ML20076A768

Draft Control of Heavy Loads at Nuclear Power Plants, Waterford Generating Station,Unit 3,Louisiana Power & Lighting Co (Phase 1), Technical Evaluation Rept

ML20076A768
Person / Time
Site:	Waterford
Issue date:	05/31/1983
From:	Sekot J, Sekot Jp, Stickley T EG&G, INC.
To:	NRC
Shared Package
ML20076A770	List: ML20076A768
References
CON-FIN-A-6457, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR EGG-HS-6291, NUDOCS 8308180325
Download: ML20076A768 (34)

Text

_ _ __

. EGG-HS-6291 MAY 1983 CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS WATERFORD GENERATING STATION, UNIT 3 LOUISIANA POWER AND LIGHTING COMPANY (PHASE I)

DOCKET NO. 50-382 J. P. Sekot T. H. Stickley Idaho National Engineering Laboratory Operated by the U.S. Department of Energy

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CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS

- WATERFORD GENERATING STATION, UNIT 3 LOUISIANA POWER AND LIGHTING CCMPANY (Phase I)

Docket No. [50-382]

Author J. P. Sekot Principal Technical Investigator T. H. Stickley Published May 1983 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the

. U.S. Nuclear Regulatory Commission Under DCE Contract No. DE-AC07-76ID01570 FIN No. A6457

ABSTRACT The Nuclear Regulatory Commission (NRC) has requested that all nuclear plants, either operating or under construction, su'mit o a response of compliancy with NUREG-0612. " Control of Heavy Loads at Nuclear Power Plants." EG&G Idaho, Inc., has contracted with the NRC to evaluate the responses of those plants presently under construction. This report contains EG&G's evaluation and recommendations for the Louisiana Power and Light Company (LP&L) Waterford Generating Station, Unit 3 (WGS No. 3).

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EXECUTIVE

SUMMARY

WGS No. 3 does not totally comply with the guidelines of NUREG-0612.

An examination by EG&G Idaho of the applicants report and response indicate that, although several sections were well presented and developed, there is still an area of noncompliance, specifically special-lift devices. Programs or procedures have not yet been completed; however, commitment toward their completion has been indicated.

i' The main report contains recommendations which will aid in bringing the above items into compliance with the appropriate guidelines.

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CONTENTS AGSTRACT ............................................................. 11

!XECUTIVE

SUMMARY

............................................. ...... 111

1. INTRODUCTION ................................................. .. 1 1.1 Purpose of Review .................................. ...... I 1.2 Generic Background ........................................ 1 1.3 Pl ant-Speci fic Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2. EVALUATION AND RECOMMENDATIONS ...... ........................... 4 2.1 Overview .................................................. 4 2.2 Heavy Load Overhead Handling Systems ...................... 4 2.3 General Guidelines . ...................................... 11 2.4 Interim Protection Measures ........................ ...... 22

3. CONCLUDING

SUMMARY

.............................................. 24 3.1 Applicable Load-Handling Systems .......................... 24 3.2 Guideline Recommendations ................................. 24

4. REFERENCES ...................................................... 28 TABLES -

2.1 Overhead Handling Devices in Vicinity of Safe Shutdown Equipment, Waterford Generation Station Unit 3 .................. 5 2.2 Overhead Handling Services Excluded from Further Concern, Wate,rford Generating Station Unit 3 ............................. 7 2.3 Reactor Containment Building Polor Crane - WGS No. 3 . . . . . . . . . . . . 9 2.4 Fuel-Handling Building Bridge Crane - WGS No. 3 ................. 10 3.1 NUREG-0612 Compliance Matrix .................................... 27

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i CCNTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS WATERFORD GENERATING STATION. UNIT 3 (Phase I)

1. INTTsCDUCTION 1.1 Purcose of Review This technical evaluation report documents the EG&G Idaho, Inc.,

review of general load-handling policy and procedures at Waterford Generating Station (WGS) No. 3. This evaluation was performed with the objective of assessing conformance to the general load-handling guidelines of NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants" [1], Section 5.1.1.

1.2 Generic Background Gene'ric Technical Activity Task A-36 was established by the U.S.

Nuclear Regulatory Commission (NRC) staff to systematically examine staff licensing criteria and the adequacy of measures in effect at operating nuclear power plants to assure the safe handling of heavy loads and to recommend necessary changes to these measures. This activity was initiated by a letter issued by the NRC staff on May 17, 1978 [2], to all power reactor applicants, requesti'ng information concerning the control of heavy loads near spent fuel.

The results of Task A-36 were reported in NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants." The staff's conclusion from j this evaluation was that existing measures to control the handling of heavy loads at operating plants, although providing protection from certain potential problems, do not adequately cover the major causes of load-handling accidents and should be upgraded.

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l In order to upgrade measures for the control of heavy loads, the staff l developed a series of guidelines designed to achieve a two phase

( objective using an accepted approach or protection philosophy. The 1

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first portion of the objective, achieved tnrough a set of general guidelines identified in NUREG-0612, Article 5.1.1, is to ensure that all load-handling systems at nuclear power plants are designed and coerated such that their probability of failure is uniformly small and appropriate for the critical tasks in which they are emoloyec. The seconc portion of tne staff's objective, acnieved tnrough guidelines identified in NUREG-0612, Articles 5.1.2 through 5.1.5, is to ensure that, for load-handling systems in areas where their failure might result in significant consequences, either (a) features are provided, in addition to tnase required for all loac-nandling systems, to ensure that the potential for a load drop is extremely small (e.g., a single-failure croof crane) or (b) conservative evaluations of load-handling accicents indicate that the potential consequences of any load drop are acceptably small. Acceptability of accident consequences is quantifiec in NUREG-0612 into four accident analysis evaluation criteria.

The approach used to develop the staff guidelines for minimizing the po.ential for a load drop was based on defense in cepth and is summarized as follows:

e Provide sufficient operator training, handling system design, load-handling instructions, and equipment inspection to assure reliable operation of the handling system o Cefine safe load travel paths through procedures and operator training so that, to the extent practical, heavy '

loads are not carried over or near irradiated fuel or safe shutdown ecuipment e Provide mechanical stops or electrical interlocks to prevent movemer.t of heavy loads over irradiated fuel or in proximity to equipment associated with redundant shutcown patns.

Staff guidelines resulting from the foregoing are tabulated in Section 5 of NUREG-0612.

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1.3 Plant-Soecific Background On Decemcer 22, 1980, the NRC issued a letter [3] to Louisiana Power and Lighting Comoany (LP&L) the applicant for WGS No. 3 recuesting tnat the apolicant review provisions for handling and control of heavy loads at WGS No. 3, evaluate these provisions with respect to the guidelines of NUREG-0612, and provide certain additional information to be used for an independent determination of conformance to these guidelines. On June 19, 1981, LP&L provided the initial response [4]

to this request.

On Septemoer 21, 1981, LP&L submitted a second or follow-uo resconse to this request. Only Phase I guidelines will be addressed in this report. These involve approximately 50". of the June 19, 1981, response. The remaining sections of the June 19, 1981, and ..i of the Septemoer 21, 1981, response are concerned with Phase II. Compliance to Phase II requirements are semi-independent on Phase I and will not be addressed in this report. Based on the information submitted, a preliminary draft of this report was prepared and discussed with the applicant. Accitional information [5] was provided on January 27, 1983. The current (final) draft of this report was prepared from information contained in those submittals.

