Table 3.9-1 shall be closed and the spent fuel area shall be exhausted through the EBFAS in the auxiliary exhaust mode. (Tech. Spec.

! 3.9.14 and 3.9.15) l l

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OP 220 a Pag 2 6 Rev. Date:11/28/77 2.13 One off-site power supply and one emergency diesel shall be operational during refueling operati6ns. (Tech. Spec.

3.8.1.2) 2.14 The minimum AC and DC electrical distribution (inplant) specified in Tech. Specs. 3.8.2.2 and 0.8.2.4 shall'be maintained during the refueling operation.

2.15 At least one charging pump or one HpSI pump shall be operational during the refueling operation. (Tech. Spec. 3.1.2.3) 2.16 A minimum of one shutdown cooling loop shall be operable duri.ng refueling operations. (Tech. Spec. 3.9.8) .

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2.17 At least one flow path to the core for boric acid injection and its associated heat tracing shall be maintained during the refueling operation. (Tech. Spec. 3.1.2.1) 2.18 At least two spent fuel storage pool area radiation monitors and b'oth the gaseous and particulate spent fuel storage pool ventilation monitors shall be operable. _(Tech. Spec.3.9.13)

3. ~1NITIAL CONDITIONS .

3.1 Reactor coolant boron concentration is being maintained unifonn and of sufficient concentration to ensure keff is less than 0.90 with all rods inserted.

3.2 Reactor coolant system temperature is maintained greater than 82*F by the shutd?wn cooling system.

3.3 The chemical volume control system is lined up for normal operation in accordance with OP 2304 (CVCS) with the following exceptions: ,

3.3.1 Charging pumps secured. Handswitches in the off a position on C0-2 and green stripe caution tagged.

3.3.2 System filled with borated water at a concentration equal to or greater than the concentration of the reactor coolant system.

3.3.3 Volume control tank at normal operating level.

3.3.4 Let down flow secured. 2-CH-515 and 2-CH-516 shut and red tagged.

OP 22 Page 7

. Rev. Date:11/28/77 3.3.5 Reactor coolant pump controlled bleed off isolated.

2-CH-505 and 2-CH-506 shut and red tagged.

3.3.6 VCT is pressurized to 5 PSIG with nitrogen.

l 3.4 To prevent the addition of unborated water to the reactor j

oolant system, the following valves are shut and red tagged.  !

1) 2-CS-10A PMW to RWST 2-CH-195, PMW TO RCS Makeup 2) 2-CH-422 PMW to CVCS Demin. j 3)

4) 2-CH-080 PMW to CVCS Flush '

5) 2-PMW-167 PMW to Spent Fuel Pool

6) 2-RW-77 PMW to SEP Demin.

3.5 Reactor coolant pump breakers are racked out and red tagged.

3.6 Pressurizer heater breakers are racked out and red tagged.

3.7 RCS hot leg drain valves 2-RC-215 and 040 are shut and caution tagged. Inaccurate refueling leve'. will result if opened.

3.8 Spent fuel pool and transfer canal filled with borated water with a concentration equal to or greater than reactor coolant system concentration and spent fuel pool cooling system in operation.

3.9 Minimum shift complement during refueling is four (4) persons.

A licensed Unit 2 SR0 shall be in direct charge of refueling operations in the reactor fuelir; area. In addition, there-shall be at least one licensed f.0 in the control room and one licensed Unit 2 SRO in the station not directly involved in supervising fuel loading.

4. PRECAUTIONS 4.1 Whenever core. geometry is being changed, neutron flux shall be continuously monitored by at least two source range neutron inonitors, wi$ each monitor providing continuous visual indication in the control room, and one with audible indication in containment.

