ML20084P026

Control of Heavy Loads at Nuclear Power Plants,Enrico Fermi Atomic Power Plant,Unit 2 (Phase I)

ML20084P026
Person / Time
Site:	Fermi
Issue date:	03/31/1983
From:	Shaber C EG&G, INC.
To:	Stickley T NRC
Shared Package
ML20084P028	List: ML20084P026 ML20085J790
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-6191, NUDOCS 8306090292
Download: ML20084P026 (40)

Text

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o ENCLOSURE 2 EGG-FiS-6191 s

i CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS ENRICO FERMI ATOMIC POWER PLANT, UNIT 2 (PHASE I)

Docket No. 50-341 Author C. R. Shaber Principal Technical Investigator T. H. Stickley Published March 1983 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 3

Prepared for the U.S. Nuclear Regulatory Comission Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6457 XA C py Has Been SenUo.PDR g30 6 M/02 9

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EXECUTIVE

SUMMARY

Enrico Fermi Atomic Power Plant,~ Unit 2 is not in total compliance with the guidelines of NUREG-0612. In general, their submission concerning compliance is excellent, and upon completion of planned actions there'will be compliance with guidelines 1, 2, 3, 5, 6, and 7. A suitable course of action is necessary as follow-up to the remaining reviews of specific components of the special lifting devices, to meet Guideline 4.

The main report contains summaries and comments which will aid in understanding the pencling actions required to reach full compliance with the appropriate guidelines.

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a s ABSTRACT '

The Nuclear Regulatory Commission (NRC) has requested that all n': lear

. plants either operating or under construction submit a response of complf-ance with NUREG-0612, "Contro1 ~ of Heavy Loads at Nt. lear 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 ev .luation and recommendations for Enrico Fermi Atomic Power Plant, Unit 2.

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CONTENTS Pace

1. INTRODUCTION .................................................... 1 1.1 Purpose of Review ......................................... 1 1.2 Generic Background ........................................ 1 1.3 Plant-Specific Background ................................. 3

2. EVALUATION AND RECOMMENDATIONS .................................. '4-2.1 Overview .................................................. 4 2.2 Heavy Load Overhead Handling Systems ...................... 4 2.3 General Guidelines ........................................ 5 2.4 Interim Protection Measures ... ........................... 18 i

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3. CONC LUD I NG S UMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 3.1 Applicable Load-Handling Systems ............ ............. 20 3.2 Guideline Recommendations ................................. 20 .

3.3 Interim Protection ........................................ 24

4. REFERENCES ...................................................... 25 TABLE 3.1 Enrico Fermi Atomic Power Plant Unit 2, NUREG 0612 Compliance Matrix ............................................... 21 i

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.- s TECHNICAL EVALUATION REPORT FOR ENRICO FERMI ATOMIC POWER PLANT, UNIT 2

1. INTRODUCTION 1~ 1 Purpose of Review This technical evaluation report documents the EG&G Idaho, Inc., " review of general load-handling policy and procedures at Enrico Fermi Atomic Power Plant, Unit 2 (Fermi 2). This evaluation was performed with the objective of assessing conformance to the general load-handling guide-lines of NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants" [1], Section 5.1.1.

1.2 Generic Background Generic 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 maasures. This activity was initiated by a letter issued by the NRC 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 i

certain potential problems, do not adequately cover,the major causes of load-handling accidents and should be upgraded.

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'In orded to upgrade measures for the control of heavy loads, the staff developed a series of guidelines designed to achieve a two phase objec-tive using an accepted approach or protection philosophy.< The .fi.rst - -

portion pf the objective,, ~ achievedI throug$ a. se,t'of genera.1[guideJinesE - *)

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i identifikd in[NUREG-0612','Ar.ticle E.1'.1, is to' ensure that all load-r {

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.handlingJ systems at nuclear power plants areIcies'igned and' operated such that their- probability 'of- failure is uniformly 'smal.1; and appropriate J. Q-h b ~ ^-

for the :ritical'ta. ski _in which 7 they,are emplSyed., sThe'se. ednd.p$rti6n ' 'u - -

