ML20002C058

Forwards Addl Info in Response to Section 5.1.1 of NUREG-0612.Info Supersedes 801107 Submittal.Detailed Review of Other Sections of NUREG-0612 Will Be Documented in 6-month Rept

ML20002C058
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/02/1981
From:	Tramm T COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NUDOCS 8101090038
Download: ML20002C058 (17)

Text

,

h Commonwe lth Edison

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) One First Nabonal s'tata. Chicago. Ilhntus

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Address Reply to: Post Othce Box 767 Chicago, lihnois 60690 N

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fo January 2, 1981 W

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m Mr. Harold R.

Denton, Director Ee9

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Of fice of Nuclear Reactor Regulation W

y U.S. Nuclear Regulatory Commission g

x Washington, DC 20555 Subj e ct :

Zion Station Units 1 and 2 Control of Heavy Loads Near Spent Fuel NRC Do cket Nos. 50-295 and 50-304 References (a):

July 31, 1980 letter from D.

G.

Eisenhut to D.

L.

Peoples (b):

November 7, l>80 letter from T. R.

Tramm to H. R. Denton

Dear Mr. Denton:

Reference (b) transmitted a report of our review of controls for handling heavy loads near spent fuel at Zion.

During the review of that report the NRC Staf f has found that additional information is necessary.

A cco rdingly, Attachment A to this letter supercedes Attachment A to Reference (b).

A complete response to each question is being submitted to avoid confusion.

Some responses remain unchanged, others have been supplemented or clarified.

The drawings referenced are not being resubmitted.

In general, we conclude that heavy loads are being handled safely at Zion and that such operations are or will be consistent with the guidelines contained in Se ction 5.1.1 of NUREG-0612 to the extent p r a cti cable. to this letter addresses areas in which safe load handlin yg i achieved by alternate means.

More detailed review of-other sections of Enclosure 1 to Reference (a) is to be docuemnted in the request ~eij six-month report.

/

One (1) original and thirty-nine (39) cooies of this letter are included for your use.

Please address fur';ier questions to this of fice.

Very trul yours

[

T. - R.

Tramm

/

Nuclear Licensing Administrator Pressurized Water Reactors cc:

RIII Inspector - tion S. P.

Carfagno, Franklin Research Center 810109008

ATTACHMENT A.

Partial Response to Request for Additional Information on Control of Heavy Loads l

2.1 General Requirements for Overhead Handling Systems Request 1:

Report the results of your review of plant arrangements to identify all overhead handling systems f rom which a load drop may result in damage to any system required for plant shutdown 2

or decay heat removal (taking no credit for any interlocks, 4

te chni cal spe ci fi cations, operating procedures, or detailed structural analysis).

Response 1:

The cranes and trolleys identified throughout the plant that handle loads in areas where equipment for shutdown or decay heat removal is located are listed below by building.

Containment Polar crane Underhung hand geared bridge crane (1 ton capacity) i Manipulator crane Fuel Handling Building Fuel building crane Fuel handling bridge Auxiliary Building 2-ton trolley attached to rail at 666' 0" elevation at roof of auxiliary building.

Diesel Generator Room 2-ton trolley attached to two 10-ton monorails. running the full length of each side of each diesel generator.

Crib House 10-ton hoist attached to 16-ton monorail I-beam at 646' 11 3/4" elevation on roof of crib nouse.

Request 2:

Justify the ex clusion o any overhead handling system from the above category by verifying that there is sufficient physical separation from any load-inpact point and any safety-related component to permit a determination by inspection that no heavy load drop can result in damage to any system or component required for plant shutdown or core decay heat removal.

. Response 2:

The turbine building crane and MSR removal trolleys were ex cluded f rom item 1 above since no system or compone n t required for plant shutdown or core decay heat removal is located in this building.

The radwaste crane and maintenance shop crane also are not listed since they are completely removed f rom the area of safe shutdown or decay heat removal equipment by con cre te walls.

