ML20053E108
| ML20053E108 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/02/1982 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR LIC-82-224, NUDOCS 8206070616 | |
| Download: ML20053E108 (33) | |
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Omaha Public Power District 1623 HARNEY e 9
OMAHA, NEBRASMA 68102 e TELEPHONE 536 4000 AREA CODE 402 June 2, 1982 LIC-82-?24 Mr. Robert A. Clark, Chief U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch No. 3 Washington, D.C. 20555
Reference:
Docket No. 50-285
Dear Mr. Clark:
Control of Heavy Loads In November,1981, Mr. Tourigny of your staff forwarded a draft Technical Evaluation Report (TER-C5257-94) to Omaha Public Power Dis-trict for comment. The TER reported the results of Franklin Research Center's (FRC's) assessment of the Fort Calhoun Station's heavy load handling capabilities. Please find enclosed the District's response to each of FRC's comments in the TER.
It should be noted that some of the detailed information requested is not available and only some could be developed through additional detailed and costly analysis. The District believes that, based upon our ten years of operational experience and the existence of commonly accepted design and manufacturing practices for cranes at the time of manufacture, the unavailability of this information is not a significant concern, as discussed in the enclosed responses. The District is not considerino further action on this issue, pending further review by the Commission.
Sincerely, j b W.C./ Jones Division Manager Production Operations
[ 03 3 f' ,
Enclosure cc: LeBoeuf, Larr.b, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C. 20036 8206070616 820602 p DR ADOCK 05000285 PDR
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- Comments to FRC's Evaluation Section 2.1.1 Overhead Heavy Load Handling Systems FRC Comment:
Criteria for the implementation of these phases are contained in Section 5.1 of NUREG-0612: Phase 1 is contained in Section 5.1.1.; Phase II is cont 'ned in Sections 5.1.2 through 5.1.5. All handling systems which handle heavy loads in the area of the rer. tor vessel, spent fuel pool, or over safe shutdown equipment should satisfy the general guidelines requirements. Based upon this, FRC does not concur with the Licensee's exclusion of the two concrete slab removal cranes, the waste evaporator equipment handling crane, the deborating demineralizer area crane, and the intake structure crane.
The requirements of NUREG-0612 Sections 5.1.2 through 5.1.5 provide for the identification of the need for additional design features (e.g., a single -
failure-proof crane) for cranes in those areas. For the cranes the Licensee has excluded from satisfying NUREG-0612, the existence of intervening floors may eliminate the need for providing single-failure proof cranes; however, the Licensee is not exempt from satisfying the general guidelines of Section 5.1.1 for each of these cranes. Therefore, the Licensee should include these cranes on the list of overhead heavy load handling systems which are evaluated in accordance with these general guidelines.
OPPD Response:
The Intake Structure Crane, Waste Evaporator Crane, Deborating Demineralizer Area Crane, and the two Concrete Slab Removal cranes are included in the Section 2.1.1 response and is addressed accordingly in each subsection below.
Section 2.1.2 Safe Load Paths [ Guideline 1, NUREG-0612, Article 5.1.1(1)]
FRC Comment:
The Fort Calhoun Station does not satisfy the safe load path criteria of Guide-line 1. Although the Licensee believes that the restrictions placed on the polar and auxiliary building cranes minimize the potential for damage due to a load drop, these restrictions do not satisfy the requirement that safe load paths be defined for each heavy load handled in the vicinity of safe shutdown equipment or irradiated fuel.
The Licensee does not satisfy the requirement that safe load paths be clearly marked on the floor.
The Licensee partially satisfies the requirements concerning deviations from defined load paths since deviations from restrictions placed on the polar and auxiliary building cranes require Plant Review Committee approval. However, the Licensee must still address deviations from individual safe load paths.
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The Licensee did not submit sufficient information to allow FRC to determine whether load paths follow structural floor members.
The Fort Calhoun Station does not comply with the criteria of Guideline 1. The Licensee should develop a program by which each individual heavy load is handled in accordance with the safe load path criteria (i.e., safe load paths are defined in procedures, follow structural members, are defined in equipment arrangement drawings, and are clearly marked, and deviations are properly controlled).
OPPD Response:
a) Definition and marking of load paths:
The District contends that we do meet the intent of the criteria in Guideline 1.
The safe load paths are defined in the load handling procedures, wherein all paths with the exception of the restricted areas are censidered equally accept-able. By defining a safe load path (area) for all loads, this is equivalent to defining a safe load path for each load. For example, the Polar crane is cur-rently restricted from operating over the reactor (unless removing the Vessel head and internals). This area has been indicated in plant layout drawings which were submitted with oar original Section 2.1 response. These drawings will be incorporated into the load har.dling procedures. Similarly, the Auxiliary Build-ing crane is limited from moving over the spent fuel pool area. Since all other
, areas except for the restricted areas defined above are safe load path areas, defining individual load paths is not necessary.