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2. EVALUATION AND RECOMMENDATICNS 2.1 Overview The following sections summarize LP&L's reviev: of heavy load handling at WGS No. 3 accompanied oy EG&G's evaluation, conclusions, and recommendations to the applicant for bringing the facilities more completely into compliance with the intent of NUREG-0612. The applicant has indicated the weignt of a heavy load for this facility (as cefinec in NUREG-0612, Article 1.2) as 1450 pounds [4].

2.2 Heavy Load Overnead Handline Systems This section reviews the applicant's list of overhead handling systems which are subject to the criteria of NUREG-0612 and a review of the justification for excluding overhead handling systems from the above-mentionec list.

2.2.1 Scope

" Report the results of your review of plant arrangements to identify all overhead handling systems from wnich a load crop may result in damage to any system required for plant shutdown or decay heat removal (taking no credit for any interlocks, technical specifications, operating procedures, or cetailed structural analysis) and justify the exclusion of any overhead handling system from your list by verifying that there is sufficient physical separation from any load-impact 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 decay heat removal."

A. Summary of Apolicant's Statements The applicart's review of overhead handling systems icentified the cranes and hoists snown in Table 2.1 as tnose which handle heavy loads in the vicinity of irradiated fuel l

or safe shutdown equipment.

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4 TABLE 2.1 OVERHEAD HANDLING DEVICES IN VICINITY OF SAFE SHUTCOWN EQUIPMENT, WATERFORD GENERATION STATICN UNIT 3 Capacity Handling System (Tons) location Reactor Circular Bridge 200/30 Reactor Builcing Fuel-Handling Building Bridge 125/15 Fuel-Handling Building l

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The applicant has also identified numerous other cranes that have been excluced from satisfying tne criteria of the general guicelines of NUREG-0612. These are listed in Table 2.2. These oyernead nandling cevices were reviewed by the applicant to the criteria of NUREG-0612 and were excluded basec on sufficient physical separation frcm any load impact point that could damage any system or component required for plant shutdown or decay heat removal. Some of the devices have been excludec because the applicant has indicated that the heavy loac of approximately 1450 pounds for this facility would not be exceedec. Tables 2.3 and 2.4 identify heavy loads to be handled by eacn crane, loac weight, designatec lift device, procedure, and load-drop analysis.

B. EG&G Evaluation The applicant's ' response [5] indicates that each overhead handling device at WGS No. 3 is listed in Tables 2.1 and 2.2. The applicant provided a listing of all plant overneaa handling systems, icentified equipment to be handled, crane or hoist location, elevations, and rate capacities.

Drawings were also provided to show the proximity of the handling devices to safe shutdown equipment. The applicant addressed each handling system and provided justification for its exclusion from the list of OHS from which load drops may result in damage to any system required for plant shutdown or decay heat removal. They further addressed the handling of heavy loads identified in NUREG-0612 (Table 3.1-1).

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i TABLE 2.2 CVERHEAD HANDLING SERVICES EXCLUCED FRCM FURTHER CONCERN, WATERFORD GENERATING STATION UNIT 3 Capacity Handling System (Tons) Location Crane; Radwaste Cask-Handling Bridge 30 Reactor Auxiliary Builcing Machine Shoo Bridge 6 Service Building Steam Generator Feecer Pumo 10 Turbine Building Bricge Intake Structure Bridge 40 Intake Structure Turbine Building Gantry 200/35 Turbine Building Monorail /Hofst Roof Hatch Cover 10 Reactor Auxiliary Builcing Water Chiller 7-1/2 Reactor Auxiliary Suilding Water Chiller (2) 7-1/2 Reactor Auxiliary Building HVAC Fan Motors 7-1/2 Reactor Auxiliary Building Cask Handling 7-1/2 Reactor Auxiliary Building CEA Orive-MG Set 7-1/2 Reactor Auxiliary Builcing RSD Equipment Access 7-1/2 Reactor Auxiliary Building Emergency Diesel Generator (4) 3 Reactor Auxiliary Builcing Emergency Diesel Generator (4) 14 Reactor Auxiliary Building Purification Filter 5 Reactor Auxiliary Building Misc. Equipment Jib Crane 1/2 Piant Shack Soent-Fuel Handling Macnine 3/4 Fuel-Handling Building Refueling Machine 3/4 Reactor 2pilcing Fue'l-Pool Filter 5 Reactor Auxiliary Builcing 7

TABLE 2.2 (continued)

Capacity Handlino System (Tens) Location Monorail / Hoist (continued)

Boric Acid Precon Filter 5 Reactor Auxiliary Building Waste, Oil, & Laundry Filter 5 Reactor Auxiliary Building Charging Pumos 5 Reactor Auxiliary Building HP-LP Safety Injection 5 Reactor Auxiliary Building

, Cont. Spray Pumps (2)

HP Safety Inject, Drain Pump 5 Reactor Auxiliary Building Safety VA Maintenance (2) 5 Reactor Auxiliary Builaing Equipment Decon Room 5 Reactor Auxiliary Building Equipment Decon Room (4) 1 Reactor Auxiliary Building Equipment Hot Machine Shop 2 Reactor Auxiliary Building General Storage (Above Machine 1 Reactor Auxiliary Building Shop)

Miscellaneous Equipment 1 Reactor Building

, IPH Drain Pump (3) 5 Turbine Building ,

Chillers (2) 5 Chiller Build

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s I ABLE 2.3 RE M:10R CONIAINM[NI bulLDileG POL 44 CRAleE--WAltRf0R0 GillERAllieG SI Allois 01:11 3 Appr04imate Weight Loal (lon) L if1 Equilament Procedure Remark s

1. Reactor Vessel I!ead wAlf t Rig 189 Heactor Vessel Head Lif t Rig a Load drop anal ReactorVesselpisover

2. Reattor Internals Lif ting Rig 16.5 N/A a Less critical than (1)

3. Reactor Upper Guide Structure 73 upper Guide Structure a less critical than (4) wAlf t Rig Lif t Rig -

4. Reactor Core 8arrel wAlf t ttig 79 Core Support Barrel Lif t Rig a Load drcp analysist over canal bottus

5. Stud lenslinier I.5 e a Less critical than (4)

6. RC Pasap IA-Motor wAlf t Rig 59 Reactor Coolant Pump Motor a toed drop analysisd Lif L Rig over operating iloor

1. RC Pump 18-Motor wAlf t Rig 59 'leactor Coolant Pump Motor a Load drop asialysisd Lif L Rig over operating iloor

. 8. RC Piamp 2A-Motor wAlf t Rig 59 Reactor Coolant Pump Motor a toad drop analysisd Lif t Rig over operating floor

9. RC Pump 28-Mutor wAlf t Rig 59 Reactor Coolant Pump Motor a load drop analysisd Lif t Rig over opersting floor

10. Plant Equipment from Lower flours 5 e a Load drop analysisd over operating iloor .

11. Main flook t oad Block 4.5 N/A a less critical than (10) 12 . Auxiliary llook Lual Blo(L I N/A a less critical than (10)

e. Procedures will be developed and implemented to cover load-hasmiling operations f aar f.eavy loads that are or could be handled over or in pioximity to irrallated fuel or safe shutdown equipment. Ihese piecedures will inciaale the inf ormattore identified in NUREG-0612 Section 5. l. l.(2). [5]

b. Analysis currently being perf ormeil. Results will be reported in Applicant's Report Part !! as Apge mila 8. [5]

c. Analysis has been perf ormed. Results will be reported in Applicant's Report Part 11 as Appi-imlin D. [5]

d. Analysis has beeri perf oeineil arms consequential ef fects have been f ound acceptable by the applicant. [5]

e. No special lif Ling devices identified by tiie applicant.

