ML20077L789
| ML20077L789 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/09/1983 |
| From: | Ahmed N, Bomberger C FRANKLIN INSTITUTE |
| To: | Singh A NRC |
| Shared Package | |
| ML20077L794 | List: |
| References | |
| CON-NRC-03-81-130, CON-NRC-3-81-130, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR TAC-10993, TER-C5506-348, TER-C5506-348-DRFT, NUDOCS 8308180560 | |
| Download: ML20077L789 (33) | |
Text
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(DRAFT)
TECHNICAL EVALUATION REPORT I
CONTROL OF HEAVY LOADS (C-10) -
TOLEDO EDISON COMPANY DAVIS-3 ESSE NUCLEAR POWER STATION UNIT 1 a_
. NRC DOCKET NO. 50-346 FRC PRCJECT C5506 NRC TAC NO. 10993 FRC ASSIGNMENT 13 NRC CCNTRACT NO. NRC-03-81-130 FRC TASK 348 Prepared by Franklin Research Center Author: C. Bo=berger 20th and Race Streets N. Ahned Philadelphia, PA 19103 FRC Group Leader: I. H. Sargent Prepared for Nuclear Regulatory Commission . . ,
Washington, D.C. 20555 Lead NRC Engineer: A. Singh August 9, 1983 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of t.1y information, appa.
ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.
XA Copy Has BeM.SehtTo'PDR A
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TER-C550 6-34 8 CCNTENTS Section Title Pace 1 INTRODLCTION. . . . . . . . . . . . . . 1 1
1.1 Purpose of Review . . . . . . . . . . . 1 1.2 Generic Background . . . . . . . . . . . 1 1.3 Plant-Specific Background . . . . . . . . . 2 2 EVALUATION . . . . . . . . . . . . . . 4
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2.1 General Guidelines . . .- . . . . . . . . 4 2.2 Interim Protection Measures. . . . . . . . . 23
- 26 3 CONCLUSION . . . . . . . . . . . . . .
3.1 General Provisions for Load Handling . . . . . . 26 3.2 Interim Protection Measures. . . . . . . . . 27 4 REFERENCES . . . . . . . . . . . . . . 28 iii
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TER-C5506-348 FIGURES Number Title Pace 1 Restricted Area in Containment . . . . . . . . . 12 E
TABLES Number Title Pace 2.1 Davis-Besse Unit 1/NUREG-0612 Compliance Matrix . . . . . 5 2.2 Handling Systems Subject to NUREG-0612 Compliance . . . . 10 2.3 Handling Systems Excluded frcm Compliance with NUREG-0612 . . . . . . . . . . . . . . 10 iv O .
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TER-C550 6-34 8 6
F0Frn'ORD This Tech 41 cal Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NBC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NBC.
Mr. C. Bomberger and Mr. I. H. Sargent contributed to the technical preparation of this report through a hubcontract with WESTEC Services, Inc.
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1 TER-C5506-34 8
- 1. INTRODUCTION 1.1 PURPOSE OF RE7IEW This technical evaluation report documents an independent review of general load-handling policy and procedures at Toledo Edison Company's Davis-Besse Nuclear Power Station Unit 1. This evaluation was performed with the following objectives:
o to assess conformance to the general load-handling guidelines of NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants" [1] ,
Section 5.1.1 o to assess conformance to the interim protection measures of NUREG-0 612, Section 5.3. ..
, 1. '2 GENERIC BACEGROUND Generic Technical Activity Task A-36 was established by the Nuclear Regulatory Commission (NaC) staff to systematically examine staff licensing m
criteria and the adequacy of measures in effect at operating nuclear power plants to ensure the safe handling of heavy loads and to recommend necessary changes in these measures. This activity was initiated by a letter issued by the NaC staff on May 17, 1978 [2] to all power reactor licensees, requesting 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 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.
! In ceder to upgrade measures provided to control the handling of heavy loads, the staff developed a series of guidelines designed to achieve a two-part objective using an accepted approach or protection philosophy. The first part of the objective, achieved through a ' set of general guidelines
' identified in NUREG-061'2, Section 5.1.1, is to ensure that all load-handling l
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I TER-C550 6-34 8 syrtems at nuclear power plants are designed and operated so that their probability of f ailure is uniformly small and appropriate for the critical tasks in which they are employed.' The second part of the staff's objective,,
achieved through guidelines identified in NU3ZG-0617. Sections 5.1.2 through 5.1.5, is to ensure that, for load-handling systems in areas where their f ailure might result in significant consequences, either (1) features are -
provided, in addition to those required for all load-handling systems, to ensure that the potential for a load drop is extremely small (e.g., a single-f ailure-proof crane), or (2) conservative evaluations of load-handling accidents indicate that the potential consequences of any load , drop are ,
acceptably small. Acceptability of accident consequences is quantified in 4
NUREG-0612 into four accident analysis evaluation criteria.