NUREG-0612 states that the load paths should follow structural members. This, in our opinion would result in increased complexity and greater operator stress and as such may result in higher probability of a load drop due to operator error.
As to the actual physical marking of the load paths on the floor, no provision is being made to physically mark these paths. However, other indications of safe load path boundaries are provided. In the Containment the Polar crane is operated from a pendant control station. The operator would not have full visual access to
, follow each individual marking, due to the irregularities of the floors and walls.
l It would be confusing to try and follow a physically marked load path. This could
- increase the probability of a load drop occuring. Further, marking of the load
- paths in Containment is not feasible since markings in the reactor cavity could 4 contaminate the reactor coolant and such marking could be incompatible to the Stainless Steel liner in a boric acid environment. Also, markings on the crane bridge would have to be reversible (symmetric).
With respect to the Auxiliary Building Crane, this crane operates without res-triction except over the spent fuel pool. The unrestricted area does not extend over any safe shutdown equipment or irradiated fuel. The Auxiliary Building l crane safe load path boundary (the Spent Fuel Pool) is visually evident to the l crane operator since the sides of the pool are elevated 13.5' above the sur-rounding floor level.
Safe Load Paths for the Monorails is a moot issue, since there is only one possi-ble load path for these cranes (Waste Evaporator, Deborating Demineralizer, and Concrete Slab Removal cranes). ,
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For the Intake Structure crane, the District believes that marking load paths along the structural members would add to the complexity of load handling and thereby increase the possibility of a load drop accident due to increased opera-tor stress.
The only safety related equipment in the intake structure are Raw Water Pumps and associated piping, valves and cabling. Raw Water pumps are not required for Hot Shutdown. However, two pumps will be required to achieve cold shut-down following a load drop accident. As indicated in our response to sections 2.4.2a of NUREG-0612, a load drop accident in most parts of the Intake Structure will not effect more than one Raw Water Pump. The only area where a load drop may result in failure of all Raw Water Pumps is the area bounded by columns D-D and C-C by rows 102 and 105, an area of about 650 sq. f t. this represents 15% of the whole crane accessibility. A load drop accident in this area may result in failure of power and control cables of the Raw Water Pumps. Considering that the Intake Structure Crane is very rarely used for handling of heavy loads and the area where the load drop could result in failure of all raw water pumps is only 15% of the total crane accessiblity area, the probability of a load drop accident resulting in failure of raw water pumps is very insignificant. Also, the Raw Water Pumps will not be required for approximately eight (8) hours following an accident and repairs can be made in a reasonable time to affect cold shutdown. In addition, fire pumps can be used as a backup.
It is, therefore, our conclusion that marking of load paths in the Intake Struc-ture would not improve plant safety and would create unnecessary restrictions on load handling possibly increasing the probability of load drop accidents due to increased operator stress and as such we request an exemption from meeting this requirement,
- b. Deviation from Load Paths:
This item has been addressed by plant procedures. Any deviations from the established plant procedures, which define load paths by exclusion, require PRC approval. This would be equivalent to handling deviations from individual load paths. In addition to the area restrictions placed on the Polar Crane, this crane is restricted in operation over the reactor core, additional restrictions are made to minimize the height of the lift, and prohibit polar crane operation when the reactor coolant system temperature is greater than 225 F. (Thus ensuring that equipment will not be damaged which could inhibit the plants capability to l Safely Shutdown.)
Deviations from safe load paths for monorails is not addressable since these hoists cannot deviate from their path.
There is no deviation from a safe load path in the Intake Structures since all i
areas are considered equally safe.
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Section 2.1.3 Load Handling Procedures [ Guideline 2, NUREG-0612, Article 5.1.1.(2)]
FRC Comment:
The Fort Calhoun Station partially satisfies the criteria of Guideline 2, on the basis of the Licensee's verification of compliance with Section 5.1.1(2) of NUREG-0612 with the exceptions that the safe load paths have not been defined in the procedures and no procedures have been developed for the spent fuel shipping cask. Since the review by FRC constitutes the only comprehensive evaluation of load handling practice at the Fort Calhoun Station, all issues should be resolved either by compliance or by instituting the recommended corrective actons within a reasonable period of time so that no items will be deferred to a future un-specified date.
The Fort Calhoun Station partially complies with the criteria of Guideline 2.
To comply fully, the Licensee should ensure that safe load paths are defined in procedures for handling heavy loads and that procedures are developed for handl-ing the spent fuel shipping cask.
OPPD RESPONSE:
At this time the District does not have a shipping cask. A procedure will be written when utilizing the shipping cask becomes necessary. The intent of NUREG-0612, Guideline 5.1.1(2) will be met when the procedure is written.