(Tech. Spec.3.9.2) 4.2 During reacto.r vessel head removal and while refueling operations are being performed in the reactor, the reactor coolant system t

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OP 22 Page 8 (V

R;v. . Date: 11/28/77 boron concentration must be maintained uniform and of a I sufficient concentration to ensure k'e ff is less than 0.90 with h11 rods inseited. (Tech. Spec.3.9.1) l 4.3 Direct communication between personnel in the control room and at the refueling machine shall be maintained during fuel movement within the reactor pressure vessel. (Tech. Spec.

3.9.5) 4.4 A minimum of 23 feet of water shall be maintained above the top of the fuel in the core whenever irradiated fuel is being handled in the core area. A minimum of 23 feet of water shall be maintained above the top of the fuel in the spent fuel storage racks whenever irradiated fuel is being handled in the spent fuel pool.

4.5 To ensure proper fuel positioning, the refueling machine must be realigned prior to loading fuel if the core support barrel had been moved.

4.6 Loads greater than that of a fuel assembly and CEA shall be prohibited from travel over irradiated fuel in the spent fuel pool. (Tech. Spec.3.9.7) 4.7 Movement of irradiated fuel in the core shall not be initiated before the reactor core'has decayed for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(Tech. Spec.3.9.3) 4.8 If an excessive or unanticipated count; rate multiplication, i.e., doubling, is indicated at any time, fuel handling will cease until the situation has been evaluated by the shift supervisor and reactor engineering persoanel.

4.9 Movement of fuel assemblies, control elem\nt assemblies or sources is not allowed without knowledge ahd approval of the r

, control room licensed operator. )

4.10 If a fuel assembly, CEA or source is belieked to be damaged.

.the fuel handling will cease. The reactor angineer will be notified and an inspection and evaluation i; to be made on the component.

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OP22ga Paga 9 d Rev. N -

Date: 11/28/77 4.11 Throughout fueling operations the refueling machine operator must be extremely careful to prevent an inadvertent driving of

. .the TV camera or hoist box into the core support barrel. To.

. minimize the possibility of such an occurrence, the refueling work list indicates allowable refueling mast positions.

4.12 Health Physics' procedures must be strictly adhered to at all

. times.

4'.13 Loa'ds greater than that of a fuel assembly and CEA shall be prohibited from travel over irradiated fuel in the vessel with the head removed, without approval of higher management. .

5. PROCEDURE 5.1 Preparing the reactor vesrel and cavity for refueling.

5.1.1 Purge the containment in accordance with OP 23148 (ContainmentandEnclosureBuil'dingPurge).

5.1'. 2 Enter the containment in accordance with HPP 2920 (ContainmentEntrance).

NOTE: Steps 5.1.3 through 5.1.5 may be done concurrently with only restrictions as per MP 2704.

5.1.3 Drain the reactor vessel toil 2" below the vessel flangeinaccordancewithOPS2301E(Drainingthe RCS). \

5.1.4 Prepare the reactor vessel he for removal in accordance with MP 2704A (Prepa tion for Reactor Vessel Head Removal).

5.1.5 Install refueling pool seal in ac'ordance with MP 2704B (Installation of Refueling P ol Seal).

5.1.6 Remove reactor vessel head in accoryance with MP 2704C (Reactor Vessel Head Removal). {

5.1.7 Remove blind flange from transfer tu 1.

. 5.1.8 Fill the reactor cavity to 31'6" leve in accordance

.' with OP 2307 (Low Pressure Safety Inf tion).

5.1.9 Uncouple the CEA extension shafts in 2 :cordance with MP2704D(UncouplingCEAExtensionShz[ts).

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. OP 2 Page 10

. Rev. .

Date: 11/28/77 5.1.10 Prr..te to remove the upper guide structure in accc Cance with MP 2704F, Steps 5.1 through 5.11 (RemvvalofUpperGuideStructure).

5.1.11 Remove incore instrument assembly in accordance with

• MP 2704E (Removal of 1C1 Assembly).

5.1.12 Fill reactor cavity to 36'6" level in accordance withOP2307(LowPressureSafetyInjection).

5.1.13 Complete removal of. upper guide structure in accordance with MP 2704F (Removal of Upper Guide Strr :ture).

5.1.14 Place the refueling pool skimmer system in operation.

in accordance with OP 2305 Section 7.7 (Spent Fuel Pool Cooling and Purification System).