A defense-in-depth approach was used to develop the staff guidelines to ensure that all load handling systems are designed and operated so that their-probability of failure is appropriately small. The intent of the guidelines is to ensure that licensees of all operating nuclear power plants perform the-following:
o define safe load travel paths, through procedures and operator - 0. . ' >
training, so that, to the extent practical, heavy loads are not -
carried over or near irradiated fuel or safe shutdown equipment o provide sufficient operator training, handling system design, load ,
handling instructions, and equipment inspection to ensure reliable operation of the handling system Staff guidelines resulting from the foregoing are tabulated in Section 5 of NUREG-0612. Section 6 of NUREG-0612 recommended that a program be initiated to ensure that these guidelines are implemented at operating plants. .
1.3 PLANT-SPECIFIC BACKGROUND On December 22, 1980, the NBC issued a letter [3] to Toledo Edison, the ,
Licensee for Davis-Besse Nuclear Power Station, requesting that the Licensee review previsions for handling and control of heavy loads at Davis-Besse Unit 1, evaluate tnese provisions with respect to the guidelines of NUREG-0612, and O
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TER-C5506-348 provide certain additional information to be used for an independent deter'=ina-N ',
tion of co'ndormance to these guidelines. -Toledo EdisonNespotided to this request.cn February 1, 1982 [4]. A draft technical evaluation report (TER) was prepared based on this infor=ation and was informally transmitted to the Licensee for review and cc==ent. On Ncrember 15, 1982, a telephorielccnference
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call was condccted with representative,s of NE, FE, and Toledo Edu>s en to <
- discuss unresolved issues. As a result of this call, additional information was submitted by the Licensee on January 31, 1983 (5) , May 2,1983 [6) , and May 6,1983 [7] . This TER is based 'on information provided in References 4 through 7. ,,
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( 2. , EVALUATION AND RECOMMENDATICNS l
This section presents a point-by-point evaluation of load handling previsions at Davis-Besse Nuclear Power Station Unit 1 with respect to NRC staff guidelines provided,in NUREG-0612. Separate subsections are provided for both the general guldhlines of NUREG-0612, Section 5.1.1 and the interim
. measures of N,UREG-0 612, Section 5.3. In each case, the guideline or interim measure is presented, Licensee-provided information is su -.narized and evaluated, and a conclusion as to the extent of compliance, including recommended additional action where appropriate, is presented. These conclusions are s - arized in Table 2.1.
2.1 GENERAL GUIDELINES The NBC has established seven general guidelines which must be followed in order to provide a defense-in-depth approach for the handling of heavy icads. These guidelines consist of the folicwing criteria frem Section 5.1.1 of NUREG-0612 o Guideline 1 - Safe Load Paths o Guideline 2 - Load Handling Procedures o Guideline 3 - Crane Operator Training o Guideline 4 - Special Lifting Devices o Guideline 5 - Lif ting Devices (Not Specially Designed) o ' Guideline 6 - Cranes (Inspection, Testing, and Maintenance) o Guideline .7 - Crane Design.
These seven guidelines should be satisfied by all overhead handling systems and procedures used to handle heavy loads in the vicinity of the reacter vessel, near spent fuel in the spent fuel pool, or in other areas where a load da p =ay damage safe shutdown systems. The Licensee's assessment of the extent to whien these guidelines have been satisfied and an independent evaluation of this assessment are contained in Sections 2.1.1 through 2.1.8 of this report.
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Table 2.8 Davle-seese tenit 1/se*EC-9682 Compliance feettle teelght latesse lateele os Culdeline 1 Guideline 2 Ostdeline 3 Culdeline 4 Culdeline S Culdeline 6 Caldeline 7 feessese i seesesse 6 Cepec5ty sefe load Csone Operates specie! I.8ftlag Crone - Teet TechniceI stwc1eI g eey leede jtossi Fathe Proceduree _ Training Deelces Sllnee and Inspectica Ctene Deelg Specificesione Attention
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peectos plenue 59.9 NC C == C - -- -- -- C Assembly peector vessel 16% Isc c -- C -- - -- - C head Isrvnt Internale Indesing Fletuse 15.6 NC C -- C = - - -- C Flenum 9.3 esc C - C -- - - -- C Assembly .
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Cenerator Demoeable Suploste me ctor 47.3 tec C - esc -- - -- -- C i
Nigelle shielde Q C = Licensee action compiles with the esumEC-9612 Culdeline.
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- 2. EVALUATION AND RECCMMENDATIONS This s'oction ' presents a point-by-point evaluation of loa'd handlinq !
previsions at Davis-Besse Nuclear Power Station Unit 1 with respect to NRC staff guidelines provided in NUREG-0612. Separate subsections are provided for both the general guidelines of NUREG-0612, Section 5.1.1 and the interim
. measures of NUREG-0612, Section 5.3. In each case, the guideline or interim measure is presented, Licensee-provided information is su. T.arized -
and evaluated, and a conclusion as to the extent of compliance, including recommended additional action where appropriate, is presented. These conclusions are summarized in Table 2.1.