Section 2.1.4 Crane Operator Training [ Guideline 3, NUREG-0612, Article 5.1.1(3)]
FRC Comment:
The crane operator training and qualification program that will be implemented at the Fort Calhoun Station will fully satisfy the Criteria of Guidelines 3.
OPPD RESPONSE:
With respect to Polar crane and Aux. Bldg. crane, Fort Calhoun is in complete compliance with the NUREG-0612 requirements.
ANSI B30.2 code does not specify that operators of monorail cranes be trained or qualified and as such this requirement is not applicable to monorail operators.
Operators for the Intake Structure crane are not trained in accordance with ANSI B30.2. However, as explained earlier the probability of a load drop accident which could result in failure of Raw Water Pumps is very small as such we would
- like to take exception to the requirement of retrainir.g the intake structure crane operator in accordance with ANSI B30.2.
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Section 2.1.5 Special Lifting Devices [ Guideline 4, NUREG-0612, Article 5.1.1(4)]
FRC Comment:
No information was provided for FRC to evaluate whether specially designed lifting devices at the Fort Calhoun Station meet the criteria of ANSI 14.6-1978.
OPPD Response:
The Fort Calhoun Station Lift Rigs identified in our previous response to Section 2.1 were designed and purchased in 1968. At that time no special industry stand-ards existed for the design of lifting rigs. The steel members and components were designed in accordance with the guidelines of the American Institute of Steel Construction (AISC), Edition 6. This code does not provide detailed guide-lines pertaining to the design of the lift rigs but does provide sufficient requirements to achieve a safe design of steel components.
We have evaluated all items of the ANSI Code relating to our lift rigs, as re-quested by the FRC. We have searched our files and contacted our vendor to obtain the necessary data for the design of the lift rigs. In some cases, the vendor has shown his inability to provide the information pertaining to some of the items required by ANSI Code, due to lack of information available in vendor's files or lack of time.
Our response to these items are as follows:
ANSI N14.6-1978 Reactor Closure Upper Guide Structure Section Reference Head Lift Rig Lift Rig Section 3.1 3.1.1 Limitations on the Used only for reactor Used only for Upper use of the lifting device. vessel head Guide Structure 3.1.2 Identification of All components are con- All components are critical components and de- sidered critical com- considered critical.
finition of critical charac- ponents.
teristics.
3.1.3 Signed stress Information verified Unable to address analyses, demonstrating from CE report S/102/P for lack of infor-appropriate margins of dated Aug. 24, '70. mation from the safety. See Table #1, in Appendix. vendor. Marginsof safety were in accor-dance with AISC, 6th Edition.
3.1.4 Indication of per- No repairs are contem- No repairs are missible repair procedures. plated so no procedures contemplated so no are available. procedures are available Section 3.2 5
ANSI N14.6-1978 Reactor Closure Upper Guide Structure Section Reference Head Lift Rig Lift Rig 3.2.1 Use of stress design See Table #1, Appendix Unable to address for '
factors of 3 for minimum yield lack of information strength and 5 for ultimate from the vendor, strength.
3.2.4 Similar stress de- Complies Unable to address for sign factors for load bearing See Table #1 Appendix lack of information pins, links, and adapters. from the vendor.
3.2.5 Slings used comply Complies Complies with ANSI B30.9 3.2.6 Subject materials to Unable to address for Unable to address for dead weight test or charpy lack of information lack of information impact test. from the vendor, from the vendor Section 3.3 3.3.1 Consideration of prob- Unable to address for Unable to address lems related to possible lamel- lack of information from lack of information lar tearing. vendor, from vendor.
3.3.4 Design shall assure Complies (CE Report) Unable to address for even distribution of the load lack of information from vendor. However, the AISC, 6th Edition requires that design shall assure even distribution of the load.
3.3.5 Retainers fitted for Unable to address due to Unable to address due load carrying components which lack of information from to lack of information may become inadvertently dis- the vendor. from the vendor.
engaged.
Section 4.1 4.1.3 Verify selection and Materials verified from Materials verified l use of materials the list indicated on from the list indi-drawings cated on drawings 4.1.4 Compliance with fab- Fabricated in accordance Fabricated in rication practice, with AISC, 6th Edition. accordance with AISC 6th Edition.
4.1.5 Qualification of Unable to address due to Unable to address welders, procedures, and lack of information from due to lack of infor-operators. the vendor. mation from the vendor.
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ANSI N14.6-1978 Reactor Closure Upper Guide Structure Section Reference Head Lift Rig Lift Rig 4.1.6 Provisions for a Unable to address due to Unable to address quality assurance program. lack of information from due to lack of infor-the vendor, mation from the vendor.
4.1.7 Provisions for identi- Unable to address due to Unable to address fication and certification of lack of information from due to lack of infor-equipment. the vendor, mation from the vendor.