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of the s,kaff's object'ive, ~ achieved through guidelines d.i' entified in ~

p , NUREG-0612, Articles 5.1.2 through 5.1'.5 is, to ensu.re that, for' load-a handling;systemsinareaswheretheirfailuremightresult.insignifi- _ .

cant conkcquences, 'either (1) features' are provi.ded,- in. addition [to c. z"N;kf

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) those re ired fdr ail lo'ad-h'a[1chlin% I'ystims,~.'to' ensure that the.po' ten-tial for ~a load-drop is extremely small (e.g., a single-failure proof crane), or (2) conservative evaluations of . load-handling accidents indicate that the potential consequences of any load drop are accept-ably.smali. Acceptability cf accident consequences is quantified in NUREG-0612 into four accident analysis evaluation criteria.

i The approach used to develop i.he staff' guidelines for minimizing the kt potential.for a load. drop was based on defense in depth and is summarized as follows:

o Provide sufficient operator training, handling system '

design, load-handling instructions, and equipment-inspection

'to assure reliable operation of the handling system o Define safe load travel path' sthrough procedures and operator training so that, to,the extent practical, heavy '

[cadsarenotcarriedoverornearirradiatedfuelorsafe shutdown equipment t 9.-

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o Provide mechanical stops or electrical interlocks to prevent movement of heavy loads over irradiated fuel or in roximity

, to equipment associated with redugdant shutdown paths.

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

1.3 Plant-Specific Backoround On December 22, 1980, the NRC issued a letter [3] to Detroit Edison, the Applicant for Fermi 2 requesting that Detroit Edison review provi-sions for handling 'and control of heavy loads at Fermi 2, 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 December 3, 1981, Detroit Edison provided the initial response [4a] to this request. On June 3, 1982, additional information and drawings [4b]

were submitted. On October 15, 1982, following discussions of an analysis of the previous responses, an improved report [4c] intended to resolve comments and upgrade the Detroit Edison submittal, was made These provide the current and a comprehensive report on conformance '

with the guidelines.

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2. EVALUATION AND RECOMP.ENDATIONS

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2.1 Overview-The following' sections summarize Detroit Edison's review of heavy load handling at Fermi'2 accompanied by EG&G's evaluation, conclusions, and -

recommendations to Detroit Edison concerning compliance with the intent of NUREG-0612. _ The response did not specify the weight of a single ,

spent-fuel element and its handling tool, the NUREG-0612 definition of un heavy load. However, the Detroit Edison specifically identifies, fbr their use, heavy load es " greater than one ton."

2.2 Heavy Load Overhead Handling 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 mentioned list.

2.2.1 Scope

" Report the results of your review of plant arrangements to identify all overhead handling systems from which a load drop 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. detailed structural analysis) and justify the exclusion of any overhead

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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 shutdow; or decay heat removal."

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. s A. Summary of Aoplicant Statements

, The Applicant's review of overhead handling systems ide ified cranes and hoists, then provided separate tables to she,- "Hcists Capable of Handling Loads Over Spent Fuel or Shutdown Safety

. System Components," and " Overhead Hoists Exempt From Further Analysis Because They Cannot Handle Heavy Loads Over Spent Fuel or Shutdown Safety System Components." They identified and excepted cranes and hoists located in buildings that do not contain safety equipment needed for safe unit shutdown. Th'e October 15, 1982, submittal supplements the original ones by adding data'on additional hoists and information on six hoists yet to be specified for purchase. They state, "These hcists and any future cranes or hoists that fall within the concerrs of NUREG-0612 will meet the design guidelines of NUREG-0612."

B. EG&G Evaluation The responses indicate that comprehensive reviews have been cade and identification is complete for present and expected noists within the specified scope.

C. .EG&G Conclusions and Recommendations EG&G concludes that Detroit Edison has included all app ! cable

, hoists and cranes in their list of handling systems whic must comply with the requirements of the general guidelines cf NUREG-0612.

2.3 General Guidelines This section addresses the extent to which the applicable hartling sys-l tems comply with the general guidelines of NUREG-0612 Article 5.1.1.