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2.1 GENERAL GUIDELINES The NRC has established seven generel guidelines which must be followed in order to provide a defense-in-depth approach for the handling of heavy loads. These guidelines consist of the following criteria from section 5.1.1
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of NUREG-0612:
c Guideline 1 - Safe Load Paths o Guideline 2 - Load Handling Procedures o- Guideline 3 - Crane Operator Training o Guideline 4 - Special Lifting Devices o Guideline 5 - Lif ting Devices (Not Specially Designed) o ' Guideline 6 - Cranes (Inspection, Testing, and Maintenance) o -Guideline.7 - Crane Design.
These seven guidelines should be satisfied by all overhead handling systems and procedures used to handle heavy loads in the vicinity of the reactor vessel, near spent fuel in the spent fuel pool, or in other areas where a load drop may damage safe shutdown systems. The Licensee's assessment of the extent to which these guidelines have been satisfied and an independent evaluation of this assesssent are contained in Sections 2.1.1 through 2.1.8 of this report.
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Cooling Wates F*sep I peranos a ll Ces rumps 2.7 tec C -- -- C -- -- - --
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Csone Seselee Wates 3.9 NC C -- -- C - = == -
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q Cise water 2.9 NC C == == C *- - -- --
Makeup Pump
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Pbtor q j t1 skusttopteettp 1.4 asC C -- == C -- -- -- --
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TER-C550 6-34 8 2.1.1 Overhead Heavy Load Handline Systems
- a. Su= mary of Licensee Statements and Conclusions The Licensee has reviewed all overhead handling systems in use at Davis-Besse Unit 1 and identified those systems which must be addressed within the scope of NUBEG-0612 cn the basis that they could carry heavy loads over the core, over spent fuel, or over safety-related equipment. These handling cystems are listed in Table 2.2.
Determination of those systems which have been excluded from compliance has also been ecmpleted by the Licensee. Identification of excluded systems es well as the reasons for exclusion are provided in Table 2.3.
- b. Evaluation and Conclusien The Licensee's evaluation of overhead handling systems and the determina-tion of those systems which must comply with NUREG-0612 is consistent with the intent of NUREG-0612. Exclusion of handling systems from NUREG-0612 compliance is acceptable if (1) no equipment required for safe shutdown or decay heat removal is located in close proximity; (2) the handling systems are used for sole-purpose lif ts, do not carry leads over other safety-related equipment, and are used only when the respective components have been placed out of service; or (3) handling of components over safety-related equipment is performed only af ter the system / equipment has been placed out of service in accordance with Technical Specifications or existing administrative procedures.
2.1.2 Safe Load Paths [ Guideline 1, NUBEG-0612, Section 5.1.l(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 pa ths 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.
Deviations from defined load paths should require written alternative procedures approved by the plant safety review cc=mittee."
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Weleht lateele lateste or culdeline 1 osideline 2 culdeIIne 3 Culdeline 4 casadeline S Goldeline 6 culdeline ? Mesause I seessuae 6 tapacIty sefe load C one opesater Specie! LaftIng C one - Teet Teca.nica I spec 1eI seavy inede Jtana) Paths psecedures feelnine Deelces ellnee esid Insdin trene Deelgst, g iticatione attention pilation rump 4.7 esc C -- -- C - -- -- -
Ollution Pump 1.1 Dec C ~ ~ C -- ~ -- --
testos plesel Flee 2.6 esc C -- -- C - -- -- --
Pump ?
I plesel rise C C -- -- - --
f pump pontos I.e esc -- --
seseen week 1.8 Isc C -- -- C ~ ~ -- --
rump screen Week 8.7 Isc C -- -- C -- -- -- --
rump #Ntos S. peactos sesulce S -- - C -- -- C C -- --
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- a. Su=marv of Licensee Statements and Conclusions The Licensee stated that, due to the large number. of handling systems, defining load paths is neither required . tor prudent for the many different load handling situations that are ancountered at Davis-Besse Unit 1. Based on the recently completed Phase II load drop consequence evaluations, the Licensee has redefined the set of administrative controls for heavy load handling operations to specifically address situations of potential safety significance and to remove restrictions from those situations that have .no potential safety significance. As a result of these evaluations, the Licensee has proposed the following actions:
- 1. Specific " safe load paths" for the handling systems identified in our February 1,1982 submittal were found to be necessary only for major' loads associated with reactor disassembly. This is based on system redundancy and diversity considerations, and structural evaluation of the protection offered by intermediate structures, e.g., slabs and other structural elements.
- 2. Additional administrative controls will be implemented in procedures to better control the acvement of loads that must be moved into and out of the restricted area shown in Figure 1.
- 3. Additional administrative controls will be implemented in procedures to ensure that safety system redundancy is available when lif ts are made over certain areas and to ensure that an expected degree of protection is provided by certain slabs and other structural alements (limits on heights of lifts in certain areas).
The Licensee reiterated that, with these revisions and additions to the current set of administrative controls, the potential safety issues have been ;
specifically addressed and any additional controls, e.g., detailed safe load paths, would only serve to u..necessarily restrict the flexibility of operation l and maintenance efforts.
Finally, each heavy load lift will be supervised by a designated individual who will be responsible for enforcing procedural requirements.
Deviations from these procedures require prior approval of the plant superintendent.