4.1.8 Verification that Unable to address due to Unable to address materials or services are lack of information from due to lack of infor-produced under appropriate the vendor, mation from the controls and qualifications.
Section 5.1 5.1.3 Implementation of By procedure visually By procedure visually a periodic testing schedule and inspect prior to use inspect prior to use a system to indicate date of expiration.
5.1.4 Provisions for estab- Procedures for use of Procedure MP-RC-7-2 lishing operating procedures. Lift rigs, are detailed guidelines for use in the removal of RCVH of UGS Lift Rig procedure #MP-RC-6-1, RC-6-2 5.1.5.1 Identification of Subassemblies may not be Subassemblies may subassemblies which may be exchanged not be exchanged exchanged.
5.1.5.1 Suitable markings Complies Complies 5.1.6 Maintaining a full This requirement is being This requirement is record of history met as follows: being met as follows:
a) This device is used to a) This device is used lift the Reactor Vessel to lift the Upper head, only. Guide Structure, only.
b) The lift rig is qualified b) The lift rig is for this load. qualified for this c) The lift rig is visually load.
instected prior to every c) The lift rig is lift. visually inspected d) The lift rig is used prior to every lift.
twice during the refueling d) The lift rig is outage only. used twice during the retueling outage only.
5.1.7 Conditions for removal Subject to visual Subject to visual from service. inspection inspection 7
ANSI N14.6-1978 Reactor Closure Upper Guide Structure Section Reference Head Lift Rig Lift Rig Section 5.2 5.2.1 Load test to 150% and Load tests was not per- Tested to 125%
appropriate inspections prior formed. Inspected prior to to initial use. However, the lifting rigs use have been inspected and used to its rated loads for over ten years without any defect.
5.2.2 Qualification of re- No program established for qualification placement parts of replacement parts.
Section 5.3 5.3.1 Satisfying annual load Inspected prior to use every 1.25-1.5 yrs test or inspection requirements, depending upon frequency of refueling.
5.3.2 Testing following No procedures for testing after major maintenance major maintenance 5.3.4 Testing after app 12- No procedure for testing after substantial stress cation of substantial stress 5.3.6 Inspections by operat- Inspections are performed by quality control ing personnel personnel 5.3.7 Non operating or main- Not applicabic tenance personnel As indicated above, most of the design data available has shown that the lift rigs designed, in accordance with AISC, 6th Edition do comply with the intent of the ANSI Code. We were unable to address some of the items, either due to lack of informacion available to us or the guidelines were not required by the code at that time.
l In some areas such as load testing the load tests were not performed because AISC, 6th Edition did not require it. However, the lifting rigs have been inspected and used to it's rated load capacity over ten years without any identified defects.
The District believes our operating experience demonstrates there is sufficient justification that the load testing could be waived. Regarding quality assurance j and fabrication procedures, we could not provide enough information as no docu-ments were available in our files.
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1 The critical items, such as the design stresses, inspection and testing are addressed in our response. We believe that they meet the intent of the ANSI N14.6 Code, which is namely to provide good engineering. We acknowledge that we could not address properly, the areas dealing with documentation control due to lack of the information available to us. However, it has been demon-strated that safe engineering practices were used in the design of the rigs and lack of documentation does not affect the safety and performance of the lift rigs.
In light of the above, we believe exceptions to some of the items listed by the FRC are justified.
Special Lift Rigs are not used with the monorails or the Intake Structure Crane.
Section 2.1.6 Lifting Devices (Not Specially Designed) (Guideline 5, NUREG-0612, Article 5.1.1(5))
j FRC Comment:
The Licensee did not provide information to allow FRC to evaluate whether the lifting device not specially designed meet ANSI B30.9-1971.
OPPD Response: Lif ting Devices that are not Specially Designed Slings are in-stalled and used in accordance with ANSI B30.9 - 1971. This includes dynamic and static loading.
Section 2.1.7 Cranes (Inspection, Testing, and Maintenance) (Guideline 6, NUREG-0612, Article 5.1.1(6))
FRC Commenc:
2 The Licensee has developed a program of crane inspection, testing, and main-tenance which satisfies the criteria of Guideline 6.
OPPD Response:
With regard to the Polar Crane and Aux Bldg. Crane we are in compliance with criteria of Guideline 6.
i The monorails are not required to be inspected by the ANSI B30.2 code. However, the monorails are inspected annually and nondestructive testing of the crane hooks are performed at that time also.
I l The Intake Structure Crane is not presently required to be inspected by the ANSI B30.2 code, but it is inspected and maintained semi-annually, with annual nondestructive testing of the crane hook. Testing is performed which meets the intent of the ANSI code thus we would take exception to applying the ANSI criteria to this crane.