The two 4-ton monorails between the fuel building and the auxiliary building (one on Unit I side, one on Unit 2 side) do not have hoists physically attached to them, are separated f rom safety-related equipment by concrete walls, and physically f ar enough away f rom the spent fuel poui (approximately 40') to preclude consideration of dropping a load into the pool or damaging spent fuel.

The two 25-ton monorails at the S92'0" elevation of the auxiliary building in front of the elevator (running in the east-west direction) do not have hoists physically attached and are so low (approx.

7' off the floor) that a physical inspection of the area confirms that no safe shutdown or decay heat removal component could be damaged by a load i

drop.

Request 3:

With respect to the design and operation of heavy load l

handling systems in the containment and the spent fuel pool area and those load handling systems identified in 2.1-1, l

above, provide your evaluation concerning compliance with l

the guidelines of NUREG-0612, Se ct ion S.1.1.

The following specific information should be included in your reply:

Request 3a:

Drawings or sketches suf ficient to clearly identify-the location of safe load paths, spent fuel, and safety-related equipment.

t I

l Response 3a:

The prints below were provided with the previous submittal i

dated November 7.,

1980.

l l

MS-16 Holst load path - Crib House MS-681 Holst load path - Plan Main Floor el. 642'0" l

MS-682 Polar Crane load paths - Plan Mezz. Floor el. 617'0" l

i MS-683 Diesel Gen. Room Holst' load path - Plan ground l

floor el. 592'0".

l

. These drawings have load paths clearly marked and the nearby equipment is also identified.

Heavy loads drop analysis and safe load path information concerning the fuel handling building have been previously submitted to the NRC in the 4-8-76 letter from R.L.

Bolger to A. Schwencer, 9-14-76 letter f rom R.L. Bolger to A.

S chwen ce r, and the 8-9-77 letter from D.E. O'Brien to A.

S chwen ce r.

Request 3b:

A discussion of measures taken to ensure that load handling operations remain within safe load paths, including p ro cedu re s, if any, for deviation from these paths.

Response 3b:

Loads moved in the areas defined in Section 5.1.1 (1) are listed in attached Table 3-1.

The procedures governing the assembly / disassembly and movements of these loads are also i

listed.

Loads number 1 through 9 are covered by maintenance department procedures.

These procedures allow the movement of the loads from only one point to another.

While the paths for these movements are not explicitly stated in the p ro cedu re s, the movements follow the safest and shortest i

routes.

These routes are shown in the sketches listed in l

the response to Request 3a above.

This practice is consistent with the company 's general safety rules and practices.

These safety rules are an integral part of Zion Station's Maintenance Department Administrative Instructions (MDAI's) under which all maintenance work is performed.

Also, this work is performed by maintenance nuclear mechanics and " A" men who are supervised by maintenance foremen.

These personnel L

have achieved these positions by demonstrating their craf t knowledge and ability in performing the required work.

Loads are thus handled along safe paths under the control of experienced personnel according to established rules.

l As indicated in Attachment B, specific prohibitions against handling loads over the reactor vessel are being added to l

the plant procedures.

If the analyses requested by the NRC indicates that other controls are appropriate, they will be addressed in the six-month report.

. Request 3c:

A tabulation of heavy loads to be handled by each crane which includes the load identification, load weight, its I

designated lif ting device, and verification that the handling of such load is governed by a written procedure containing, as a minimum, the information identified in NUREG-0612, Se ction 5.1.1 (2).

The attached Table 3-1 lists the cranes and the loads normally handled by ea ch.

i Table 3-1 indicates the written rocedures that govern the handling of each load.

These procedures generally in clude sections such as Equipment Description, Purpose, Re f e ren ce s,

Initial Plant and/or cumponent Conditions, Pre caut ions / Limitations in addition to the step by step instructions.

The procedures being used meet the intent of Se cton 5.1.1 (2) of NUREG-0612.

Restrictions on loads in the vicinity of the spent fuel pit are also stateo in the Corgosite Licenses for the Zion Units.