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- b. Evaluation The Licensee's response has been evaluated with respect to the NRC's objective, as discussed in Section 1.2 of this evaluation, which is to achieve a defense-in-depth approach for the handling of heavy loads. Two distinct ,,,
phases of implementation are to be accomplished to achieve this goals o first phase - overall improvement of procedures, training, maintenance, and verification of crane and lifting device design, as well as establishment of safe travel paths which avoid irradiated fuel and safe shutdown equipment, as means to ensure' reliable operation of handling systems.
o second phase - implementation of additional safeguards by satisfying
- single-failure-proof crane criteria or installation of mechanical or i electrical interlocks; or performance of analyses that substantiate -
the Licensee's contention that damage to irradiated fuel will not exceed limits for criticality or release of radioactivity, or that damage to redundant or dual safe shutdown systems will not result in loss of required safety functions.
The intent of the first phase of NUREG-0612 is to ensure that all cranes 4
operating in the vicinity of irradiated fuel or safe shutdown equipment meet the requirements of the general guidelines (Section 5.1.1) with no regard or credit given for system redundancy, mechanical or electrical interlocks, administrative procedures, or single-failure-proof cranes. The intent of Guideline 1 is to ensure the existence of defined load paths, developed by knowledgeable engineering staff f amiliar with overall plant arrangement and equipment functions, so that the. direction of load movements is not the responsibility of individual crane operators or maintenance supervisors who may not be knowledgeable of various functier.s or locations of safety-related equipment. The use of polar crane matchmarks for tne reactor vessel closure head and the plenum assembly is consistent with this requirement.
The Licensee's proposed actions and conclusions resulting fro = the recently completed Phase II load drop consequence analysis are not consistent with the intent of this guideline. Phase I implementation requirements, as discussed above, disallow any credit for administrative procedures, system redundancy or structural analysis. Therefore, proposed improved
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1 TER-C5506-34 8 adm'aistrative controls and system redundancy in lieu of defined load paths are also not consistent with Guideline 1 of NUPEG-0612.
In addition, other than polar crane matchmarks for two loads, no information has been 'provided to verify that load paths have been defined er are incorporated into general arrangement drawings for major loads of all cranes subject to compliance with NUREG-0612 and identified in Table 2-2. The Licensee may use alternatives to floor markings that provide suitable visual aids and assist the operator in keeping the load on the load path. Such visual aids may consist of rope, tape, temporary stanchions, or a supervisor (with duties delineated in procedures) directing load movement froc the handling floor along the load path.
Licensee procedures for dealing'with deviations from procedures are consistent with requirements of this guideline,
- c. Conclusion and Recorcmendations Actions pecposed at Davis-Besse Unit 1 with respect to the designation of safe load paths are not consistent with Guideline 1. To be consistent with this guideline, the Licensee should define safe load paths of all major loads carried by cranes subject to compliance with NUREG-0612, incorporate load paths into general arrangement drawings, and provide suitable visual aids to the operators when transporting loads.
2.1.3 Load Handling Procedures (Guideline 2, NUREG-0612, Section 5.1.l(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 procedures should include: identification of required equipment; inspections and acceptance criteria required before movement of lead; the steps and proper sequence to be followed in handling the load; defining the safe path; and other special precautions.."
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TER-C5506-348
- a. Summarv of Licencee Statements and Conclusions The Licensee has identified the procedures in use or being , developed for the various NURIG-0612 cranes. These procedures include the following:
Polar Crane .
SP 1104.46 " Polar Crane System Procedure" SP 1504.01 " Reactor Vessel Closure Head Removal and Replacement" SP 1505.01 " Reactor Internals Removal and Replacement" Component Cooling Water Pump Monorail SP 1104.1.3
- Component Cooling Water Pump Menorail System Procedure" Soent Fuel Cask Crane SP 1104.50 " Spent Fuel Cask Crane Operating Procedure" Intake Gantrv Crane '
SP 1104.53 " Intake Gantry Crane System Procedure" The Licensee has stated that all lifting procedures, including those identified abov'e, have been updated to satisfy the requirements of Section 5.1.l(2) of NUREG-0612.
- b. Evaluation -
The criteria of this guideline are satisfied on the basis of the Licensee's verification that load handling procedures contain the information identified in NUREG-0612.
- c. Conclusion Procedural provisions for heavy load handling at the Davis-Besse plant are consistent with Guideline 2.
I 2.1.4 Crane Ocerator Training (Guideline 3, NUREG-0612, Section 5.1.l(3))
" Crane operators should be trained, qualified, and conduct thamselves in accordance with Chapter 2-3 of ANSI B30.2-1976, 'Cverhead and Gantry Cranes' [8]."
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TER-C5506-348
- a. Summary of Licensee Statements and Conclusions The Licensee states that procedures for the qualification and training of crane operators are contained in Davis-Besse dministrative Directive
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AD 1844.06 which . requires that crane operators be qualified to criteria ,
ossentially identical to the provisions of ANSI B30.2-1976, Chapter 2-3. This general directive is implemented at Davis-Besse Unit 1 by training / examining l prospective operators and documenting successful qualification on specific qualification cards for each crane. Training and examination of prospective operators are performed by designated instructors.