f. Ilie spent-fuel cask cannot be bruught over the spent-fuel storage pool; also. It cannot be Ilf tal more than 30 f eet t rian the f loor. Both the spent-fuel cask storage aeul wash-down areas are supported on the huge mass concrete slahs which are structurally isulepeculeret of the spent-fuel storage lumil. Iheref ore, Llie impact due to a s.ask drop on the stora9e- arkt wash-demn-4rea slabs will not have a detrimintal structural effect on tlie spent-fuel staurage gnjol s t ruc ture s. No other load drop analysis is required. l4) n --

I ABLE 2.4 Fu[1-llAME.!NG hullDING BRil6L CRANE--WAl[Rf 0RD GENf RAllNG ST All0N UNil 3 Appronlaate Weight t ea.1 (lon) Lif t Equipment Procedure itemar k s

1. Spent-Fuel Cask w/10 Fuel Assemblies 10 0 e a f

2. Gate No. I 1.6 e a Less critical than (4)

3. Gate No. 2 1.6 e a Less critical usan (4)

4. Gates No. 3A and 38 12. 7 e a Loal drop analysis over storage area bo ttom

5. Gate No. 4 10.8 e a Less critical than (4)

6. Hatch Cover itC-6 11.5 e a Loal will be haeulled at minle ss height from floor

7. Hatch Cover llc-5 12 e a Load will be handled at alnimum height from floor

8. liatch Cover HC-15 5.5 e a Load will be handled at minimum height from iloor 5 9. New Fuel Containers w/2 Fuel 3.5 e a Load will be handled at minimum height Assemelles from floor

10. Plant Equipment from Lower f loor 10.5 e a Load wilI be handled a1 minimum height from floor

11. Main llook load Block 2.1 e a Load drop analysis over operating iloor

a. Procedures will be developed and implemented to cover load-harulling operattuns f or lieavy loads that are or could be harulled over or in proximity to irradiated fuel or safe shutdown equipment. These procedures will include the inf onnation identified in MUR[G-0612 Section 5.1.1.(2). [5]

b. Analysis currently being performed. Results will be reported in Applicant's Report Part 11 as Appesufix 8. [5]

c. Analysis has been perf ormed. Results will be reported in Applicant's Report Part 11 as Appendla D. [5]

d. Analysis has been perf ormed arid cosisequential ef fects have been fourut acceptable by the applicant. [5]

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e. No special lif ting devices identified by the applicant.

f. Ine spent-f uel cask cannot be brought over the spent-fuel storage pool also. It cannot be lif ted more tt:45 30 f ee t f rom the flour. Both the spent-fuel cask storage maki wash-down areas are supported on the huge mass con (rete slabs whith are structurally irmlependent of the spent-fuel storage puol. Ilierefore, tiie impact due to a cask drop on the storage- asal wash-down-area slabs will not have a detrimental structural ef fect on the spent-fuel storage pool structuses. No other load .

drop analysis is required. (4]

C. EG&G Conclusions and Recommendations Since there is no information to the contrary, EG&G concludes that the applicant has included all applicable

• hoists anc cranes in their list of handling systems in ccmpliance with the requirements of the general guidelines of NUREG-0612.

2.3 General Guidelines This section addresses the extent to which the applicable handling systems comply with the general guidelines of NUREG-C612, Article 5.1.1. EG&G's conclusions and recommendations are provided in summaries for each guideline.

Tha NRC has established seven general guidelines which mus ce met in order to provide the defense-in-depth approach for the handling of heavy loads. These guidelines consist of the following criteria from Section 5.1.1 of NUREG-0612:

o Guideline 1--Safe Load Paths e Guideline 2--Load-Handling Procedures e Guideline 3--Crane Operator Training e Guideline 4--Special Lifting Devices I e Guideline 5--Lifting Devices (not specially designed) l e Guideline 6--Cranes (Insoection, Testing, and Maintenance) e Guideline 7--Crane Design.

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These seven guidelines snould be satisfied for all overnead nandling systems and programs in order to nandle heavy loads in the vicinity of the reactor vessel, near spent fuel in the spent-fuel pool, or in otner areas where a load droo may damage safe shutdown systems. The succeeding paragraphs address the guidelines incivicually.

2.3.1 Safe Load Paths (Guideline 1. NUREG-0612, Article 5.1.1(1)] .

" Safe load paths should ce defined for the movement of neavy loads to minimize One potential for heavy loads, if cropced, to imoact irradiated fuel in the reactor vessel and in the spent-fuel pool, or to imoact safe shutdown equipment. The path

hould follow, to the extent practical, structural floor members, beams, etc., such that if the load is creoced, tne structure is more likely to withstand the imoact. These load paths should be defined in procedures, snown on equipment layout crawings, and clearly marked on the floor in the area where the load is to be handled. Deviations from cefined loac paths snould require written alternative procedures aporoved by the plant safety review committee."

A. Summary of Acolicant's Statements 1

The applicant submitted drawings identifying safe load paths, location of spent fuel, and safety-related equipment. Crane travel over areas not defined as safe load paths (i.e., exclusion areas) is prohibited without safety review. Safe load paths and exclusion areas will be cefined in all load-handling procedures and clearly marked on equipment and floor layout drawings appended to each procedure. Any heavy-load-handling operation, prior to movement through an exclusion area, will be required by acministrative control to undergo a clant engineering safety review anc evaluation. Analyses have shown that the floor structure will withstand the impact of heavy load drops in safe load path areas where safe shutdown or cecay heat removal equipment may lie below the ficer structure. Based on the acove, the applicant feels that marking the ficers is unnecessary and impractical [5]. The applicant 12

identifiec those heavy operations over or near irraciated fuel, reactor vessel, spent-fuel storage pool, or safe shu:down ecuipment and icentifies those cases for nnich a load drop analysis will be performed [4].

. B. EG&G Evaluation The applicant provided detailed and well-illustrated crawings of the load paths for eacn overnead nandling sys em anc stated that the load patns were generally defined in accorcance with the NUREG guidelines. LP&L stated that the load paths and exclusion areas will be defined and clearly marked on each load-handling procedure, and safety review is required for any deviations. EG&G concludes that adequate measures have Deen taken to ensure that loac-handling operations remain within safe 10ad ;aths.

C. EG&G Conclusions and Recommendations Waterford Generating Station, Unit 3 fully complies witn the criteria of NUREG-0612, Guideline 1, Safe Load Paths.

2.3.2 Load-Handling Procedures (Guideline 2. NUREG-0612, Article 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 NUREG-0612. These procecures should include:

identification of recuired equipment; inspections anc acceotance criteria required cefore movement of load; the steps and proper sequence to be followed in handling the load; defining the safe path; and other special precautions."

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A. Summary of Acolicant's Statements

" Prior to Fuel Loac, procedures will be cevelooed and implemented to cover lead-nandling operations for heavy loads that are or could be handiec over or in proximity to irradiated fuel or safe shutdown equipment. These procedures will include: identification of required equipment; insoections and acceotance criteria recuired before movement of load; the steps and proper secuence to be followed in handling tne load; cefining the safe path areas; and special precautions; if necessary [5]."

8. EG&G Evaluation On the basis of the applicant's statement. EG&G feels that the criteria of NUREG-0612, Guideline 2 wii; be satisfied.

Procedures must be prepared and made available for audit prior to fuel load.

C. EG&G Conclusions and Recommendations EG&G concludes that Waterford Generating Station, Unit 3 is in compliance with the intent of criteria of NUREG-0612, Guideline 2, Load-Handling Procedures.