For applicable loads that will be moved in the future for whi ch no procedure is now in e f fe ct (i.e., reactor vessel lower internals), a procedure will be developeo prior to the movement of such a load.

i Specific load handling devices are identified below:

i Rx vessel head lifting rig l

RCP tripod Upper internals lifting rig-Lower internals lifting rig Request 3d:

Verification that lif ting devices identified in 2.1.3-c, above, comply with the requirements of ANSI 14.6-1978, or ANSI B30.9-1971 as appropriate. -For lif ting devices where these' standards, as supplemented by NUREG-0612, Se ction 5.1.1 (4) or 5.1.1 (5), are not met, describe any proposed alternatives and demonstrate their equivalency in terms of-load-handling I

reliability.

Response 3d:

This equipment was designed according to industrial standards using good engineering practices.

L

. l A review of calculations for design of the Reactor Vessel Head Lif t Rig indicates that the calculations were based on using 1/5 of the ultimate material allowable stresses for lifting the dead weight of the assembled head.

Using todays AISC standards, applicable to the weakest design point of the structure, (i.e.

the sling block) p rodu ce s a f actor of safety of 1.93.

Using the actual material test report yield strength of 45.2KSI results in a f actor of safety of greater than 2.0 at the sling b lo ck.

All other areas of the design pravide a factor of safety of at least 2.0.

The design calculation for the Internals Lif t rigs also showed that they were based on 1/5 of the ultimate material allowable stresses over the dead weight of the internals.

A dynamic load factor applied to the weight of the lif t is 2 for the reactor coolant pump motor tripod.

Design stresses are as specified in ASME Section III, Appendix XVII.

l-Fittings for the above lift rigs were selected such that the load does not exceed 5 times the breaking strength of the fitting.The RCP motor lif ting cable and the 17-ton shield blocks slings used at the station comply with ANSI 830.9-1971.

This in cludes, use, maintenan ce, and storage.

The RCP motor lif ting cable is an 8 part braided rope of 6 x 19 construction using 1" diameter improved plow steel grade component ropes, and is rated at approximately 50 tons.

A 50 ton shackle is used to attach this cable to the tripod.

This shackle is manufactured in accordance with Federal Specification RR-C-271 and has a safety factor of 5.

4-1" 6 x 19 classification improved plow steel grade ropes with independent wire rope cores make up the bridle sling for lif ting the shield blocks.

This allows a load lift of.24 tons.

A 26 ton shackle is used to attach the shield block sling to the hook.

This shackle also meets Federal Specification RR-C-271-and has a Safety factor of 5.

Request 3e:

Verification that ANSI B30.2-1976, Chapter 2-2, has been invoked with respect to crane inspection, testing, and maintenance.

Where any ex ception is.taken to this standard, su f fi cient information should be provided to demonstrate the equivalency of proposed alternatives.

. Response 3e:

The crane inspection, main tenan ce, and operating procedures are all based upon ANSI B30.2-1976, and Section 179 of 29CFR1910.

Request 3f:

Verification that crane design complies with the guidelines of CMAA Specification 70 and Chapter 2-1 of ANSI B30.2-1976, including the demonstration of equivalency of actual design requirements for instances where specific compliance with these standards is not provided Response 3f:

The cranes used at Zion Station were purchased to the Sargent &

Lundy Spe cification for Electric Overhead Traveling Bridge Cranes, Form 2808, which is based on the American Institute of Steel Construction Specifications and tha Electri c Overhead Crane Institute, Inc. Specifications and USAS Safety Code B30.2.0-1967.

A comparison of the requirements of Form 2808 to the CMAA70-1975 Specification is shown in Table 3-3.

This Table 3-3 ano the following discussion shows that the Zion crane pro curement spe ci fi ca t ion, Form 2806, meets the intent of CHAA-70:

1)

Impact Force:

The Electric Overhead Crane Institute's (EOCI) specification which was referenced in Form 2808, requires a design force equal to 15% of the rated capa ci t y of the crane.