NOTE: The following step is optional, depending on water clarity.

5.1.15 Place the spent fuel pool purification system in service on the refueling pool in accordance with OP 2305 Section 7.8 (Spent Fuel Pool Cooling and -

Purification).

5.1.16 Verify spent fuel pool level and refueling pool level are at the same level and greater than 35'6",

then open the transfer tube -isolation valve.

~5.1.17 If not .already operating, place the spent fuel pool skimer system in operation in accordance with OP 2305 (Spent Fuel Pool Cooling and Purification).

5.1.18 Handle all core components in accordance with OP 2303 (Fuel Handling) and the refueling worklist.

5.2 Refueling operation - control room operating personnel.

5.2.1 Direct and approve all core component movement during the refueling operation.

NOTE: The refueling worklist contains a step by step refueling sequence (material transfer forms).

5.2.2 Receive notification of core component movement and acknowledhe such notification by, step No., component serial numbers, originating location, present i location and orientation of the kefueling machine mast, if applicable. i i

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OP 22 n P:ge 11 O

Rev. 2 Date: 11/28/7:

5.2.3 Maintain an up to date status of material transfer l

fonns. Initial and note date and time (as executor) l after each completed step. (Refueling Worklist) 5.2.4 Maintain the count rate data log (OPS Form 2209A-2).

Log counts hourly, even during periods when refueling operations have been interrupted.

5.2.5 Stop.any fuel handling movement imediately if any j discrepancy is noted or for reasons of safety and  ;

immediately notify shift supervisor.

5.2.6 Maintain direct communications with refueling area -

l and fuel storage area at all times while hand 11ng  ;

fuel.

5.2.7 Ensure Chemistry Dept, samples the reactor coolant system boron concentrat. ion at least daily.

5.3 Refueling operation - refueling area operating personnel.

5.3.1 Move all components under the directica of the control room and in accordance with material transfer

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forms. (Refueling Worklist) 5.3.2 Operate all fuel handling equipment in accordance with OP 2303 (Fuel Handling System).

5.3.3 Notify control room of completion of each applicable step, including step No., component serial number, or,iginating location, present location and orientation

. of refueling machine mast, if applicable.

5.3.4 Notify control room of the following:

5.3.4.1 Receipt of a fuel bundle from spent fuel storage area via transfer carriage.

. 5.3.4.2 Holding a fuel bundle over a core location prior to insertion into the core.

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. .. 5. 3 5. 3 full insertica of the fuel bundle.into the

. core.

5.3.4.4 Unlatching the fuel bundle.

5.3.4.5 Initiati.ng transfer of fuel bundle to spent fuel area.

2209A Page 12

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.2' Date: 11/28/77 5.3.5 Obtain permission from control room prior to transporting fuel from containment to spent fuel area via transfer carriage.

5.3.6 Initial and note date and time after completion of each applicable step on the material transfer form (refueling machine operator will sign as Executor, SRO or RE as SNM checker).

5.3.7 ' Immediately notify control room if any discrepancies are discovered.

5.4 Refueling operation - fuel storage area operating personnel.

5.4.1 Move all components under the direction of the control room and in accordance with the material transfer forms. (Refueli.ng Worklist) 5.4.2 Operate all fuel handling equipment in accordance with OP 2303 (Fuel Handling System).

5.4.3 Notify control room of the following:

5.4.3.1 When over a fuel assembly in the spent fuel storage /new fuel storage racks, prior to latching, stating step number, component serial number and fuel storage rack location.

5.4.3.2 After the completion of each applicable

. step (Refueling Worklist) by step number, component serial number, originating location and present location.

5.4.3.3 Receipt of a fuel bundle from refueling cavity area via transfer carriage.

5.4.4 Obtain pennission from control rocm to transfer a ,-

core component to the refueling cavity via transfer ,

carriage. Notify control room when transfer is complete and receive acknowledgement.