These procedures and practices were reviewed against the provisions of ANSI B30.2-1976, Chapter 2-3. A number of minor changes were made by the Licensee to the procedures and the qualification card process to ensure that -
cil items pertinent to operator training, qualification, and conduct were cdequately addressed. No exceptions to A' NSI B30.2-1976 are taken by the Licensee.
- b. Evaluation Programs implemented by the Licensee satisfy the criteria of this guideline en the basis that no exceptions are taken with Chapter 2-3 of ANSI B30.2-1976.
- c. Conclusion Provisions for crane operator training and qualification at Davis-Besse Unit 1 are consistent Guideline 3.
2.1.5 Special Lif tino Devices (Guideline 4, NU7EG-0612, Section 5.1.1(4))
"Special lif ting devices should satisfy the guidelines of ANSI N14 . 6-1978, ' Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or Mere for Nuclear Materials' [9).
This standard should apply to all special lifting devices which carry heavy loads in areas as defined above. For operating plants, certain ,
inspections and load tests may be accepted in 1.ieu of certain material !
requirements in the standard. In addition, the stress design facter j 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 i= parted on the handling
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device based on characteristics of the crane which will be used. This is stress design factor on only the weight (static load) of the load and of the intervening components of ,the special handling device (NUFIG-0612,-
Guideline 5.1.1(4 ) ] . "
- a. Summary of Licensee Statements and Conclusiens j The Licensee has identified four special lif ting devices used in lif ts over the reactor vessel, including the following:
- 1. Head and internals handling fixture
- 2. Turnbuckle pendants and head lifting pendants
- 3. Internal handling adapter, pendants, and spreader ring
- 4. Internals indexing fixture pendants.
The missile shield lifting harness has also been identified as a special, lif ting device; however, necessary information has not yet been retrieved for this device. In addition, no cask or lifting device has yet been selected for spent fuel equipment.
For the four lif ting devices identified above, a detailed comparison of ANSI N14.6-lS78 was limited to Sections 3.2 and 5 for the following reasons:
- a. All of the devices described above were designed by Babcock and Wilcox prior to the existence of ANSI N14.6-lS78. In this regard, there are a number of sections in the standard that are difficult to apply in re trospect. These sections are those entitled Designer's Responsi-bilities (Section 3.1); Design Considerations (Section 3.3);
Fabricator's Responsibilities (Section 4.1); Inspector's Responsibilities (Section 4.2); and Fabricator's Considerations (Section 4.3) . These sections have not been reviewed item by item for the purpose of identifying and justifying exceptions.
- b. Certain sections of ANSI N14.6-lS78 are judged as not pertinent to I
the load handling reliability of the devices and have not been addressed for the purpose of identifying and justifying exceptions.
These sections are Section 1.0, Scope; Section 2.0, Definitions; l
I Section 3.4, Design Considerations to Minimize Decontamination Effects in Special Lifting Device Use; Section 3.5, Coatings; and Section 3.6, Lubricants.
- c. Section 6 of ANSI N14.6-1978 is applicable to lifting devices used
- for critical loads as defined in Section 2 of the standard. None of the loads lifted by the lifting devices-identified above have as yet been determined to be critical loads. Such determinatien would require an analysis of the consequences of various load drops. Since i
such analyses have not yet been performed, and are not required to be l
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TER-C5506-348 performed until the 9-month report to the NRC, it is premature to de;ignate certain loads as critical loads and, accordingly, to apply the requirements of Section 6 of ANSI N14.6-1978 to their designated
. lifting devices.
The detailed comparisen of special lif ting devices with the requirements of Sections 3.2 and 5 of ANSI N14.6-1978, as supplemented by auREG-0612, indicates that load bearing components of these lif ting devices have actual structural margins that are, in general, significantly higher and in all cases were found to meet the ANSI stress design factors. .The Licensee further states that these devices comply with the standards, with the following exceptions:
Exception 1: Section 5.3.7 of ANSI N14.6-1978 specifies that visual inspections by maintenance or nonoperating personnel be performed at -
intervals of three months or less. Since these devices are stored in a specific location under a controlled environment and are not subject to any other uses, the Licensee believes that current procedures requiring inspections (visual, dimensional, and nondestructive examination) prior to each use are sufficient to meet the intent of these standards.
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Exception 2: There are several lead-bearing members of special lifting devices for which inspection in accordance with Section 5.3.1(2) is impractical due to problems involved in disassembly and paint removal.
The Licensee proposes to institute an annual visual inspection coupled with a more comprehensive 5-year dimensional and nondestructive examination (NDE) program for these members. The proposed inservice inspection program is based upon the Licensee opinion that these devices are:
- 1. used infrequently and are therefore subjected to fewer stress cycles
- 2. stored in a controlled environment
- 3. constructed of materials with ample design safety margins
- 4. handled in accordance with stringent operating procedures.
Further, the Licensee believes that the proposed inspection program is equivalent to the intent of ANSI N14.6 and provides sufficient inspection and examinatier. to identify wear or degradation that could potentially reduce design safety margins.
- b. Evaluation e It is acknowledged that a strict interpretation of compliance cf existing special lif ting devices .with the crir~ '.a of ANSI N14.6-1978 cannot be made.