The CMAA #70-1975 specifies that the impact load be 1/2% load X Hoist Speed in feet per minute and that the impact should not be less than 15% or greater than 50%

of the rated capa ci ty.

Therefore, the Zion cranes have been procured to a criteria which conforms to the requirements of CMAA specification for hoist speed less than 30 ft/ min.

Both the polar crane and the Fuel Handling Building cranes have hoist speed of 5 ft/ min or less.

Therefore, those craees satisfy CMAA-70-1975.

2)

Compressive Stress:

As shown in Table 3-3, the. allowable compre ssiva stress specified in Form 2808 is identical to those specified by CMAA-70-1975 for members with non-slender compressiv a flange.

A comparison of the allowable compressive stress criteria given in Form 2808 and CMAA-1975 is shown in Figure 3-1.

The box girders for the polar crane and the fuel handling building crane in l

Zion have a b/c ratio of 11 and 24, re spe ctively.

For l

these b/c ratios, these structural elements meet the requirements of CMAA-70-1975.

l

. i Request 3g:

Ex cep t ions, i f any, taken to ANSI B30.2-1976 with respe ct to operator training, qua li fi ca tion, and condu ct. Response 3g:

l The crane operators for the Maintenance are all

'B' category union personnel.

The polar crane can only be operated by

'A' union personnel who have demonstrated their capability through on-the-job pe r forman ce.

The fuel handling crane operators receive a ref resher course in crane operations prior to every refueling outage.

This is seminar type training administrated by the senior fuel handling foremen.

1 It has been determined that our current training program does comply with ANSB30.2-1976, but, as stated'previously, our committment is to 1.tode a reference to Chapters 2-3 of ANSI 830.2-1976 in our current program and to provide a review of

.e end of the training session.

We do not

]

that document at feel this will change our program but will provide a review of the course and ANSI B30.2-1976 at its end.

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Table 3-1 LOADS PROCEDURE

1) Reactor Vessel Head

1) RC001-1 " Reactor Vessel and Lifting Rig Head Installation" RC001-4 " Reactor Vessel Head Removal"

2) Reactor Upper Internals

2) RC001-5 " Removal of Reactor and Lifting Rig Vessel Upper Internals" RC001-6 " Installation af Reactor Vessel Upper Internals"

3) Reactor Lower Internals

3) No procedure now. Will be and Lifting Rig developed when needed.

4) Reactor Coolant Pump Motor

4) P/RC110/410-6N

" Inspect / Adjust Reactor Coolant Pump Motor"

5) Reactor Coolant Pu g

5) P/RC110/410-1N

" Reactor Coolant Pug Seal Inspection / Replacement"

6) Shield Blocks

6) RC001-1 and RC001-4

7) Reactor Vessel Head Studs

7) RC001-1 and RC001-4 and Stud Hydraulic Tensors

8) Service Water Pump and Motor

8) SW001-1 "Disassemoly/Asseroly of Layne Bowler Service Water Pump"

9) Equipment Hatch and

9) P/PP000-2N Missile Shields

" Removal and Installation of Equipment Hatch"

10) Spent Fuel

10) FHI-23

11) New Fuel

11) FHI-02 l

FHI-14 FHI-33

12) Fuel Handling Equipment 12)

A) Spent Fuel Assemoly A) FHI-19 Handling Tool B) Thimole Plug Assemoly

8) FHI-20 Handling Tool C) Rod Control Cluster C) FHI-21 Change Fixture

0) Full Length Control Rod

0) FHI-26 Orive Shaft Unlatching Tool

Table 3-1 (Cont'd)

LOADS PROCEOURE E) Irradiation Sample Handling E) FHI-30 Tool F) Burnacle Poison Rod Assembly F) FHI-31 Handling Tool G) Guide Tube Cover Handling G) FHI-32 Tool H) New Fuel Assemoly Handling H) FHI-33 Tool I) Rod Control Cluster Changing I) FHI-37 Tool J) Manipulator Crane J) FHI-13 K) Fuel Transfer System Operation K) FHI-12