2.3.3 Crane Operator Training fGuideline 3. NUREG-0612, Article 5.1.1(3)1

" Crane ooerators should be trained, cualified, and conduct themselves in accorcance with Chacter 2-3 of ANSI B30.2-1976,

' Overhead and Gantry Cranes' [6]."

A. Summary of Acolicant's Statements "Lo&L has trained and qualified crane operators in accordance with Chaoter 2-3 of ANSI 830.2-1976 [5]."

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B. EG&G Evaluation On the basis of the applicant's statement, EG&G concludes that the criteria of NUREG-0612 Guideline 3 nas been satisfied. Training and qualification recorcs must be made available for audit.

C. EG&G Conclusions and Recommendations EG&G concludes tnat the Waterford Generating Station, Unit 3 is in compliance witn NUREG-0612, Guideline 3, Crane Ooerator Training.

2.3.4 Soecial Lifting Devices [ Guideline 4, NUREG-0612, Article 5.1.1(4)]

"Special lifting devices should satisfy the guicelines of ANSI N14.6-1978, ' Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More for Nuclear Materials' [7]. This standard should apply to all special lifting devices which carry heavy loads in areas as cefined above. For operating plants, certain inspections and load tests may be accepted in lieu of certain material requirements in the standard. In addition, the stress cesign factor stated in Section 3.2.1.1 of ANSI N14.6 should be based on the combined maximum static and dynamic loads that could be imparted on the handling device based on characteristics of the crane which will be used. This is in lieu of the guideline in Section 3.2.1.1 of ANSI N14.6 which bases the stress design factor on only the weight (static load) or the load and of the intervening components of the special handling device."

A. Summary of Acolicant's Statements The apolicant identified six special lift devices that are to be used and discussed their evaluation as follows [5):

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1. Two of the:e devices (Oisposaole Cask Liner Lift Rig -

and Shipping Cask lift Rig) were excluded from further consideration because they are; designated for use on a monorail / hoist.that has been excluded from further consiceratior because of physical separation by distance or limited load oath. ,

2. The Reactor Coolant Motor Lift Rig complies with'tne 2 stress design factors addressed in ANSI N14.6-1078, Section 3.2.1.1, as sucpiemented by NUREG-0612, Section 5.1.1.(4). In aedition, an analysis for a costulated crop of the RC pump motor to the operating floor elevation -11 ft was cerformed and its consecuent effects were found acceptat,le.

3. A heavy load droo analysis, prepared for tne Core Support Barrel, indicates that the local and overall effects of the impact on the structure are acceptable -

' , The analysis also determined that.the travel path is '

e not over any: irradiated fuel and tnat the effects N a postulated drop of the Core Support Barrel.are 1ess ,

critical than that of the uoper guide stracture. No postulated load drop was initiated for tha L.pper. guide structure since its effect is less critical than that of the vessel head. The CSB lift rig is part of the UGSliftrigandthisdevicewasevaluated'witbregard

~ to the. design.and ' fabrication compliance with i NUREG-0612 and ANSI N14.6-1978 criteria. Both lift i

rigs exceed NUREG-0612 stress allowances in a number of locations an~d do 'not fully meet all ANSI N14.6-1978 , _

reqUi rements .' '

4 A Heavy load creo analysis is^ currently beirq q

erformed y for the, Reactor Vessel Head and the S.V' head lift rig is <

currently undergoing review. -It'is exoected that the '

4 review will show nearly' identical results to those of y .

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l the UGS/CSB lift rig, including areas of nonccmpliance'. ~

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s N B. EC&G Evaluation s , On the basis of the information submitted, fx

1. EG&G agrees that the Discosable Cask Liner Lift Rig and u . .the Shipping Cask Lift Rig may oe excluded from further

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, s 2. EG&G concludes that the Reactor Coolant Motor Lift Rig

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is in compliance.

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3. The applicant submittec sketches of the UGS/CSB lift rig to show areas where stress levels exceed the

~ s N NUREG-0612 criteria, however, neglected to state what

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action, if any, would be taken toward comoliance. In evaluating the applican*'s comparisen tc ANSI N14.6 criteria, it was noted that the applicant identified numerous areas where the Lift Rig Soecification differed from the ANSI N14.6 requirements; however, tne applicant again neglected to identify actions to be taken.

M 4 Load drop analysis and ANSI N14.6 comparison review for the RV Head Lift Rig have not yet been completed.

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E V fl C. E_GO Conclusions and Recommendations

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EG&G concludes that Waterford Generating Station, Unit 3 is

'i . not in como11ance with the criteria of NUREG-0612, s

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Guideline 4, Special Lift Devices.

i It is recommended that LP&L:

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-(1) Take a more positive approacn towarc defining actions

,1 to be taken toward meeting the intent of this NUREG

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guideline. Differences noted between the Lift Rig 3 i N Specification and ANSI N14.6 include critical item

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recuirements, design load, ASME Section III allowable

, stress versus yield strength (i.e., in most cases 4,ff ,

'5,3 3 ~ f MSy ), lamellar tearing, load tesWg,

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recuirements placeo on the material suppliers (i.e. ,

LI, . .n2, material 'normally procured to ASTM specifications

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require drop weight or cnarpy impact tests), and non-

- destructive examinations.

(2) Complete load drop analysis and ANSI N14.6 comparison

.,' review for the Reactor Vessel Head Lift Rig.

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2.3.5.LiftineDevices)NotSoeciallyDesicned)IGuideline5.

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, NUREG-0612. . Article 5.1.1( 5)1 "L1fbng devices that are not specially designed should be 3: - s '

installed and used in accordance with the guidelines of ANSI B30.9-1971, ' Slings' [8]. However, in selecting the proper

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' sling, the load used should be the sum of the static and maximum dynamic load. The rating identified on the sling should ' ce in terms of tne ' static load' which produces the maximum static and

• %, 1 dynamic load. Where this restricts slings to use on only certain

' cranes,Ahe sMngs should be clearly marked as to the cranes with F v.hich they may be-used."

A. Surx.1ary of Acolicant's Statements h>

~

/ A review / ;/

of otherMifting devices used in Waterford 3

',a< l, E ir.cluding ropes, slings, and cables, will be done to

',j , , <

, 6.termineJthe e.xtent that the design, fabrication, and

'y giroof-testing methods used comply with the guidelines of j

AN51A30'.9-1971, as supplemented by NUREG-0612, r .r  ?

.,  ?

j. ,i, u*;< Section,,- '5.1'.1.~,(S) .

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, 4 . , . .' - .

g/ "In selecting the proper. sling 9here the load is based on a combination of static ar.d dynamic loacs, the dynamic contfributions of the rated load is taken as 1/2'.' (sic) of y .

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hoisting speed in feet per dinute (fpm), but not less tnan 15%, nor more than 50% of the rated load. The hoisting speeds at Waterford 3 do not exceed 30 fpm. Hence, the dynamic contribution is 15%. While LP&L coes not agree that dynamic loads must be addressec, tne safety factor of 5

. required by ANSI B30.9 is consicerec adeouate to account for any required dynamic effect. This is ... strains (i.e., ... blocks). Additionally, if comoliance with the acove cannot be verified for a particular sling, then tne sling will be load-tested to demonstrate its equivalency in terms of load handling reliabilit y, or the sling will ce replaced with one which meets tne guidelines [5]."