Section 2.1.8, Crane Design (Guideline 7, NUREG-0612, Article 5.1.1(7))
FRC Comment:
The auxiliary building crane satisfies the criteria of Guideline 7 on the basis of the Licensee's verification that the crane is currently being retrofitted and has been designed to meet ANSI B30.2-1976 and CMAA-70.
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The polar crane substantially satisifies the criteria of Guideline 7 on the l basis of the Licensee's verification that this crane conforms to the requirements of the industry standards that were applicable when it was built and meets the 1
majority of current CMAA-70 standards. The Licensee's evaluation of existing 1 crane design indicates that the values for hoist speed (less than 6 feet per minute) and b/c ratio (24) are within the limits of, and ti.erefore satisfy, CMAA-70 criteria for impact allowance and compressive stress. However, in-formation supplied by the Licensee is insufficient to allow FRC to determine
- if the installed polar crane hoisting rope meets the breaking strength require-ments of CMAA-70.
FRC has compared the recommendations of CMAA-70 against those of EOCI-61 and has indentified several additional areas where revisions incorporated into CMAA-70 which may affect crane safety have not been specifically addressed by the Licensee. The Licensee should evaluate these areas to determine whether the intent of Guideline 7 of NUREG-0612 is satisifed. The following CMAA-70 issues should be addressed in the Licensee's review.
FRC Comment:
1 1. Nonsymmetrical girder sections were not used.
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- 2. Any longitudinal stiffeners in use conform to the requirements of CMAA-70 and allowable h/t ratios in box girders using these stiffeners do not exceed those specified in CMAA-70.
- 3. Fatigue failure was considered in crane design and the number of design loading cycles at or near rated load was less than 20,000.
- 4. Drum design calculations were based on the combination of crushing and bending loads.
- 5. Drum groove depth and pitch substantially conform to the recommendations of CMAA-70.
- 6. A cab-control, cab-on-trolley, configuration was not used.
- 7. Either a mechanical load brake was used or hoist holding brakes have l torque ratings in excess of the hoist motor torque (approximately 125%).
- 8. Crane operation under load near the end of bridge or trolley travel either is not allowed or is compensated for by bumpers and stops in substantial conformance to the requirements of CMAA-70.
- 9. Static control systems were not used or substantially conform to the requirements of CMAA-70.
- 10. Spring-return or momentary-contact pushbutton controllers were used or controllers are equipped with a device which disconnects all motors on power failure and will not permit restart until the controller handle is brought to the OFF position.
- 11. Maximum crane load weight plus the weight of the bottom block, divided by number of parts of rope, does not exceed 20% of the manufacturer's published breaking strength.
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i OPPD Response:
j The FRC has requested that we address each item as listed above and supply them
, with verification as to our compliance and noncompliance.
The District has evaluated the polar crane design as per FRC's recommendations, i
and have concluded that some of these items cannot be addressed for lack of information from our vendor. We have contacted the Polar Crane vendor and have been advised that to supply the equired information would take at least three (3) months. Ilowever we can answer most of the FRC's concers. The following items are addressed:
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- 1. Nonsymmetrical girders were not used.
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- 2. Longitudinal Stiffeners a) h/t = 240 Complies with CMAA-70, allowable h/t - 236 b) As shown in attachment 1, Moment of inertia for the polar crane is 8.34 IN4 which is 5.1% less than the CHAA-70 required moment of inertia of 8.796 IN . 4The moment of inertia required by CMAA-70 is 20% more than required by E0CI-61. The polar crane was designed ,
in accordance with E0CI-61. In our judgement a 5.1% less moment of inertia is considered acceptable.
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Thus the crane design meets the requirements of CMAA-70, Article 3.3.3.1, longitudinal stiffeners. *(See calculation sheets Appendix for justifier _ ton)
- 3. Fatigue Failures The Polar Crane is used to lift loads less than its design condition on a 2 lifts per refueling basis. Thus the near design loading cycle is not even close to the 20,000 frequency cycles limit for stress evaluation listed i in the CHAA 70 code. Thus the requirements of the CHAA-70 code are not of l consequence to the design of the Polar Crane.
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- 4. Drum Design:
The District is not able to adress this item for lack of information from the vendor. However, since this crane was designed to _ the EOCI code, the
{ drum was designed to withstand maximum load bending and crushing. The i combination of the two was not part of the EOCI code, but we feel that the drum design meets the intent of the CHAA-70 code.
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- 5. Drum Design:
a) Drum groove depth (minimum required: .4688" - actual provided 0.75",
this meets the criteria of CHAA-70, Article 4.4.3) b) Drum pitch (minimum required: 1.41" actual provided 1.625") this complies with the CMAA-70 criteria, Artic1,e 4.4.3.
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- 6. Bridge Brake Design:
Our Polar Crane does not use cab-control, or cab-on-trolley control, thus we meet the criteria set forth.
- 7. Iloist Brake Design:
l We are unable to address this item for lack of information from the vendor.