5.4.5 Immediately notify control room if any discrepancy is discovered.

5.4.6 Initial and note date and time after completion of

' each applicable step on the material transfer form (spent fuel machine operator will sign as Executor,

.REasSNMchecker). .

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OP22g Rev. 2 Pagm 13 Date: 11/28/77 5.5 Refueling operation - reactor engineering personnel.

5.5.1 Monitor count rate activity.

5.5.2 Maintain current entries in reactor engineers leg.

5.5.3 Monitor entire refueling operation to include spot checks of each area and review of all data.

, 5.5.4 Resolve any questions of discrepancies concerning refue'ing.

5.5.5 Keep the unit reactor engineer apprised of tha stat.us of refueling. .

5.5.6 Stop refueling operations at any time for reasons of' safety.

5.5.7 Maintain the tag board to reflect status of all' fuel assemblies, control element assemblies and sources.

5.6 Returning the reactor coolant system to a cold shutdown condition.

5.6.1 Verify the post refueling verification check has been completed. (Refueling Worklist) ,

5.6.2 Transfer the transfer carriage to the spent fuel pool transfer canal for storage.

CAUTION: If the spent fuel purifict. tion system is to remain in operation on refueli.ng pool, ensure it is lined up for operation with the transfer tute isolation valve shut. Ensure spent fuel pool cooling system is lined up for operation with transfer tibe isolation valve shut. (Refer to OP 2305, Spent Fuel Cooling

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'and Purification.) .

5.6.3 Install spent fuel pool. gate. .

5.6.4 Shut fuel transfer tube isolation valve.

5.6.5 Install the upper guide structure in accordance with MP 2704I (Installation of UGS) Steps 5.1 through 5.5. .

5.6.6 Secure the refuel pool skimmer system OP 2305 (Spent

. Fuel Pool Cooling and Purification). l 5.6.7 Drain the refuel pool to the 31'6" level (to clear the operating platform of the UGS lift, assembly) in

0 09A Page 14

, Rev. 2 Date: 11/28/77 accordance with OP 2305 Section 7.9 (Spent Fuel Pool Cooling and Purification). For an alternate method

.of draining refer to OP 2307 Section 7.3 (Low Pressure SafetyInjection). -

5.6.8 Install the incore instrument assembly in accordance with MP 2704J (Installation of I.C.I. Assembly).

5.6.9 Complete installation of upper guide structure in accordance with MP 2704I (Installation of UGS).

5.6.10 Couple the CEA extension shafts in accordance with MP 2704K (Coupling the CEA Extension Shafts). ,

5.6.11 Drain the refuel pool in accordance with OP 230S Section 7.9 (Spent Fuel Pool Cooling and Purification).

For alternate method of draining, refer to OP 2307 Section 7.3 (Low Pressure Safety ~ Injection).

5.6.12 Install blind flange on transfer tube. Perfonn leak detection test on fuel transfer tube in accordance with Surveillance Procedure 2609B (Local Leak Detection  ;

Test). -

1 5.6.13 Drain the reactor vessel to 12 inches below the reactor vessel flange in accordance with OP 2301E l (DrainingtheRCS).

5.6.14 Install the reactor vessel head in accordance with MP 2704L (Reactor Vessel Head Installation).

5.6.15 Remove the refueling pool seal in accordance with MP 2704M (Removal of Refueling Pool Seal).

5.6.16 Complete the reactor vessel head installation in accordance with MP 2704N (Completion of Reactor

. Vessel Head Installation).

5.6.17 . Fill and vent the reactor coolant system in accordance with OP 2301D (Reactor Coolant System Fill and Vent).

5.6.18 Perform the reactor coolant system liak rate test in accordance with OP 2301B (Reactor Coolant System LeakRateTest).

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6. CHECK OFF LISTS 6.1 None ,

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