13) Spent Fuel Handling and Shipment

13) FHI-23

14) Site Removal of New Assenclies

14) FHI-02 from Shipping Containers and Handling of Shipping Containers

l TABLE 3-2 ZION STATION - UNITS 1&2 CRANES AND HOISTS, Load Load Crane / Hoist Identification Location Loads Carried Weight Path RPV Head 73.5T See Polar Crane 225T Main Hook Each Containment. Rail Elevation 617'-O" RPV Upper MS-682 Internals 60T 35T Aux. Hook RPV Lower Internals 170T lRC Pump Motor 3GT

RC Pump 51T

' Concrete Slabs 17T.

i RX vessel head

.5T Same as RPV Underhung Hand Each Containment on permanent rails studs.

head.

Geared Bridge over the reactor cavitv.

2 work baskets.

.125T Along cavity Crane - 1. ton (In p' lace only during " refueling).

walls when head k N*c g *,7 "himbio ni mm OMT i

5:aintenance Each Containment over reactor Spent. fuel

.8T Reactor cavit.

Bridge cavity.

assy's.

New fnel assy's.

.8T Reactor cavity 1 ton Fuel handling l. 2T Reactor caeitc

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tools.

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' Fuel Handling Fuel Handling Builcing. Rail Spent Fuel Cask 100T See Fig. 1 gg Building Crane Elevation 643'-0". Col. Ecws New Fuel Contain 3T I in 7/14/76 125T Main Hook R-W/17-23

,ers.

letter.

c::::5 15T Aux. Hook l

55 g g Spent Fuel Spent fuel building over spent

Spent fuel

.8T In spent fuel fuel pool.

assy's.

pool.

c -o Bridge New fuel

.8T 1 ton

.assy's.

Cr Fuel tools

.2T In RX cavity.

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Table 3-2 1

• Load Load I

Crane / Hoist Loads Carried Weight Path Location I-Identification 2T Trooley Auxiliary Building in each Diesel k Diesel Genera-2T See Generator Room.

Approx. Rail tor.

MS-683 Elevation 615'-O".

Parts 2T Trolley Auxiliary Building. Approx. Rail Elevation 666'-0". Col. How N/18-20 Equipment 2T See i

Removal MS-681

{ GT

'. Crib House. Rail Zievation 646'-11 3/4".

Rcceval Slab See e

10T Trolley l

Row CC-BB/101-113 SW Pump ST MS-16 SW Pump Motor 7.5T I

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s Table 3-3

'OVZRIIEAD AND CANTRY C1%*ES CO!1PARISON OF STRUCTURAL DESIGN CRITORIA ZIO:. 1 & 2 f

(3)

Structural All wable stresses (ksi)

Itoisting

Non -S t ruc t.

'a uirements Structural.

Cor.pression(2)

Rope j:. cad Sc 'tri:

Denien Forces gg,c1

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S ecifications Impact = I Lateral l Material l Tension Shear Bearing Rated Cap. Capacity i

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C".AA Spec #70 1.

bs Lead x 2b% of ASTM-A36 17.6 17.6 for b/c 13.2 l26.4 20s 206 Ocpyright 1975 (floist Speed (Live Load l

f 38 ru l t ir.a -

Cl.:ss A1 (Standby in Feet / Min)

+ Dridge)

Breaking

.Sertice) l l

Strength 2.

15 % ( I (50s i

I of rated i

capacity.

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f Zion Crane (1)

I=15% of the 5s of (Live i ASTM-A36 17.6 17.6 for b/c 11.2' 21.6,

20%

20s Precureront Rated Capacity i Load +'

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.IS C Breaking !,

T.J 1 t ina t.