However, since it was designed to EOCI criteria, the hoist holding brake torque rating is not less than 100% of the hoist motor torque. In our opinion the 100% rating provides a sufficient margin of safety and was considered good engineering practice.
- 8. Bumpers and Stops:
The bridge of the polar crane does not have bumpers such as this polar crane. The trolley however has both bumpers and stops near the end of trolley travel.
- 9. Static Control System:
Our polar crane uses static control systems, however, for lack of informa-tion from vendor, we are unable to address this item in comparison to the CIAA-70 code.
Since the crane was designed to E0CI criteria no specifications were made as to the design of static control systems. However, we believe that good engineering practices were used as indicated by the design factors listed above, they exemplify that the polar crane substantially conforms to most of the CMAA criteria, even though it was designed to EOCI-61 criteria.
- 10. Restart Protection:
Since our crane is equipped with momentary contact push buttons, no device is necessary that will disconnect all motors upon power failure.
- 11. Breaking Strength of Rope:
We have verified that the maximum crane load weight plus the weight of the bottom block, divided by the number of parts of rope, does not exceed 20% of the manufacturer's publishing breaking strength.
As shown above in our response to FRC's comments our polar crane design has shown that good engineering practices were used, and though not designed to CMAA-70 that it substantially meets the codes criteria.
We believe that in the cases where FRC comments could not be answered, that this polar crane does meet the intent of the CMAA code. We would like to take excep-tion to answering items 4, 7, 9 due to lack of information, and on the basis that not meeting these criteria does not indicate unsafe practices.
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A comparison of EOCI-61 and CHAA-70 for items 4 and 7 shows that only small dif-ferences exist between the two codes. llowever since E0CI-61 does not give guidance for the design of static control systems, we believe that safe engineer-ing was used as in the rest of the crane design.
The monorails and Intake Structure cranes were not designed to the CMAA-70 code or the ANSI B30.2 chapter 2.1 criteria. However the Intake Structure crane was designed to the EOC1-61 criteria. In regard to the design of the monorails, the CMAA-70 and ANSI B30.2 chapter 2.1 codes do not specify any criteria for their design.
As was shown for the Polar Crane, the crane design using the E0CI code sub-stantially conforms to the CHAA code thus meeting the intent of the CMAA code, and therefore we feel that since the Intake Structure Crane was designed to this code, that a point-by-point comparison will not be required.
SECTION 3, FRC Response: "The licensee made no statements or conclusions re-garding this (special reviews for heavy loads over the core) interim protection measures.
OPPD Response:
Attached is a copy of our interim protection measures which were implemented May 15, 1981.
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TABLE NO. 1
SUMMARY
OF STRESS LEVELS & SAFETY FACTORS IN IIEAD LIFT RIG COMPONENT PARTS REF: Combustion Engineering Calculation No. RS-102 dated August 24,'1970 and CE Letter No. CE-18074-989 dated June 30, 1981.
NORMAL MIN. MINIMUM RATIO = RATIO =
STRESS LOAD YIELD ULTIMATE ULT. STRESS / YLD. STRESS /-
ELEMENT CONDITION STRESS STRESS STRENGTil NATERIAL NOR. LOAD NOR. LOAD TRIPOD TENSION 5.1 37.5 75.0- A235-E 120*F 14.7 7.4 LIFTING EYE SIIEAR 5.3 21.6 50.0 A235-E 120*F 9.4 4.1 TRIPOD LIFTING TENSION 11.7 37.5 75.0 A235-E 120"F 6.4 3.2 EYE SilANK LIFTING SIIEAR 6.2 21.5 46.7 SA516-70 120*F 7.5 3.5 FRAME LUG BEARING 13.1 37.3 70.0 SA516-70 120 F 5.3 2.85*
PIN Sl! EAR 7.7 50.5 76.7 SA193 120*F 9.9 6.6 ROD TENSION 9.3 77.0 100.0 4340 120*F 10.7 8.3 SIIEAR (TilD.) 3.5 44.4 66.7 4340 120*F 19.0 12.7-CLEVIS SHEAR 3.9 20.4 46.7 SA105II 120*F 11.9 '
5.2 BEARING' 7.8 35.4 70.0 SA105II 120*F 8.9 4.5 TENSION 2.5 35.4 70.0 SA105II 120*F 28.0 14.2-PIPE AND COMPRESSION 3.5 60.0 SA106B 120*F 17.1 PIPE WELD SHEAR 2.1 29.1 48.0 SA233 E7015 22.8 13.9 TUBING TENSION 11.3 50.4 72.0 SA233 E7015 6.4 4.5 LIFTING BEARING 6.4 37.5 75.0 A235-E 120*F 11.7 5.9 EYE AND WELD SIIEAR 3.0 21.6 50.0 A235-E 120 F 16.7 7.2 TUBE AND TENSION 7.6 36.0 58.0 SA36 7.6 4.7 TUBE SilELL WELD SifEAR 12.8 29.1 48.0 SA233 3.7* 2.3*
SilELL TENSION 1.2 36.0 58.0 SA36 120*F <48.3 30.0
- The safety margins are lower than required by ANSI.N14.6-1978. However, the safety margins are not significantly lower than the required.