8. EG&G Evaluation EG&G feels that LP&L should not only perform a review to determine " extent of compliance" but should also take necessary actions to " demonstrate" compliance. On the basis of the applicant's statement, EG&G concludes that LP&L will ir, fact utilize a dynamic factor of 15% of the operating load in their equipment' selection. EG&G does not agree that an established safety factor should be considered as contingency to account for dynamic effects. Equipment selection should be based on the design load, comprised of

" dead" lead plus " live" load, which, in this case, would be operating static load plus dynamic effect. Two slings of different load-capacity ratings may be capable of handling a given load safely; however, they will not be equivalent in terms of load-handling reliability, since they will have different factors of safety and reliability is basec on factor of safety. The NRC has agreed to utilize the guidelines given in CMAA-70 (3.3.2.1.1.3) wnien indicates the acceptability of using 1/2% of the load per foot per minute of hoisting soeed, but not less than 15% or more than

)

19 1

50P. for the dynamic effect. The sum of the static and dynamic loads can then be incorocrated into written procedures as the weight of the load. Lifting devices coulc then be selected on the basis of that total load (i.e., the design load).

C. EG&G Conclusions and Recommendations EG&G concludes that Waterford Generating Station, Unit 3 will comply witn the intent of NUREG-0612, Guideline 5 Lifting Devices (not specially designed).

2.3.6 Cranes (Insoection. Testina, and Maintenance) [ Guideline 6, NUREG-0612, Article 5.1.1(6)]

"The crane should be inspt.;ad, tasted, and maintained in accordance with Chapter 2-2 of ANSI B30.2-1976, 'Overnead and Gantry Cranes,' with the exception that. tests and inspections should be performed prior to use where it is not practical to meet tne frequencies of ANSI B30.2 for periocic inspection anc test, or where frequency of crane use is less than the specified inspection and test frequency (e.g., the polar crane insice 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, however, calls for certain inspections to be performed daily or monthly. For such cranes having limited usage, the inspections, test, and maintenance should be performed prior to their use)."

A. Summary of Acolicant's Statements "All cranes concerned will be inspected, tested, and maintained in accordance with the guidelines of Chacter 2-2 of ANSI 330.2-1976, Overhead and Gantry Cranes, with the exception that tests and insoections will only be performed orior to their use when it is not practical to meet the 20

frequencies of ANSI B30.2 for periodic insoection and test, or where the frequency of crane use is less tnan the specified insoection and test frequency, and where tne requirements of tne rated loac tests co not conflict with safe hancling practices [4]."

B. EG&G Evaluation The applicant noted the oossible conflict between the Rated Load Test (ANSI S30.2-1976, Section 2-2.2.2) anc Incustry safe handling practice. However, the applicant stated tnat they do not anticipate any such situation to exist. It should be further noted that the Rated Load Test should be conducted prior to initial use. EG&G is in agreement with LP&L's prooosed program.

C. EG&G Conclusions and Recommendations EG&G concludes that Waterford Generating Station, Unit 3 is

in compliance with the intent of the criteria of NUREG-0612, Guideline 6 Cranes (Inspection, Tes, ting, and Maintenance).

2.3.7 Crane Design [ Guideline 7, NUREG-0612, Article 5.1.1(7)]

"The crane should be designed to meet the applicable criteria and guidelines of Chapter 2-1 of ANSI 830.2-1976, ' Overhead and Gantry Cranes,' and of CMAA-70, ' Specifications for Electric Overhead Traveling Cranes' [9]. An alternative to a specification in ANSI B30.2 or CMAA-70 may be accepted in lieu of specific comoliance if the intent of the specification is satisfied."

A. Summary of Acolicant's Statements All cranes were designed, fabricatec, installed, anc tastec in accorcance witn Ebasco specification which generally

comolies with the guidelines of CMAA-70, " Specification for Electric Overhead Traveling Cranes" and Chaoter 2-1 of ANSI 21

B30.2-1976, " Overhead and Gantry Cranes" or better [4]. A ccmparison was mace for selected pertinent items between the Ebasco specification and CMAA-70. The apolicant concluced that cranes furnished through the Ebasco specification in conjunction with CMAA-70 definitely satisfy the intent of either CMAA-70 and/or Chapter 2-1 of ANSI B30.2-1976 or

-better[5].

B. EG&G Evaluation On the basis of the applicant's submittal, EG&G concluces that the Ebasco specification is more stringent that CMAA-70 for the selected pertinent items. Since CMAA-70 (1.8.1) invokes the safety features of ANSI B30.2.0 safety code and the applicant stated tnat toe cranes were designed fabricated, installed, and tested in accordance with CMAA-70 or Ebasco specifications, whichever is more stringent [5],

it must be concluded that the cranes also meet the requirements of ANSI B30.2. Procurement documents anc speci.fications snould be made available for aucit.

C. EG&G Conclusions and Recommendations EG&G concludes that Waterford Generating Station, Unit 3 is in compliance with the criteria of NUREG-0612, Guideline 7, Crane Design.

2.4 Interim Protection Measures The NRC staff has established (NUREG-0612, Article 5.3) that six measures should be initiated to provide reasonable assurance that nandling of heavy loads will be performed in a safe manner until final implementation of the general guidelines of NUREG-0612, Article 5.1, is complete. Four of these six interim measures consist of general Guideline 1, Safe Load Paths; Guideline 2, Load-Handling Procecures; 22 J

Guideline 3, Crane Operator Training; and Guideline 6, Cranes (Inspection, Testing, ana Maintenance). The two remaining interim measures cover the following criteria:

e Heavy load technical soecifications e Special review for heavy loads handled over the core.

However, because the WGS No. 3 plant is currently not an ocerating facility nor will it be operating in the near future, EG&G recommencs that LP&L not spend time and effort adcressing tne interim protection phase of NUREG-0612, but instead devote its efforts towards the completion of operating procedures and qualifications and addressing the guideline deficiencies noted. It should be noted that guicelines must be satisfied prior to plant operation.

23

3. CONCLUDING

SUMMARY

3.1 Acolicable Load-Handline Systems The list of cranes and hoists supplied by the apolicant as being .

sucject to the provisions of NUREG-0612 appears to ce complete (see Section 2.2.1). The applicant has fulfilled the requirements of NUREG-0612 concerning exclusion of various overhead handling systems.

3.2 Guideline Recommendations Compliance with the seven NRC guidelines for heavy load handling (Section 2.3) are partially satisfied at WGS No. 3. This conclusion is represented in tabular form as Table 3.1. Specific recommendations to aic in comoliance witn the intent of these guidelines are provicec as follows:

Guideline Recommendation

1. Section 2.3.1 a. None Safe Load Paths WGS No. 3 is in compliance

2. Section 2.3.2 a. Procedures must be completed and made Lopd Handlino Procedures available for audit prior to fuel loading WGS No. 3 is in compliance 24 i _

Guideline Recommencation

3. Section 2.3.3 a. Training and Qualification records Crane Ooerator Training must be made

. available for audit WGS No. 3 is in comoliance prior to fuel loading

4. Section 2.3.4 a. Take more positive aporoach towarc Soecial Lift Device icentifying actions to be taken to ensure WGS No. 3 is not in compliance compliance.

b. Complete analysis and comparison for the R'l Head Lift Rig.

5. Section 2.3.5 a. None.

Lifting Devices (Not Soecially Designed)

WGS No. 3 is in compliance

6. .Section 2.3.6 a. Inspection and test procedures and

'. Cranes (Inscection and Testing) records should be made available for WGS No. 3 is in compliance audit prior to fuel load ,

25

1 l .

