ML20079N113
| ML20079N113 | |
| Person / Time | |
|---|---|
| Site: | Hatch |
| Issue date: | 01/23/1984 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NED-84-019, NED-84-19, TAC-47007, TAC-47008, NUDOCS 8401300030 | |
| Download: ML20079N113 (15) | |
Text
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- eorgta Power Company 333 Piedmont Avenue Atlanta, Georg.a 30'308 Telephone 404 526-7020 Maeng Address:
Post Offce Box 4545 A!!anta Georg:a 30302 b
Georgia Power tre scchern esectnc system J. T. Beckham, Jr.
Vce President and General t/anagar Nuclear Generation January 23, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Ccmnission Washington, D. C. 20555 NRC DOCITIS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HA'ICH NUCLEAR PLANT UNITS 1,2 NUREG-0612, " CONTROL OF HEAW IDADS AT NUCLEAR POhT:R PLANPS" Gentlenen:
Our letter of July 29, 1983 transmitted a partial report addressing the cmpliance of Plant Hatch Units 1 and 2 with the General Guidelines and Interim Protection Measures of NUREG-0612.
The renainder of that report (Appendix B, Cmparison of Special Lifting Device Design to ANSI N14.6-1978) is hereby subnitted.
Please note that reference is made to certain changes in procedures and modifications to equipuent.
%ese are tenatively scheduled to be cmplete by June 29, 1984.
%is subnittal cmpletes Georgia Power Cmpany's response to the NUREG-0612 General Guidelines and Interim Protection Measures.
Please contact this office if there are any questions.
Very truly yours, 8401300030 840123 gDRADOCK 05000321 4
/
PDR 1, 4_
. T. Beckhan, Jr.
JH/jh
Enclosure:
Appendix B
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t i L. T. Gucwa H. C. Nix, Jr.
P. D. Rice J. P. O'Reilly (NRC-Region II)
Senior Resident Inspector
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APPENDIX B OCMPARISON OF SPECIAL LIPTING DEVICE DESIGN TO ANSI N14.6-1978
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%e. purpose of this evaluation is to determine the extent of empliance of the HNP-l&2 Reactor Head Strongback and the HNP-l&2 Dryer / Separator Sling with Guideline 4 of NUREG-0612.
Franklin Research Center (FRC) has stated in their Technical Evaluation Report (TER) that empliance with Guideline 4 can be denonstrated by addressing those aspects of ANSI N14.6-1978 which are directly related to load bandling reliability. We applicable sections of ANSI N14.6-1978 were identified as:
3.1, Designer's Responsibilities; 3.2, Design Criteria; 3.3, Design Considerations; 4.1, Fabricator's Responsibilities; and 5.0, Acceptance
. Testing, Maintenance, and Assurance of Continued Cmpliance.
GPC has obtained all available docunentation on the design of the subject General Electric (GE) supplied lifting devices.
%e devices have been evaluated with respect to the above criteria as follows:
II. HATCH SPECIAL LIFTING DEVICE EVAWATION SECTION 3.1 - DESIGNER'S RESPONSIBILITIES Subsection 3.1.1
" Limitations on the use of the lifting device" Evaluation ne specific usage of each lifting device is clearly identified on its nameplate as rq uired by the design specification.
We l
fulfillment of the design requirements for materials, fabrication, i
testing and other quality assurance requirenents by the quipnent l
suppliers is discussed in the evaluation for Subsection 4.1.6.
(
Subsection 3.1.2 l
" Identification of critical cmponents and definition of critical characteristics" I
(B-1)
Evaluation A separate critical itms list was not required in the GE specification.
However, based on our review of the available docments, this information has been provided for the critical cmponents that were identified in a stress analysis. 'Ihe analysis 4
is detailed in Subsection 3.2.1.
The available docments provided information such as material identification, chmical and physical properties, type of testing rq uired and acceptance criteria.
Therefore, it is our position that the intent of this subsection has been met.
Subsection 3.1.3
" Signed stress analysis which amonstrates appropriate margins of safety" Evaluation GE did not provide a stress report for the subject devices.
However, an independent stress analysis has been cmpleted for each load bearing cmponent of the subject devices. The details of the analysis are presented in the evaluation for Subsection 3.2.1.
Subsection 3.1.4
" Indications of permissible repair procedures" Evaluation GE's specification rq uired the weldir.g procedure and testing procedures to conform to Appendix "D"
of the American Welding Society code Dl.0.-
(B-2)
l SECTION 3.2 DESIGN CRITERIA Subsection 3.2.1 "Use of stress factors of 3 for minimm yield strength and 5 for the ultimate strength" Evaluation As stated in Subsection 3.1.3, the reluired stress analysis has been performed.
%e analysis covered all load bearing cmponents for the subject devices. With the exception of the hook pins, the stress safety factor of each cmponent met the above criteria. %e book pins are being upgraded to meet the stated criteria.