14
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At?ochment 2 OMAHA PUBLIC POWER DISTRICT'S INTERIM MEASURES FOR CONTROLLING HEAVY LOADS NRC Position: NUREG-0612 Safe load paths should be defined per the guidelines of Section 5.1.1(1).
5.1.1(1):
Safe load paths should be defined for the movement of heavy loads to minimize the potential for heavy loads, if dropped, to impact irradiated fuel in the reactor vessel and in the spent fuel pool, or to impact safe shutdown equipment, The path should follow, to the extent practical, structural floor members, beams,-etc., such that if the load is dropped, the structure is more likely to withstand the impact. These load paths should be defined in procedures, shown on equipment layout drawings, and clearly marked on the floor in the area where the load is to be handled. Devi-ations from defined load paths should require written alternative procedures approved by the plant safety review committee.
Response
The operating instruction for the containment polar crane (0I-HE-1) will provide the following restrictions:
- 1. The polar crane will not be used to carry loads over the reactor coolant system when the reactcr coolant system temper-ature exceeds 2250F. (Technical Specification 2.11(1)).
- 2. The polar crane will not be used to transport any load over the core when the reactor vessel head is removed without a Plant Review Comittee (PRC) approved procedure.
- 3. The polar crane will not be used to transport any load over the area bounded by containment columns 10 and 11 and the RC-2B biological shield without a PRC approved procedure pending the results of a load drop analysis. -
- 4. Loads should not be lif ted higher than necessary to safely clear obstacles along the load path.
The operating instruction for the auxiliary building crane (0I-HE-
- 5) will provide the following restriction:
- 1. The auxiliary building crane will not be operated over the spent fuel pool without a qualified crane supervisor present and a PRC approved procedure.
Discussion The restrictions on the containment polar crane operation given above provide for a safe load path by exclusion. The potential to impact irradiated fuel is minimized by allowing only necessary loads to be transported over the core, using a PRC approved procedure as detailed in Item 2 below. Safe shutdown equipment is defined by NUREG-0612 as-
" safety related equipment and associated subsystems that would be re-quired to bring'the plant to cold shutdown conditions or provide con-tinued decay heat removal following the dropping of (a) heavy load".
The above restrictions prohibit use of the polar crane unless the reactor is subcritical (except during low power physics testing below 2250F). Decay heat removal capability is assured by prohibiting trans-port of a heavy load over locations where a single load drop could 4- remove both HPSI and LPSI as decay heat removal paths unless an alter-native decay heat removal path is available. Safe shutdown and decay heat removal capability is therefore assured. Movement of the trolley over the core with no load on the hooks is allowed, since only a spnn-taneous failure of the cable or sheeves could cause a load drop in this mode. The possibility of this type of failure is minimized by the i preoperational inspections performed per Item 4 below.
1 The restrictions on the auxiliary building crane operation also provide a safe load path by exclusion. The potential to impact ir-radiated fuel is minimized by not allowing loads to be carried over irradiated fuel (Technical Specification 2.11(2)), and by allowing loads te be carried over the spent fuel pool only according to PRC approved procedure and under the direction of a qualified crane supervisor.
There is no safe shutdown equipment below any area accessible to the auxiliary building crane (see definition above).
The closest item of safe shutdown equipment is LPSI discharge piping. This piping is 72" north of the northern limit of crane travel. The maximum load dimensions able to be handled are restricted by floor access opening dimensions such that the piping is 16" north of the maximum load extent.
NRC Position: NUREG-0612 I Procedures should be developed and implemented per the guidelines of Section 5.1.1(2).
5.1.1(2):
Procedures should be developed to cover > load handling operations for heavy loads that are or could be handled over or in proximity to irradiated fuel or safe shutdown -equipment. At a minimum, procedures should cover handling of those loads listed in Table 3-
- 1 of this report. These procedures should include
- identification of required equipment; inspections and acceptance criteria required before movement of load; the steps and proper sequence to be followed in handling the load; defining the safe loa'd path; and other special precautiorr.
i
Response
Safe load paths for the polar crane and the auxiliary building crane are included in 01-HE-1 and 01-HE-5, as described in Item 1 above. The PRC approved procedures listed below will provide identi-fication of required equipment, inspections and acceptance critgria required before movement of the load, and steps and proper sequ 9ce to be followed in handling of the load:
Procedure Title MP-AE-4-1 Missile Shield Removal MP-AE-4-2 Missile Shield Replacement MP-FH-16-1 Removal of Spent Fuel Pool Gate MP-FH-16-2 Installation of Spent Fuel Pool Gate SP-NFR-2 Fuel Receipt Procedures MP-RC-6-1 Removal of Reactor. Vessel Closure Head MP-RC-6-2 Inspection and Replacement of Reactor Vessel Closure Head SP-RC-6-2 Upper Guide Structure Lif t Rig and ICI Plate Removal and Installation MP-RC-7-2-A Upper Guide Struc?.ure and ICI Plate Removal MP-RC-7-2-B Upper Guide Structure and ICI Plate Installation Special precautions are provided where necessary.