Guideline Recommendation

7. Section 2.3.7 a. Procurement documents and scecifications Crane Desian snould be made availacle for audit WGS No. 3 is in compliance prior to fuel load 26

- . - . . _. ~ _ - - - - .-

I A8t[ 3.1. ContINsR MAIRig idAltRioRD GENf MAllNG SI All0N UNll 3 Guideline 3 Guideline 4 Guideline i Crane Specification Guideline 6 Guideline 7 Capacity Safe Load Guideline 2 Operator Lift Guideline 5 Crane-lest Crane Equipment Deslenation lleavy loads (Inns) Papas Procedures IraininL Devices Slings and Inspec t Design Reactor Cont. Bulldhuj C 200/30 C C C NC C C C Polar Crane fuel-Harsiling Building C 12 5/15 C C C C C C C C

• Applicant action fully cumplies wi th NUREG-0612 Guideline, subject to review by NHC Staff.

NC = Applicant action doe not fully comply with NUREG-0512 Guideline, subject to review by NRC Staf f.

1 x

P

I 4 REFERENCES

1. NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, NRC.

2. V. Stello, Jr. (NRC), Letter to all acplicants. .Suoject: Request for Additional Information on Control of Heavy Loads Near Spent Fuel, NRC, May 17, 1978.

3. USNRC, ~ Letter to LP&L Co.

Subject:

NRC Request for Additional Information on Control of Heavy Loads Near Spent Fuel, NRC,

• December 22, 1980.

4 Letter to NRC;

Subject:

Waterford 3 SES Control of Heavy Loads, from L. V. Maurin, Assoc. Vice Pres. LP&L Co. to D. G. Casennut, Director Division of Licensing, USNRC, datec June 19, 1981.

5. Letter to NRC;

Subject:

Response to EG&G Draft Tecn Evaluation Reoort, from L. V. Maurin. LP&L Co. datec January 27, 1983.

6. ANSI B30.2-1976, " Overhead and Gantry Cranes."

7. ANSI N14.6-1978, "Stancard for Lifting Devices for Shioping Containers Weigning 10,000 Pounds (4500 kg) or more for Nuclear Materials."

8. ANSI B30.9-1971, " Slings."

9. CMAA-70, " Specifications for Electric Overhead Traveling Cranes."

i l

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. . ]

1. O

,, U.S. NUCLEAR REGULATORY COMMISSION BIBLIOGRAPHIC DATA SHEET EGG-HS-6291 4 TITLE AND SUSTITLE 2 (Leave osan=1 Control of Heavy Loads at Nuclear Power Plants Ifaterford Generating Station, Unit 3, Louisiana Power and 3. RECIPIENT S ACCESSION NO.

Lighting Comoany (Phase I) Docket No. 50-382

7. AUTHOR tSi 5. DATE REPORT COMPLETED

" ** ^"

J. P. Sekot, T. H. Stickley May l983 1

9. PERFORMING QRGANIZATION NAME AND MAILING ACORESS (Inctuar lea Cooet QATE REPORT ISSUED

• VCN N l YEAR July 1983 EG&G Idaho, Inc. . ,L, ,, ,,,,,

l Idaho Falls, ID 83415 a ite-e a a, >

12. SPONSORING ORGANIZATION NAME AND MAILING ACORESS (tac /vor I.o Caoes to PROJECT TAS0 WORK UNIT NO.

Division of Systems Integration Office of Nuclear deactor Regulation , i ,,N No U.S. Nucicar Regulatory Commission Washington, DC 20555 A6457

13. TYPE OF REPORT oE RICO COV E mE O 8 tactus.ve fates /

15. SUPPLEVENTARY NOTES 14 fleave orn>=?

16. ABSTR ACT /200 woros or lessJ The Nuclear Regulatory Commission (NRC) has requested that all nuclear plants, either operating or under construction, submit a response of compliancy with NUREG-0612,

" Control of Heavy Loads at Nuclear Power Plants." EG&G Idaho, Inc. has contracted with the NRC to evaluate the responses of those plants presently under construction.

This report contains EG&G's evaluation and reccmmendations for Washington Nuclear Project No. 2 (WNP-2) for the requirements of Section 5.1.1 of NUREG-0612 (Phase I).

Sections 5.1.4, 5.1.5, and 5.1.6 (Phase II) will be covered in a separate report.

I 17 KEY WOROS ANO DOCUMENT AN ALYSIS lia. CESCR.PTORS 1

17b IOENTIFIERS/CPEN ENCE O TERMS

18. AV AILA81LITY STATEMENT 19 SE CURITY CLASS hs voorri 21 NO 05PAGES Make available only as specifically approved Unclassified l by program office. ** ffWg'g)Rf'"'

8xe eOm ns m en l

m - _

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

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ENCLOSURE SYNOPSIS OF ISSUES ASSOCIATED WITH NUREG 0612 The following information is provided to identify exceptions or interpretations related to verbatim compliance with NUREG 0612 Guidelines that have occurred during the course of this review. For each of the major Guidelines specific exceptions are identified, a discussion concerning the underlying objective of that Guideline is provided, and approaches felt to be consistent and inconsistent with that guideline are identified. While each such exception has been handled on a case by case basis, and has been considered in light of overali compilance with NUREG 0612 at a particular plant, the topics are of a nature general enough to be of interest to other plants.

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1

GUIDELINE I SAFE 1.OAD PATHS Exception 1 In the opinion of the licensee, development of individual load paths is impractical since there are a significant number of loads for which the pickup and laydown areas vary from outage to outage. Further, in some cases the location of safety related' equipment combined with the design of the floor over which heavy loads are carried indicates that for a number of lif ts thcre is no preferred load path.

Discussion The purpose of this portion of Guideline 1 is to ensure that the paths over which heavy loads are carried have been developed and approved in advance of the lif t and are based on considerations of safety. In particular it is provided to avoid the ad hoc selection of load paths by maintenance personnel since such a situation

, could result in the use of a load path which has been established by a process wherein considerations other than safety have taken precedence.

it is recognized that there are a class of loads which, although in excess of the weight specified for classification as a heavy load, are actually miscellan-eous or maintenance related loads for which it is impractical to identify a specific laydown area which can be fixed from outage to outage. Conversely there are a number of loads for which specific laydown areas have been allocated in the original plant design and which should reasonably be expected to be carried over the same load paths during every outage. A tabulation of loads in this latter category, generally applicable to PWR's and SWR's, was provided in NUREG 0612 as Table 3-1.

A fundamental principal of NUREG 0612 is protection through defense in depth. Specifically, the first line of protection from an accident which could result in damage to spent fuel or equipment required for safe shutdown or decay heat removal is to avoid or minimize the exposure of such equipment to crane borne loads overhead.

Where such exposure is minimized, rather than avoided, a second line of defense can then be provided by intervening barriers such as floors or the provision of additional lif ting device redundancy or safety factors. Considering the foregoing, the use of exclusion areas, rather than safe load paths, is consistent with this g0ideline only under circumstances where there is no safety related equipment located beneath the area accessible to the crane hook but outside of the exclusion area. This situation has been found in buildings such as the turbine hall or screen house where safety related equipment is concentrated in a specific area within the crane path. It is unlikely to occur within containment due to the numerous safety related piping and electrical systems provided to support decay heat removal.

Aporoaches Consistent With This Guideline Specific safe load paths are prepared and approved for major components for which hazardous areas are well established. For miscellaneous lifts load corridors are established such that any movement within that corridor cannot result in carrying a heavy load over spent fuel or systems required for safe shutdown or decay heat removal (regardless of intervening floors). Movement within these corridors is at the discretion of the load handling party.

Specific safe load paths are prepared and approved for major components for which hazardous areas are well established. For miscellaneous lif ts detailed direct-ions are prepared and approved for developing safe load paths which nclude floor plans showing the location of safety related equipment and instructions to avoid such equipment. Specific safe load paths are then prepared each time a miscellaneous lif t qualifying as a heavy load is made. These individual load paths are temporary and may change from outage to outage. -

2

s.

