ML20008G110

Requests Extension of Submittal Dates to 811101 & 820301 for Responses to NRC Re Control of Heavy Loads, Per NUREG-0612.Implementation of Interim Measures Projected by Apr 1982

ML20008G110
Person / Time
Site:	Calvert Cliffs
Issue date:	06/25/1981
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0612, RTR-NUREG-612 NUDOCS 8107020280
Download: ML20008G110 (3)

Text

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BALTIM ORE GAS AND LECTRI CHARLES CENTER.P.O. BOX 1475. BALTIMORE, MARYLAND 21203 v1eIp,,$.

June 25, 1981 h PPLY Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

'Jashington, D.C.

20555 Attention:

Mr. D. G. Eisenhut, Director Division of Licensing

Subject:

Calvert Cliffs Nuclear Power Plant Units Nos. 1 & 2, Docket Nos. 50-317 and 50-318 Control of Heavy Loads

Reference:

NRC letters dated December 22, 1980 (forwarding NUREG 0612) and February 3, 1981 from Eisenhut to All Licencees of Operating Plants Gentlemen:

This is to review the status of our study of measures taken to control the movement of heavy loads at Calvert Cliffs and our progress toward implemen-tation of the Interim Measures as requested in your December 22, 1980, letter.

Also, it is the purpose of this letter to request an extension of the submittal dates for the reports requested by that letter.

Background

After a preliminary staff study of your m rectives and NUREG 0612, it was determined that the scope of work necessary to conduct an adequate heavy loads review would involse close coordination among several departments within our Company. A Working Group was established consisting of members from our engineering, perations, maintenance, and quality assurance organizations to conduct this review.

We also initiated a contract with an architect-engineering firm as a consultant to assist us in this evaluation.

Following the receipt of your December 22, 1980, letter, a second letter, dated February 3,1981, was receite.1 which forwarded several pages which had been missing from the former letter and extended one of the implementation dates to account for the omission. There was considerable contusion within our Company as to just which date(s) were extended. Subsequent telephone conversations between your staff and ours left us with the understanding that the submittal dates for This understanding was the six month and nine month reports were also extended.

further clarified during an industry meeting cn hUREG 0612 held at Florida Power dates had not

& Light Company where nembers of your staff stated that the report been officially modified but that the NRC would entertain specific requests for extensions on a case-by-case basis.

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Mr. D. G. Eieenhut June 25, 1981 The following provides our request for such an extension and also addresses the status of implementation for the Interim Measures per your December 22, 1980, letter.

Request for Extension Due to the misunderstanding of schedule described above and to the press of other high priority tasks, we will be unable to complete this work as required.

Therefore, it is requested that an extension of submittal dates for the six month and nine month reports be granted as follows:

November 1, 1981 - Submittal of information identified in Section 2.1 of Enclosure 3 of December 22, 1980, letter.

>2rch 1, 1982

- Submittal of information identified in Sections 2.2, 2.3, and 2.4 of above enclorure.

Also, an extension of the implementation date for the Interin Measures of your December 22, 1980, letter is requested. We are committing to the full implementation of all Interim Measures (discussed below) prior to our next re-fueling outage in April 1982.

Interim Measures Status As described below, not all of the Interim Measures have been completed.

We have assigned a priority to this task to ensure that all appropriate requirc-ments are met before specific heavy loads are permitted to be lif ted.

Our basic approach to assessing heavy load lifting operations is to assure public health and safety by decreasing the probability that such a load could fall and the prob-ability that radioactive releases could occur if the load did fall.

Interim Measure 1 Safe load paths should be defined per the guidelines of Section 5.1.1(1).

Status: Heavy loads have been identified for each overhead cranc.

Each of these I

heavy loads has been reviewed to determine if the load must pass over the l

reactor, the spent fuel pool, equipment associated with safe shutdown, or equipment required for heat removal geners'ed from decay of spent fuel, Safe load paths have been defined for most of the critical heavy loads.

i Fuel handling operations are being examined to define the safe load paths, l

and work is continuing to complete this Interim Measure with the objective that safe load paths will be defined before a critical heavy lift is made.

Interim Measure 2 Procedures should he developed and implemented for the guidelines of Section 5.1.1(2).

Status: Many of the critical hecvy loads were already covered by written proce-dures, and each of these procedures is being reviewed and revised as necessary.

In addition, procedures are being developed for those criti-cal heavy loads not having them. We will have a written procedure for each critical heavy load before such a lift is allowed.

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Mr. D. G. Eissnhut June 25, 1981 l

- Interim Measure 3 Crane operators should be trained, qualified, and conduct themselves per the guidelines of Section 5.1.l(3).

Status: The training program for crane operators is being reviewed to verify its adequacy and to incorporate any necessary modifications. Crane operators have been trained using a program developed by the National Inspection and Certification Bureau.

Only operators so trained are permitted to operate crancs. These operators are designated by name on a shop / lab memo.

Interim Measure 4 l

Cranes should be inspected, tested, and maintained in accordance with l

the guidelines of Section 5.1.1(6).

Status: There is an inspection and maintenance program in existence. This pro-j gram is being evaluated against the guidelines.

Inspection and mainte-n tnce are being reviewed to ensure that proper documentation exists.

Cranes will be reinspected where such reports are not available.

Interim Measure 5 Special attention to procedures, equipment and personnel for the han-dling of heavy loads over the core, such as vessel internals and vessel inspection tools.

Status: Review is. underway to. identify those specific loads that merit such spe-cial attention. Most of these loads are associated with a refueling operation.

t Yf you have any questions on this matter, please call us.

We will assume, in the interim that our proposed dates are acceptable.

Very truly yours, 4.

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FMA:jch cc:

J. A. Eiddison

- C. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr. - NRC R. E. Architzel - NRC a

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