Procedures are also available for spent resin and filter disposal, but these do not address load handling since these loads are not carried over or in proximity to irradiated fuel or safe shutdown equipment.
Procedures for handling other heavy loads identified in Table 3.1-1 of NLIREG-0612 will be written and/or reviewed prior to handling of thosa heavy loads.
NRL Position: NUREG-0612 Crane operators should be trained, qualified and conduct themselves per the guidelines of Section 5.1.1(3).
5.1.1(3):
Crane operators should be trained, qualified and conduct themselves in accordance with Chapter 2-3 of ANSI B30.2-1976, " Overhead and Gantry Cranes".
Response
Standing Order M-8, " Control of Crane Operations". will require operators, signalmen, and supervisors of the containment polar crane and the auxiliary building crane to be trained and qualified, in accordance with ANSI B30.2-1976. Quality control administers qualification exer-cises and retains certifications. Currently qualified crane operators, signalmen, and rupervisors will be advised of new requirements resulting from NUREG-06)2.
NRC Position: NUREG-0612 Cranes should be inspected, tested and maintained in accordance with the guidelines of Section 5.1.1(6).
5.1.1(6):
The crane should be inspected, tested and maintained in accordance with Chzpter 2-2 of ANSI B30.2-1976, " Overhead and Gantry Cranes",
with the exception that tests and inspections should be performed prior to use where it is not practical to meet the frequencies of ANSI B30.2 for periodic inspection and test, or where frequency of crane use is less than the specified inspection and test frequency (e.g., the polar crane inside a PWR containment may only be used every 12 to 18 months during refueling operations, and is generally not accessible during power operation. ANSI B30.2, Sowever, calls for certain inspections to be performed daily or monthly. For such cranes having limited usage, the inspections, tests and maintenance should be performed prior to their use.)
Response
The auxiliary building crane and the containment polar crane will be inspected and maintained in accordance with ANSI B30.2-1976. The auxiliary building crane will be inspected daily or prior to each-use (whichever is less frequent) according to 01-HE-5, monthly as part of the preventive maintenance program, and annually according to MP-HE-5.
The polar crane will be inspected daily and monthly during use (re-fueling outages) according to MP-HE-1-B and MP-HE-1-A, and at refueling outage frequency according to MP-HE-1. Additional maintenance and inspections are performed as part of the preventive maintenance program and as prerequisites to specific critical lifts.
NRC Position: NUREG-0612 In addition to the above, special attention should be given to procedures, equipment, and personnel for the handling of heavy loads over the core, such as vessel internals or vessel inspection tools.
This special review should include the following for these loads: (1) review of_ procedures for installation of rigging or lifting devices and movement of the load to assure that sufficient detail is provided and that instructions are clear and concise; (2) visual inspections of load bearing components of cranes, slings, and special lifting devices to identify flaws or deficiencies that could lead to failure of the com-ponent; (3) appropriate repair and replacement of defective components; and (4) verify that the crane operators have been properly trained and are familiar with specific procedures used in handling these loads, e.g., hand signals, conduct of operations, and content of procedures.
Response
The procedures listed below have been specially reviewed and found satisfactory or procedure changes will be made as follows:
1.~
. Sufficient detail and clear and concise instructions will be provided.
d
- 2. Requirements for necessary inspectior.s will be-included.
- 3. Approval of load bearing components inspected per 2 above is required before performance of each procedure; therefore, appropriate repair of defective components will have been completed.
I 4. Only qualified crane operators are allowed to operate the l containment polar crane per 01-HE-1 and Standing Order M-8. '
Additionally, each of the listed procedures requires a job
' briefing prior to start of the procedure.
Procedure Title 4 MP-AE-4-1 Missile Shield Removal MP-AE-4-2 Missile Shield Replacement
, MP-RC-6-1 Removal of Reactor-Vessel Closure Head.
} MP-RC-6-2 Inspection and Replacement of Reactor Vessel Closure Head j -SP-RC-7-2 UGS Lift Rig and ICI Plate Removal and Installation MP-RC 2- A UGS and ICI Plate Removal MP-RC-7-2-3 UGS and ICI Plate Installation i
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