In the analysis, the load exerted on the caponent is based on the handled load plus the weight of intervening cmponents of the device.
The stress sustained by the caponents is based on the cabined maxim m static and dyn mic loads.
Subsection 3.2.4 "Similar stress design factors for load bearing pins, links and adaptors" Evaluation All load bearing pins, links and adaptors are included in the stress analysis which was noted in the evaluation of Subsection 3.2.1.
Subsection 3.2.5
" Slings used emplied with ANSI B30.9-1971" (B-3)
Evaluation
%e HNP-l&2 Dryer / Separator Sling assably has a 4-leg apparatus.
Each wire rope is made of the standard 6 x 19 improved steel of wire centered construction. The factor of safety for the slings is 5, whichi is based on the cabined maximum static and dynmic loads.
The slings, therefore, are in full cmpliance with ANSI B30.9-1971.
Subsection 3.2.6
" Subjecting materials to ' drop weight testing or Charpy impact testing" i
Evaluation Dynmic testing such as drop weight or Charpy impact tests was not required in the GE specification.
However, the ability of the devices to withstand the subject dynmic load can be deonstrated by the following facts:'
l.
The stress contributed by the dynamic load was included in the determination of the stress design f..etors.
With the exception of the hook. pins, the calculated stress design factor for each load bearing cmponent met the rquirments of the ANSI N14.6-1978 Subsections 3.2.1 and 3.2.4.
2.
As stated in the evaluation for Subsection 3.2.1, the book pins are being upgraded to meet the rquired standards.
The pins will be subjected to the magnetic particle tests after repairs.
3.
ne mill test reports indicated that all the load bearing caponents have a relatively high degree of ductility.
Furthemore, with the service temperature at about 70 F, the material will maintain its initial ductility range.
(B-4)
Even though the materials were not subjected to impact testing, it is our conclusion that the reliability of the special lifting devices is not empreised for the above reasons.
SECTION 3.3 DESIGN CONSIDERATIONS subsection 3.3.1 p-
" Consideration cf problens related to possible laellsr tearing" Evaluation It could not be verified that problens related to possible laellar tearing were considered by GE when the materials for the subject devices were selected.
However, if 1 mellar tearing had been present frm the time when welding was empleted, we believe that the original lanellar tears would have grown and propagated under the-influence of the operating loads.
%is assessment is reasonable when the fact that the equipnent has been operated for seven or more years is considered. %e equipnent is also subjected to inspection on a regular basis and no problems have been found.
%erefore, it is unlikely that 1mallar tearing had occurred.
Based on the above, we believe that there is sufficient assurance that lanellar tearing is not an issue for the subject devices.
_ Subsection 3.3.4'
" Design shall ensure even distributione of the load" Evaluation
%e load bearing nmbers in each device are designed to carry an 3
equal share of the load.
(B-5) l
Subsection 3.3.5 "Petainers fitted for load-carrying camponents which may became inadvertently disegaged" Evaluation he ball lock pins are used to secure the hook pins onto the subject devices.
Subsection 3.3.6
" Verification that renote actuating mechanims securely engage and disengage" Evaluation A
renote pnetnatically-operated mechanim is used on the Dryer / Separator Sling assenbly to insert end socket pins into the lifting lugs.
We availability of adequate pressure in each actuating cylinder is indicated by an individual pressure gauge on the renote control box.
As a strict procedural requirenent, canplete insertion of each pin is verified by visual exmination before a lift.
SICTION 4.1 FABRICNIOR'S RESPOSIBILITIES Subsection 4.1.3
" Verify selection and use of material" Evaluation A certified material list for each device has been provided by the fabricator which stated its cmpliance with the GE specification.
(B-6)
+
Subsection 4.1.4 "Canpliance with fabrication practices" Evaluation The detailed fabrication process was not epecified in the design specification. However, based on the qualification of the material suppliers as GE's approved vendors and their cubnitted material's chenical and physical reports, it is concluded that the industry accepted fabrication practices have been used. Based on the above, we consider that the special lifting devices used at Plant Hatch meet the intent of this subsection of ANSI N14.6-1978.
Subsection 4.1.5 "Qualf fication of welders, procedures, and operators" M 1uation
%e fabricator's welding procedure qualification test reports show that personnel, procedure and testing anployed in the welding are in accordance with ASME Section IX.
Subsection 4.1.6
" Provision for a quality assurance program" Evaluation l
Based on the available quality assurance doctrnents, it is indicative that a proper quality assurance prograa was enforced during the design aM fabrication of the subject devices.
The available doctrnents include the following:
(B-7)
1.
Certified material list - identifies the cmponents, material specification and suppliers 2.
Certified chemical and physical test reports certifies the material and 3.
Certificate of compliance fabrir:ation process are furnished in accordance with the specification 1
4.
Certified ultrasonic and magnetic particle inspection records includire detailed results and acceptance criteria 5.
