ML20082P841
| ML20082P841 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, LaSalle, 05000000 |
| Issue date: | 12/02/1983 |
| From: | Barnes P COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR 7659-N, 7659N, NUDOCS 8312090202 | |
| Download: ML20082P841 (5) | |
Text
.
N Commonwealth Edison
) One First Nitionsi Piara, Chicago. Illinois i
O Address Reply to: Post Office Box 767 Chicago, Illinois 60690 December 2, 1983
-Mr. Harold /R. Denton,. Director Office of. Nuclear Reactor Regulation LU.S. Nuclear Regulatory' Commission Washington, OC-20555
Subject:
LaSalle County Station Units 1 and 2 l
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Supplemental Information to the Resolution of " Control of Heavy Loads at. Nuclear Power Plants" NRC Docket Nosc 50-373/374, 50-454/455, 50-456/457
References:
See Attachment A
Dear.Mr. Denton:
References (a) and (b) requested Licensees and Applicants to review controls for-the handling of heavy. loads.
References (c) thru (f) fer'LaSalle County and (c) thru (g) for Byron and Braidwood documented our review and response.
References (g) and-(i) for LaSalle County and (h) for Byron and Braidwood-transmitted draft Technical Evaluation Reports (TERs) by EG&G Idaho, Inc. with References (h) and (j) for LaSalle' County and (1) for Byron and Braidwood documenting our review and. response to those TERs.
The EG&G review of our Phase II response for LaSalle County seems to be based upon a strict interpretation of.NUREG-0612 as
.being.a set of requirements that must be met.
We believe that the reviewer should exercise judgment as to whether or not the Licensee
.has met the. " intent" of the NUREG-0612 guidance document.
In our judgment the intent of the NRC's request for the
' review of controls for the handling of heavy loads is to insure that the risk associated with load-handling failures at nuclear power plants lLs extremely low.. To assist Licensees in their review, the NRC developed guidelines that. offer various alternative approaches
- to ' Licensees-to~ assure thes safe handling of heavy loads.
The
. recommended guidelines listed in References (a) and (b) include Lgeneral-guidelines to reduce ths potential for the uncontrolled
. movement of a " heavy" load or load drop, such as by calling for:
' definition of safe' load paths; development of load handling 8312090202 831202 2
DR ADOCK 05000373 p
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. procedures, periodic inspection and testing of the crane, qualifications, training and specified conduct of the crane operator and use of guidelines on rigging.
Additionally, the NRC guidelines defined acceptable hazard elimination categories for the overhead handling systems operating in the reactor building or in plant areas containing equipment required for reactor shutdown, decay heat removal or spent fuel pool cooling.
These hazard elimination categories were:
1.
Crane travel for this area / load combination prohibited by electrical interlocks or mechanical stops.
2.
System redundancy and separation precludes loss of capability of system to perform its safety-related function following this load drop in this area.
3.
Site-specific considerations eliminate the need to consider load / equipment combination.
4.
Likelihood of handling system failure for this load is extremely small (i.e. section 5.1.6 NUREG 0612 satisfied).
5.
Analysis demonstrates that crane failure and load drop will not damage safety-related equipment.
With regard to the reactor building crane, we believe that our Phase II response for LaSalle County (References (e) and (j))
demonstrated that adequate measures had been taken to insure that the likelihood of a load drop which may potentially damage spent fuel is extremely small.
This was accomplished by using administrative procedures and/or interlocks to keep " heavy" loads away.from spent fuel and safe shutdown equipment, which was defined to be one of the acceptable alternative approaches provided by the NRC (hazard elimination catories 1 and 3 above).
It is our belief that the approach and actions taken by Commonwealth Edison meet the intent of minimizing risk associated with load-handling failures.
Our Phase II response submitted for l
LaSalle County and those to be submitted for Byron and Braidwood should be reviewed based on the approach taken.
With this, we believe that the concerns expressed in the telecon between NRC, EG&G Idaho, and Commonwealth Edison on November 4, 1983 will be resolved.
Should you or your staff have any further questions please contact this office.
Respectfully, A A. %
P. L. Barnes.
Nuclear Licensing Administrator
- cc:
J. G. Keppler - RIII RIII Inspector - LSC/BY/BW L
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4 ATTACHMENT A References - LaSalle County Docket (a):
D. G. Eisenhut letter to All Licensees dated December 22, 198D (TJR 81-9) l (b):
D. G. Eisenhut letter to All Licensees dated February 3, 1981 - Generic Letter 81-07 (TJR 81-40)
(c):
J. S. Abel letter to D. G. Eisenhut dated May 15, 1981 (TJR 81-93)
(d):
E. D. Swartz letter to D. G. Eisenhut dated June 22, 1981 (EDS 81-10)
(e):
E. D. Swartz letter to D. G. Eisenhut dated September 22, 1981 (EDS 81-92)
( f):
E. D. Swartz letter to D. G. Eisenhut dated December 11, 1981 (EDS81-144)
(g):
A. Schwencer letter to L. O. De1 George dated July 2, 1982 (EDS82-144)
(h):
E. D. Swartz letter to D. G. Eisenhut dated October 15, 1982 (EDS 82-17)
(1):
A. Schwencer letter to D. L. Farrar dated June 21,.1983 (EDS83-223)
.(j):
P. L. Barnes letter to H. R. Denton dated September 16, 1983 (NL-83-0277)
References - Byron and Braidwood Dockets 1
(a):
D. G. Eisenhut letter to All Licensees dated December 22, 1980 (TJR 81-9)
(b):
D. G. Eisenhut letter to All Licensees dated February 3, 1981 - Generic Letter 81-07 (TJR 81-40)
(c):
J.
S. Abel. letter to D. G. Eisenhut dated May 15, 1981 (TJR 81-93)
(d):
E. D. Swartz letter to D. G. Eisenhut dated June 22, 1981 (EDS 81-10)
(e):
T.R.
Tramm letter to H. R. Denton dated December 24, 1981 (TRT 81-334)
(f):
T.R. Tramm letter to H. R. Denton dated February 5, 1982 (TRT 82-36)
(g):
T. R.
Tramm letter to H. R. Denton dated Apr11 7, 1982 (TRT 82-83)
(h):
B. J. Youngblood letter to H. R. Denton dated August 2, 1982 (TRT 82-160)
- (1):
T.R.
Tramm letter to H. R. Denton dated October 25, 1982 (TRT 82-223)
(j):
E. D. Swartz letter to H. R. Denton dated Apr11 26, 1983 (EDS83-159)
(k):
T. R.
Tramm letter to H. R. Denton dated June 17, 1983 (TRT 83-173)
(1):
T.R.
Tramm letter to H. R. Denton dated November 7, 1983 (NL-83-0565) l l
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