Therefore, the Licensee's respense is consistent with the intent of this guideline in addressing only those sections (3.2 and 5) directly related to O
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TER-C5506-348 the load handling reliability of the lif ting devices. It is noted from the Licensee's response that the devices comply with the design safety margins of 3 on yield strength and 5 on ultimate strength for the four lifting devices reviewed. Evaluatiens cf the four special lif ting devices identified satisfy
- the requiraments of this guideline for these sections based on the Licensee's statement that the lifting devices comply with the standards, with exceptions noted.
For those exceptions noted by the ' Licensee, proposed actions for Exception 1 (periodic inspections by maintenance or nonoperating personnel) are consistent with this guideline and with NUREG-0612 guidance for inspection of cranes (Guideline 6) . In addition, the Licensee's intent to perform an annual visual inspection of special lifting devices to ensure confirmed f compliance, coupled with comprehensive dimensional and NDE every 5 years, should provide lifting devices with continued reliability consistent with the requirements of this guideline.
- c. Conclusion and Recommendations Special lifting devices at Davis-Besse Unit 1 comply with Guideline 4 on
.the basis that four of the lif ting devices noted have been found to comply with Sections 3.2 and 5 of ANSI N14.6-1978. The Licensee, however, should perform a similar evaluation of the missile shield lifting harness in accordance with ANSI N14.6-1978.
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1 2.1.6 Lifting Devices (Not Specially Designed) (Guideline 5, NUREG-0512, Section 5.1.l(5)]
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l " Lifting devices that are not specially designed should ce installed and l used in accordance with the guidelines of ANSI B30.9-1971, ' Slings' [7].
- However, in selecting the proper sling, the load used should be the sum i
of the static and maximum dynamic load. The rating identified on the sling sh'ould be in terms of the ' static load' that produces the maximum static and dynamic load. Where this restricts slings to use on only certain cranes, the slings should be clearly marked as to the cranes with which they may be used."
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- a. Su==ary of Licensee Statements and Conclusions
, The Licensee states d2at, with the exception of the spent fuel shipping I cask, other loads identified by the Licensee are ifted with slings selected, inspected, and maintained in accordance with ANSI B30.9-1971. An analysis has been performed which demonstrates that dynamic loading on slings is within the variance of 14 to 8% of the static leads handled; this dynamic load effect is insignificant and may be disregarded.
- b. Evaluation Procedures for use of slings at Davis-Besse Unit 1 satisfy the recommendations of this guideline on the basis that they comply with ANSI B30. 9-1971. Dynamic loads are a reasonably small percentage of the overall "
static loads and may be disregarded in rating the slings.
- c. Conclusion and Recommendations Davis-Besse Unit 1 complies with Guideline 5.
2.1.7 . Cranes (Insoection, Testino, and Maintenance) [ Guideline 6, NUREG-0612, Section 5.1.l(6)]
"The crane should be inspected, tested and maintained in accordance with Chapter 2-2 of ANSI B30.2-lS76, ' Overhead and Gantry Cranes,' with the exception that tests and inspections should be performed prior to use when 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, however, calls for certnin inspections to be performed daily cr mon thly. For such cranes having limited usage, the inspections, tests, and maintenance should be performed prior to their use) ."
- a. Summary of Licensee Statements and Conclusions Davis-Sesse preventive maintenance and surveillance test programs provide for crane inspection, testing, and maintenance. The preventive maintenance program outlines a schedule of preventive maintenance per Administrative Directives AD 1844.00, Maintenance, and AD 1844.01, Preventive Maintenance.
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TER-C5506-348 Periodic Test Procedure PT-5199.02, Station Crane Periodic Test, provides for station crane surveillance. Administrative Directive 1844.04 specifies crane lubrication guidelines. Crane lubrication data are kept in the plant lubrication manual.
These procedures and practices were reviewed against the provisions of ANSI B30.2-1976, Chapter 2-2. Where areas of noncompliance with the standard were identified, revisions to procedures were developed. No exceptions to
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ANSI B30.2-1976 are taken.
- b. Evaluation Davis-Besse Unit 1 satisfies the requirements of this guideline on the basis that existing procedures have been reviewed and revised to comply with ANSI B30.2-1976, with no exceptions.
- c. Conclusion
- Davis-Besse Unit 1 complies with Guideline 6.
2.1.8 Crane resien (Guideline 7, NUPEG-0612, Section 5.1.l(7))
"The crane should be designed to mest the applicable criteria and guidelines of Chapter 2-1 of ANSI B30.2-1976, ' Overhead and Gantry Cranes, ' and of CMAA-70, ' Specifications for Electric Overhead Travelling Cranes' [11] . An alternative to a specification in ANSI B30.2 or C.%A-70 may be accepted in lieu of specific compliance if the intent of the specification is satisfied."
- a. Summarv of Licensee Statements and Conclusions Specifications for cranes subject to NUREG-0612 compliance have been com-pared to CMAA-70 and to the additional safety requirements of ANSI B30.2-1976.