, .[ Approaches Inconsistrnt With this Guideline.

Use of limited exclusion areas in containment which merely prohibited the carrying of heavy loads directly over the core or specific components and allow full load handling party discretion in other areas.

Exception 2 In the opinion of the licensee marking of load paths on the floor is impractical. This may be caused by the general use of temporary floor coverings which would cover the load path markings, or, due to the number of loads involved, a requirement for multiple markings which could confuse the crane operator.

Discussion The purpose of this feature of Guideline 1 is to provide visual aids to assist the operator and supervisor in ensuring that designated safe load paths are actually followed. In the case of the operator it has the additional function of avoiding undesirable distractions while handling suspended loads (e.g., trying to read procedural steps or drawings while controlling the crane). This feature should also be seen as a provision necessary to complete a plan for the implementation of safe load paths.

Specifically it provides some additional assurance that, having spent the time and effort to develop safe load paths, those paths will be followed.

Acoroaches Consistent With this Guideline Rather than mark load paths a second member of the load handling party (that is, other than the crane operator)is made responsible for assuring that the designated safe load path is followed. This second person, a signalman is typically used on cab operated cranes, checks out the safe load path prior to the lif t to ensure that it is clear, refers to the safe ! cad path guidar.ce during the lift and provides direct-icn to the operator and that the load path is followed. To support this approach the duties and responsibilities of each member of the load handling party should be clearly defined.

. Prior to a lif t the appropriate load path is temporarily marked (rope, pylons, etc.) to provide a visual reference for the crane operator. In cases where the load path cannot be marked (e.g., transfer of the upper internals in a PWR) temporary or permanent match marks can be employed to assist in positioning the bridge and/or trolley during the lif t.

In either case reasonable engineering judgement would indicate that in certain specific lifts marking of safe load paths is unnecessary due to physical constraints on the load handling operation (e.g., simple hoists, monorails, or very short lif ts where movement is limited to one coordinate axis in addition to the vertical).

Approaches Inconsistent With this Guideline Positions which in effect do not recognize the need for realistically providing visual aids to the crane operator and imply that, for all lif ts, the operator will remember the load path from review of procedures or by reference to a drawing.

Exception 3 Obtaining written alternative procedures aporoved by the plant safety review committee for any deviations from a safe load path is considered too

cumbersome to accommodate the handling of maintenance loads where laydown areas may have to change or load paths altered as a result of unanticipated maintenance requirements.

s

Discussien I Tha purpose of this portion of this guid:line is to ensure that deviations frorb established safe load paths receive a level of review appropriate to their safety significance. In generai it is highly desirable that once safe load paths are established they are retained and kept clear of interference rather than routinely deviated from.  !

It is recognized, however, that issues associated with plant safety are the respensibility '

of an individual licensee plant safety review comraittee (or equivalent) and the details of their excercizing this responsibility should be within their jurisdiction.

Approach Consistent With this Guideline A plant safety review committee (or equivalent) delegates the respon-sibility for approving temporary changes to safe load paths to a person, who may or may not be a member of that committee, with appropriate training and education in the area of plant safety. Such changes are reviewed by the safety review committee in the normal course of events. Any permanent alteration to a safe load path is approved by the plant safety review committee.

Aporoach Inconsistent With this Guideline Activities which in effect allow decisions as to deviations from safe load paths to be made by persons not specifically designated by the plant safety review committee.

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GUIDELINE 2 LOAD HANDLING PROCEDURES No s'gnificant exceptions to this guideline have ueen encountered.

Occasionally a question arises concerning the need for individual procedures for each lift. In general,it was not the purpose of this guideline to require separate procedures fer each Ilft. A reasonable approach is to provide separate procedures for each major lif t (e.g., RV head, core internals, fuel cask) and use a general procedure for handling other heavy loads as long as load specific details (e.g., load paths, equipment requirements) are provided in an attachments or enclosures.

+

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GUIDELINE 3 CRANE OPERATOR TRAINING Exception The only exception occassionally encountered with respect to this Guideline other than fairly minor, site unique, exceptions has been a desire to deviate from the requirement of ANSI B30.2-3.1.7.o for testing of all controls before beginning a new shift. In some cases a licensee has qualified a commitment in this area by noting

. that only crane controls "necessary for crane operation" will be tested at the start of a shif t.

Discussion This requirement (ie. not a recommendation) of ANSI B30.2 is important since crane control system failures are relatively significant contributors to load handling incidents. The only reason that can be seen for an exception in this area is a general aversion to the word "all". Specifically, it appears that some licensees fear that a commitment to this requirement will force them to test all control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those fer.tures generally known as controls (ie. hoist, bridge, and trolley motion controllers).

Aporoaches Consistent With this Guideline Exceptions that clearly indicate that all normal controls (hoist, bridge, and trolley motion controllers) will be tested at the start of each shif t and that the purpose of not committing to "all" controls is to avoid a misunderstanding concerning other control devices.

Acoroaches Inconsistent With This Guideline

. A response that implies that a decision to test or not test a normal control will be made by the crane operator on the basis of what type of lif t or direction of motion he expects for the forthcoming shif t.

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." . GUI.DE1.INE 4 SPECIAL LIFTING DEVICES Exception 1 Some licensees have indicated that their special lif ting devices were designed and procured prior to the publication of ANSI N14.6 and therefore are not designed in accordance with that standard. This fact is sometimes combined with a reference to the title of that standard to reach a conclusion that the standard is not applicable.

Discussion The purpose of this section is to ensure that special lif ting devices were designed and constructed under controlled conditions and that sufficient document-ation is available to establish existing design stress margins and support future mainten-ance and repair requirements. ANSI N14.6 is an existing standard that provides require-ments supporting this goal for lif ting device applications where the consequence of a failure could be similar to that which could be expected in the event of the failure of a speciallifting device carrying a load within the jurisdiction of NUREG 0612.

Consequently it seems appropriate that for special lif ting devices subject to NUREG 0612 it should be able to be demonstrated that, from a design standpoint, they are as reliable as a device for which ANSI N14.6 was developed.

Approaches Consistent With This Guideline Although not originally specified to be designed in accordance with ANSI N14.6 the special lifting device in question was provided by a reactor vendor, in accordance with appropriate quality assurance and quality control procedures, for a specific application associated with power plant components provided by that vendor.

Based on either the review of the original stress report cr, if such a stress report is unavailable, the preparation of a new stress report, the licensee has determined that margins to material yield and ultimate strength are comparable to those specified in ANSI N14.6. Although not required of the lif ting device vendor, the licensee has reviewed the design of the lif ting device and prepared a list of critical components whose repair or replacement should be performed under controlled conditions.

Approaches Inconsistent With This Guideline No information is available concerning the original design but it is probably allright because the device has been used for ten years and never failed.

The device was built before the publication of ANSI N14.6, does not carry shipping containers of nuclear material weighing more than 10,000 pounds, and thus need not comply with ANSI N14.6.

Exception 2 No 150% overload test has been performed and, in the opinion of the licensee, such a test is impractical.

Discussion The performance of a load test in excess of the load subject to NUREG 0612 is an important contributor to the ability to assess the overall reliability of a device. Such a test supplements design reliability by demonstrating that the device was properly fabricated or assembled and that a portion of the design safety margin has been demonstrated. Such proof of workmanship is particularly important for a fairly complicated device. It is recognized, however, that the specification of a 150% overload test is somewhat arbitrary and that, in some cases, the nature of the device is such that the !!klihood of workmanship shortcomings is remote.