I Bridge) l

' Fitte,d Strength ji i

' Specification,

Form 7803

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t Notes g

(1) Based on 1.1 tires the allowables of ECCI ~61, Class A Service or b

b 0.8 Tires the allowables of AISC (>th 2dition) and use of A36 Steel.

M (2) b = Distance between web plates (inches) c = Thickness of top cover plate (inches) 11/25/80 C

(3) Fult = Published average ultirate stress of esterial E ch N

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AliACHMENT 8 Summary of Review of Load Handling Operations at Zion f

with Respect to Se ction 5.1.1 o f NUREG-0612

~

l A review of Section 5.11 of NUREG 0612 has shown that the Zion Station is substantially in compliance.

Only five(5) points of deviation are discernable and these are itemized below.

These points are expanded upon in the specific question area of this response.

1)

In item 1) of paragraph 5.1.1 of NUREG 0612, Safe Load Paths, a requirement is made for clearly marking load paths on the floor in the area where the load is to be handled.

2)

Also, deviations from defined load paths should require alternative procedures approved by the plant safety review committee.

Dis cussion :

Loads are moved by the safest and shortest paths as shown on the Zion drawings MS-16, 681, 682, and 683 previously submitted.

Because no deviations are allowed' from the load paths identified on the drawings, no alternate procedures are required.

l Due to the configuration of the. load-paths (e.g. the load path for the RCP is from the pump deck up to the 617' level then over grating to its lay down area; the 'se rv i ce wa te r pump motors are removed through the roof of the crib house l

and moved across the roof) it is.not apparent that marking l

load paths on the floor is generally feasible or would contribute to reactor safety.

s 3)

In Item 2) o f pa ragraph 5.1.1. of NUREG' 0612, Pro cedu r e s, E l

requirement is made for defining the safe load path in the p ro cedu re s.

j Dis cussion:

Zion maintenance procedures are controlled by administration procedures (MDAl's).

To comply with the above item, Commonwealth Edison will addithe following paragraph, to the administrative procedures:

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"All loads inside containment shall be moved by straight line or shortest path to its lay down area.

No load shall be moved over the Rx vessel ex cept the following items during their removal or installation:

ductwork fan plenum assembly missil; shield blocks missi'.e shield block support beams J

CRDM equipment" The applicable maintenance procedure provides the proper sequence for these movements.

Should the analysis of Zion for compliance to paragraphs 5.1.2, 5.1.3, 5.1.4 (due 1/21/81) show additional area spe cific noncompliances, we are prepared to revise the procedures further to ensure that they are in complete compliance.

4)

In Item 3) of paragraph 5.1.1 of NUREG 0612, Crane Operators, a requirement is made for training and qualifying crane operators in accordance with Chapters 2-3 of ANSI B30.2-1976.

Dis cuss ion :

A review of the Zion crane operator training program has shown that is does comply with Chapters 2-3 of ANSI B30.2-1976 and provides plant specific crane operator training, both in the classroom and with actual crane operation.

This training is followed with a written quiz and an operational evaluation of the individual crane operator's knowledge.

1 However, to insure that the intent of the specific questior i

is met, we will include a reference to Chapters 2-3 of ANS:

i B30.2-1976 in our current program, and will provide a review of that document at the end of the training session.

5)

In Item 5) of paragraph 5.1.1 of NUREG 0612, Spe cial Lif ting Devices, a requirement is made for satisfying the guidelines of ANSI N14.6-1978.

Paragraph 3.2.1 states tha-the load bearing members of a special lif ting device shall be capable of lif ting three times the combined weight of the shipping container plus the weight of intervening components.

They shall also be capable of lif ting 'five _

times that weight without exceeding the ultimate strength of the materials.

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_3 Dis cus sion :

Lif ting devices at Zion were designed to be capable of lif ting five times the load without ex ceeding the ultimate strength of the materials.

The design safety f actor is twc not three as required by ANSI N14.6.

Since ANSI N14.6 did not exist at the time of Zion design, good engineering practice was used, and a safety f actor of 2 was considered to be adequate.

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