Each of these cranes--the containment polar crane, the reactor service crane, the spent fuel shipping cask crane, and the intake structure gantry crane--was designed in accordance with sechtel design specifications. These specifica-tions required that each crane be designed in accordance with the minimum requirements for Class A ' cranes, except as the requirements are extended by the Bechtel specification, in which case the more stringent restriction O
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TIR-C5506-348 governed.' The Licensee noted that the Bechtel specification predates ,the 1975 revision to CMAA-70. As a result of the above comparison, the Licensee states that all four cranes have been found to comply with CMAA-70 and ANbI B30.2-1976, with two exceptions:
- 1. The Bechtel specifications place no additional requirements on welding other than the requirement of CMAA-70, which in turn ref erences AWS
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D14.1 for welding. ANSI B30.2-1976 requires welding to be in accordance with AWS Dl.1 as modified by AWS D14.1. With the exception of requirements for storage of low hydrogen welding rods included in AWS D1.1, there are no significant differences between AWS Dl.1 and AWS D14.1 that would affect load-handling reliability. Licensee review revealed that the manufacturer's shop practices provided for control of low hydrogen rods even though AWS Dl.1 was not specifically used. Therefere, the welding requirements in effect were equivalent to the requirements of ANSI B30.2. -
- 2. In regard to the tolerance on crane runway dimensions, CMAA-70 specifies that center-to-center distances on runway rails be within 11/8 inch. For the polar crane, the equivalent center-to-center distance is the diameter of the circular track. The plant designer (Bechtel) and the polar crane manuf acturer (Harnischfeger) have used a tolerance of 11/2 inch. It is the Licensee's judgment that this deviation from the standard is not significant to load handling reliability in view of the fact that both Bechtel and Harnischfeger worked to the same dimensions.
- b. Evaluation Cranes at Davis-Besse Unit 1 satisfy the requirements of this guideline on the basis that they were designed and built to specifications which meet or exceed the criteria of CMAA-70 and ANSI B30.2-1976. The Licensee responses regarding exceptions indicate that (1) welding procedures used are equivalent to ANSI B30.2-1976 and meet the intent of this guideline and (2) deviation from the crane center-to-center . runway tolerances is not significant to load handling reliabil'ity.
- c. Conclusion ,
Davis-Besse Unit 1 complies with Guideline 7.
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- i TER-C5506-348 2.2 INTERIM PRCfrECTION MEASURES The NBC has established six interim protection measures to be implemented at operating nuclear power plants to provide reasonable assurance that no heavy loads will be h'andled over the spent fuel pool and that measures exist to reduce the potential for accidental load drops to impact on fuel in the core or spent fuel pool. Four of the six interim measures of the report consist of Guideline 1, Safe Load Paths; Guideline 2, Load Handling Procedures; Guideline 3, Crane Operator Training; .snd Guideline 6, Cranes (Inspection, Testing, and Maintenance) . The two remaining interim measures cover the following criteria
- 1. Heavy load technical specifications
- 2. Special review for heavy loads handled over the core.'
Licensee implementation and evaluation of these interim protection measures are contained in the succeeding paragraphs of this section.
2.2.1 Technical Specifications (Interim Protection Measure 1, NUREG-0612, Section 5.3 (1)]
" Licenses for all operating reactors not having a single-f ailure-proof overhead crane in the fuel storage pool area should be revised to include 7 specification comparable to Standard Technical Specification 3.9.7,
'Cra m Travel - Spent Fuel Storage Building,' for PWR's and Standard Technical Specification 3.9.6.2, ' Crane Travel,' for BWR's, to prohibit handling of heavy loads over fuel in the storage pool until implementation of measure 3 which satisfy the guidelines of Section 5.1 [of NUREG-0612) ."
- a. Evaluation A review of technical specifications at Davis-Besse Unit 1 indicates that Technical Specification 3.9.7 prohibits movement of loads greater than 2430 lb over spent fuel assemblies in the spent fuel pool area.
- b. Conclusien Cavis-Besse Unit 1 complies with Interim Protection Measure 1.
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TER-C5506-348 2.2.2 Administrative Controls (Interim Protection Meas'ures 2, 3, 4, and 5, NUREG-0 612, Sections 5.3 (2)-5.3 f 5))
" Procedural or. administrative measures (including safe load pcths, load handling procedures, crane operator training, and crane inspection] ...
can be accomplished in a short time period and need not be delayed for completion of evaluations and modifications to satisfy the guidelines of Section 5.1 (of NUREG-0612)."
Evaluation a.
The specific requirements for load handling administrative controls are contained in NUREG-0612, Section 5.1.1, Guidelines 1, 2, 3, and 6. The Licensee's compliance with these guidelines has been evaluated in Cections 2.1.2, 2.1.3, 2.1.4, and 2.1.7, respectively, of this report.
- b. Conclusions and Recommendation 2 Conclusions and recommendations concerning the Licensee's compliance
- with these administrative controls are contained in Sections 2.1.2, 2.1.3, 2.1.4, and 2.1.7 of this report.