Certified proof load test results and acceptance criteria 6.
Certified welding procedure qualification test record.
Subsection 4.1.7
" Provision for identification and certification of material" Evaluation
'Ihe evaluation provided for Subsection '3.1.2, 4.1.3 and 4.1.6 shows that the required identification and certification of materials have been furnished by the equipment suppliers.
Subsection 4.1.9
" Verification that materials or services are produced under appropriate controls and qualifications" (B-8)
i t
j Evaluation ne evaluation provided for Subsection 4.1.6 indicates that the required inspections and tests have been performed by the equipnent suppliers.
%e subnitted certificates of ccinpliance by the suppliers indicated that materials and processes used are within the reguried specifications and meet the criteria dictated by the inspection procedures.
SECTION 5.0 ACCEPTANCE TESTING, MAINTENANCE, AND ASSURANCE OF CONTINUED CXMPLIANCE Subsection 5.1.3 "Implenentation of a periodic testing schedule and a system to indicate expiratlon" Evaluation All special lifting devices are required by the procedure HNP-6975 to be tested at a frequency as specified in ANSI N14.6-1978. his procadure is also being updated to include a rcquirenent for verification that the latest test has not expired.
Subsection 5.1.4
" Provisions for establishing operating procedures" Evaluation
%e proper use and maintenance of each special lifting device is
'oecified in the procedures HNP-6977 and 6975.
(B-9)
1 l.
Subsection 5.1.5.1
" Identification of subassemblies which may be exchanged" Evaluation Each of the special liftity devices is unk ue and restricted to the l
services that are designated on its nameplate.
% erefore, their suoassenblies are not exchangeable.
Subsection 5.1.5.2
" Suitable markings" Evaluation he specific usage and load rating of each special lifting device are identified on its nameplate.
Subsection 5.1.5
" Maintaining a full record of history" Dealuation he procedure HNP-6975 is being updated to include a tajuirement for the Maintenance Department to keep an active record of all maintenance, inspection 3nd testing work for all special lifting devices.
Subsection 5.1.7
" Conditions for renoval for service" (B-10)
Evaluellon If any unsafe condition is found in a special lifting device the procedure HNP-6975 rauires that the device be returned to the Maintenance Tool Shop.
A tag is the placed on the equipnent which identifies the defective itens.
%e equipnent cannot be returned to service until all the defective itens have been corrected.
Subsection 5.2.1 "Ioad test of 150% and appropriate inspection prior to initial use" Evaluatica All special lifting devices have been load tested at 150% of the maximtsu handling load prior to initial use. All load-bearir.g welds were subjected to magnetic particle test before and after the load test.
Subsection 5.2.2
" Qualification of replacanent parts" 1
Evaluation
%e procedure HNP-6975 is being updated to include the qualification reluirenents for replacenent parts as defined in this subsection.
Subsection 5.3.1
" Satisfy annual load tests or inspection requirenents" (B-ll)
t Evaluation As required by the procedures'HNP-6977.and 6975 all special lifting devices are subjected to the test and inspection' requirments as specified in this subsection.
Subsection 5.3.2
" Testing following major maintenance" Evaluation i
%e procedure HNP-6975 is being updated to include a requirement to subject a special lifting device which has been extensively repaired to the test and inspection requirments as specified in this subsection.
J subsection 5.3.4 4
" Testing after application of. substantial stresses" f
Evaluation
%e use of each lifting device under this evaluation is restricted to the cervices that are designated on its neeplate.
% erefore, an overloading of a device is highly unlikely.
However, if a device were subjected to an overstress condition during a lifting event, the procedure HNP-6975 requires that the affected emponents in the device be tested and inspected per the requirements of this subsection.
Section 5.3.6_
" Inspection by operating personnel" (B-12)
Evaluation Per the procedures HNP-6977 and 6975, the special lifting device is required to be visually inspected by operating personnel prior to each use.
4 Subsection 5.3.7 i
e
" Inspections by non-operating or maintenance personnel" Evaluation
%e procedure HNP-6975 is being updated to include the inspection rq uirements as indicated in this subsection.
III.CINCWSION i
1
'Ihe preceding evaluation d eonstrates 'that the design, fabrication, testing.and maintenance.of the subject special lifting devices emplies with the guidelines _'of ANSI N14.6-1978 to a substantial degree. For the limited cases mentioned in Subcections 3.2.6, 3.3.1, and 4.1.4, where compliance could not be verified directly, it is determined that the reliability is not cmpromised for the reasons as stated in the evaluation.of the respective subsections. In addition, as noted in the specific subsections, various plant procedures are being upgraded to j
assure empliance with the requirments. We therefore conclude that the design', fabrication, testing and maintenance of the HNP-l&2 Reactor Head Strongback and Dryer / Separator Sling assembly meet the intent of NUREG-0612 Guideline 4.
S s
(B-13)
-