7

i Approrchts Consistant With This Guideline The licensee has evaluated the lif ting device in question and has determined that design stress margins are substantial. Further it has been established that the device itself is uncomplicated and principally put together with mechanical joints such that an assembly error is highly unlikely. The use of welded joints is severly limited and where employed were performed in accordance with substantial quality controls (eg AWS DI.1) including NDE. The device has been tested to 100% of rated load.

Although a 130% overload test has not been performed the lifting device has been subjected to a manufacturer recommended overload to demonstrate proof of workmanship (typically 120-125 %).

Aporoaches Inconsistent With This Guideline See this topic for Exception 1 above.

Exception 3 The requirement of ANSI N14.6 for an annual 150% load test or ful! NDE is excessive, Both the load test (due to the inability to make the test lift within containment) and the NDE (due to the need to remove protective coatings) are impractical and not justified by the infrequent use of these devices.

Discussion A continuing Inspection program to assure the continued maintenance of safety margins incorporated in the original design of the device is important to demonstrate the reliability of special lif ting devices. It is recognized, however, that some devices employed in a nuclear power plant, particularly those associated with refueling, are used under conditions of control and at frequencies of use that are substant-

- ially less severe than that possible for the type of lifting device for which ANSI N14.6 was originally prepared. Consequently a reasonable relaxation of the inspection interval seems appropriate.

Approaches Consistent With This Guideline Overload tests will be conducted but at a longer interval,5 years, between tests to be consistent with the number of operational lifts required.

NDE of load bearing welds will be conducted at 5 year intervals or, alternatively, load bearing welds will be examined through a program that ensures ,

that all welds will be examined over a normal inservice inspection interval of 10 years '

in a manner similar to that specified in the B&PV Code for Class 2 Component Supports.

Approach Inconsistent With This Guideline Continuing inspection will be limited to an annual visual examination of the device.

e 8

G'UIDELINE 5 LIFTING ' DEVICES NOT SPECIALLY DESIGNED Exception Licensees have taken exception to the requirement to select slings in accordance with the maximum working load tables of ANSI B30 9 considering the sum of static and dynamic loads. Most commonly it is the licensees position that the approximate factor of safety of five on rope breaking strength inherent in these tables adequately accomodates dynamic loading.

Discussion The intent of this portion of this Guideline, which also applies to special lifting devices under Guideline 4, is to reserve the ANSI B30.9 safety factors for accomodating sling wear and unanticipated overloads and avoid a reduction of this safety factor as a result of the routine dynamic loads inherent in hook / load accel-eration and deceleration. While it is acknowledged that, for operating characteristics typical of cranes employed at nuclear power plants, these dynamic loads are unlikely to be substantial, such a determination cannot be made generically. Typically the actual dynamic load due to hook / load acceleration or deceleration is a function of design hook speeds and the type of hoist control system employed. It should also be recalled that ANSI B30.9 is a general industrial standard which applies to allload handling devices and does not in itself provide for any additional conservatism in consid-eration of the potential consequences of a load handling accident at a nuclear power plant. Based on this, it is considered reasonable that individual licensees evaluate the potential contribution of dynamic loading in their operations and if such dynamic loading is indeed significant accomodate it in their procedures for sling selection.

Aporoach Consistent With This Guideline The licensee has evaluated the potential routine dynamic loading for lif ting devices not specially designed and found them to be a relatively small fraction (typically 5-15%) of static load. This estimate has been made on the basis of either calculated acceleration and deceleration rates or through use of the industrial standard

_ for impact loading of cranea specified in CMAA-70. In either case having verified that routine dynamic loading of a specific hoist is indeed small the licensee has drawn the conclusion that revised selection criteria to accomodate such minor additional loads will not have a substantial effect on overall load handling reliability.

Approach Inconsistent With This Guideline Statement to the effect that dynamic loads are accomodated in the tables of ANSI B30.9 with no indication that the licensee has assessed the actual dynamic loading imposed on cranes subject to NUREG 0612.

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' GUIDELINE 6 CRANE INSPECTION TESTING AND MAINTENANCE.

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Exception The only exception occasionally encountered with respect to this Guideline other than fairly minor and site-unique exceptions has been a desire to deviate from the requirement of ANSI B30.2-1.1.2.a.2 and 3.2.4 for testing of hoist limit devices before beginning a new shift. In some cases a licensee has qualified a commitment in this area bf noting that this limit switch will be tested only if operations in the vicinity of the limit switch are anticipated.

Discussion While this issue is treated somewhat ambigously in ANSI B30.2 (it is a recommendation in article 1.1.2 and a requirement in article 3.2.4) it is important since two-blocking incidents are relatively significant contributors to load handling incidents. Further it should be noted that this test has been incorporated as a require-ment of OSHA in 29 CFR 1910.179.(n).(4).(i). It is recognized, however, that there

' may be circumstances where such a test is not prudent. First, such a test clearly should not be made with the hook under load. Consequently if a shif t change is made with the hook loaded (this, by the way, is not a desireable practice and could be preclud-ed through strict compliance with ANSI B30.2-3.2.3.j) a hoist limit switch test should not be performed. Second, there may be circumstances where the nature of forthcoming load handling operations indicates that the time (and minor risk) associated with this test is not justified. In particular if it is known that a hoist will not be used or used only in an area substantially removed from the upper travel limit, it would seem reason-

. able to defer the limit switch test until the start of the next shift. If such an approach is taken, however,it should be approached with care. Requirements for deferring an upper limit switch test should accomodate the uncertainty associated with maintenance plans and establish unambiguous criteria concerning what operations can be determined to be rernote from upper travellimits. Such criteria should recognize that the need for upper travellimit switch protection may be preceeded by a control system failure and consequently should conservatively allow for operater response time and potential l delays associated with emergency shutdown of the crane.

Approach Consistent With This Guideline General compliance with this requirement. Certain specific provisions made for deferring upper limit switch testing under conditions that are not subject to operater interpretation.

Approaches Inconsistent With This Guideline An approach that implies that a decision to test or not is left to the discretion of the operator or implies that such a test will bo required only if operat-lons are planned in close proximity to the hook upper travel limit.

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GUlDELINE 7 CRANE DESIGN Exception Occasionally a licensee has indicated that the overhead electric travelling cranes employed at a site were purchased prior to the publication of CMAA-70 or ANSI B30.2-1976 and thus these standards should not be applied.

Discussion The purpose of this Guideline is to ensure that all cranes carrying heavy loads in nuclear power plants meet certain minimum criteria in their design and, consequently, can be assumed to provide an acceptable standard of mechanical, electrical, and structural reliability. It is also recognized, however, that cranes in operating plants may have been designed and procured prior to the publication of current standards and, thus, not strictly comply with some details of these standards.

In general, though, current standards have evolved from predecesor standards in existence at the time of crane procurement (EOCI 61, ANSI B30.2-1967) and, since the later standards are not revolutionary, it is likely that cranes at nuclear power plants will provide a degree of reliability equivalent to that provided by the current standards.

Such a general determination canot be made, however, by the staff since nuclear power plant cranes are usually unique and provided with site specific design features.

It is up to the licensee then to make a systematic comparison of their crane design with the requirements of current standards and determine if additional design features are appropriate.

Approach Consistent With This Guideline The licensee has compared original crane procurement specifications or existing crane designs with the requirements of the referenced standards in areas effecting load handling reliability. In instances where the current standard provides additional protection against the consequences of operater error or component failure the licensee has proposed modifications which will result in a degree of load handling reliability similar to that provided in the current standard.

Approach Inconsistent With This Guideline Positions to the effect that the cranes satisfied standards in existence at the time of procurement and what was good enough then is good enough now.

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