2.2.3 Special Review for Heavy Loads Handled Over the Core (Interim Protection Measure 6, NUREG-0612, Section 5.3 (6)]
...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 lif ting devices and movement of the load to assure that i
i sufficient detail is provided and that instructions are clear and l 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 component; (3) appropriate repair and replacement of defective components; and (4) verify that the crane operators have been properly trained and are familiar with specific l
procedures used in handling these loads, e.g., hand signals, conduct of operation, and content of procedures."
I a. Su==ary of Licensee Statements and Conclusions ,
l Toledo Edison has performed the special rev'iews for the Interim Protection Measure 6 of NUREG-0612.
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- b. Evaluation and Conclusion
. The Davis-Besse plant complies with Interim Protection Measure 6 based on the Licensee's verification. In light of the responses to Guidelines 2 and 3, ,
it is apparent that procedures for handling loads over the core and for operator training have been reviewed and upgraded as appropriate. In addition, design of cranes and programs for selection and use of slings have
.been reviewed and found to comply with NUREG-0612.
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- 3. CONCLUSION o
This summary is provided to consolidatie t$e results of the evaluation contained in Section 2 concerning individual NRC staff guidelines into an overall evaluation of heavy load handling at Davis-Besse Nuclear Power Station Unit 1. Overall conclusions and recommended Licensee actions, where
, appropriate, are provided with respect to both general provisions for load i handling (NUREG-0612, Section 5.1.1) and completion of the staff recommendations for interim protection (NUREG-0612, Section 5.3).
3.1 GENERAL PROVISIONS FOR LOAD HANDLING The NRC staff has established seven guidelines concerning provisions for handling heavy loads in the area of the reactor vessel, near stored spent fuel, or in other areas where an accidental load drop could damage equipment required for safe shutdown or decay heat removal. The intent of these guidelines is twofold. A plant conforming to these guidelines will have developed and implemented, through procedures and operator training, safe load travel paths such that, to the maximum extent practical, heavy loads are not carried over or near irradiated fuel or safe shutdown equipment. A plant conforming to these guidelines will also have provided sufficient operator training, handling system design, load handling instructions, and equipment inspection to ensure reliable operation of the handling system. As detailed in Section 2, it has been found that load handling operations at Davis-Besse Nuclear Power Station Unit 1 can be expected to be conducted in a highly reliable manner consistent with the staff's objectives as expressed in these guidelines. A need for further Licensee action, however, was identified in the following areas:
o Toledo Edison should define safe load paths of all major loads carried by cranes subject to compliance with NUREG-0612, incorporate load paths into general arrangement drawings, and provide suitable visual aids to the operators when tranporting loads.
o Toledo Edison should evaluate the missile shield lifting harness and
- ensure that it is designed and maintained in a manner censistent with Guideline 4.
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TER-C5506-348 3.2 I::TERIM PROTECTION MEASURES
. The NBC staff has established certain measures (NUREG-0612, Section 5.3) that should be initiated to provide reasonable assurance that handling of heavy loads will be performed in a safe =anner until final implementatica of the general guidelines of NUREG-0612, Section 5.1 is complete. Specified measures include the implementation of a technical specification to prohibit the handling of heavy loads over fuel in the storage poo2; compliance with Guidelines 1, 2, 3, and 6 of NUREG-0612, Section 5.1.1; a review of load handling procedures and operator training; and a visual inspection program, including component repair or replacement as necessary of cranes, slings, and special lif ting devices to eliminate deficiencies that could lead to component failure. The evaluation of information provided by the Licensee indicates .
that the Davis-Besse plant complies with the staff's measures 'for interim protection.
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- 4. REFERENCES
- 1. NBC
" Control of Heavy Loads at Nuclear Power Plants" July 1980 NUREG-0612
- 2. V. Stallo, Jr. (NRC)
. Letter to all Licensees
Subject:
Request for Additional Information on Control of Heavy Loads Near Spent Fuel May 17, 1978
- 3. D. G. Eisenhut (NRC) -
Letter to all operating reactors
Subject:
Control of Heavy Loads December 22, 1980
- 4. R. P. Crouse (Toledo Edison)
. Letter to J. F. Stolz (NBC)
Subject:
Control of Heavy Loads February 1, 1982
- 5. R. P. Crouse (Toledo Edison)
Letter to J. F. Stolz (NBC) .,
Subject:
Centrol of Heavy Loads January 31, 1983
- 6. R. P. Crouse (Toledo Edison)
Letter to J. F. Stolz (NFC)
Subject:
Control of Heavy Loads May 2, 1983
- 7. R. P. Crouse (Toledo Edison)
Letter to J. S. Stolz (NRC)
Subject:
Control of Heavy Loads May 6, 1983
- 8. American National Standards Institute
" Overhead and Gantry Cranes" ANSI B30.2-1976
- 9. American National Standards Institute
" Standard for Lif ting Devices for Shipping Containers iielghing 10,000 Pounds (4500 kg) or More for Nuclear Materials" ANSI N14.6-1978
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- 10. American National Standards Institute
" Sling s"
. ANSI B30.9-1971 a s
- 11. Crane Manufacturers Association of America
" Specifications for Electric Overhead Travelling Cranes" Pittsburgh, PA CNAA-70 O
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