EG'&G's conclusions and recommendations are provided in summarf es for each guideline.

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The NRC has established seven general guidelines which must be 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:

• A. Guideline 1--Safe Load Paths -

B. Guideline 2--Load-Handling Procedures C. Guideline 3--Crane Operator Training ,

D. Guideline 4--Special Lifting Devices E. Guideline 5--Lifting Devices (not specially designed)

F. Guideline 6--Cranes (Inspection, Testing, and Maintenance)

-G. Guideline 7--Crane Design.

These seven guidelines should be satisfied for all overhead handling systems and programs in order 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 succeeding paragraphs address the guidelines individually.

2.3.1 Safe Load paths [ Guideline 1, NUREG-0612, Article 5.1.1(1)]

" Safe load paths should be defined for the movement of heavy loads to minimize the potential for heavy loads', if dropped, to impact irradiated fuel in the reactor vessel and in the spent-fuel pool, or to impact safe shutdown equipment. The path i should follow, to the extent practical, structural floor members, l beams, etc., such that if the load is dropped, the structure is l more likely to withstand the impact. These load paths should be defined in procedures, shown on equipment layout drawings, and clearly marked on the floor in the area where the load is to be .

handled. Deviations from defined load paths should require

, written alternative procedures approved by the plant safety I

review committee."

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E A. ' Summary of-Applicant Statements The Applicant has revised their refueling equipment laydown location drawings. The laydown locations had travel paths to them for the reactor crane and the main and auxiliary hoists utilize the criteria of NUREG 0612. Also, the Fermi 2 plant has completed 16 procedures and has one under develop-2

, ment'that addresses administrative, rigging, and load-4 handling concerns of.NUREG 0612. The procedures include i definitions of " Safe Load Paths" and prior to refueling will, wherever practical, require floor lines to show the

- heavy load paths.

Because of the high strength integrity of the fueling floor (fifth floor) due to its heavily reinforced, _24-inch thick construction, very little added strength is achieved along the building column lines. However, travel paths along these column lines have been established where it is practicable, to keep the travel and placement as simple as possible so as not to confuse operators and supervisors.

The established travel paths now on drawings will be included in specific maintenance procedures developed prict to criticality with the exception of the procedure for the 4

spent-fuel cask which will be developed prior to handling after criticality. -An initial step in the procedures will require the person responsible for performing the lift to verify the safe load path is free of obstructions that would interfere with the movement of the load. Because of the high strength integrity of the fueling floor at all locations and the separation of_ redundant safety systems located below the fueling floor, deviations from the travel paths shown on the drawings do not notably increase the consequences of any potential accidents, as long as these 7

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deviations do not traverse over the Reactor, Fuel Storage ,

Pool, and Equipment Hatch areas. Therefore, the placement

, of painted travel path lines for each, heavy " load offers very little advantage and could cause confusion. However, painted ,

barrier lines and signs will be established arouH the Reac-tor, Fuel Pool, and Equipment Hatch areas. Additionally, painted travel paths will be provided for the five major loads handled over the fifth-floor deck. These include the ,

Reactor Shield Plugs, Reactor. Vessel Head, Drywell Head, Spent-Fuel Cask, and the Equipment Storage Pool Slot Plugs.

For significant loads, placement of temporary markers will identify the load path.

B. EG&G Evaluation The actions reported and planned should fully satisfy the safe load path guidelines.

C. EG&G Conclusions and Recommendations The scope and intent of the guideline appears to be properly recognized. Completion and execution of the plans will sat-isfy the NUREG 0612 requirement.

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, pro-cedures should cover handling of those loads listed in Table 3.1-1 of NUREG-0612. These procedures should include: identification of required equipment; inspections and acceptance criteria required before movement of load; the steps and prpper sequence to be followed in hand)ing the load; defining the safe path; and other special precautions."

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A. Summary of Applicant Statements

, Detroit Edison has committed to complete their written pro-

, cedures prior to criticality. Unanticipated load-handling procedures will be written prior to the handling. The pro-cedures will meet NUREG 0612. A table was provided that lists heavy loads carried by each crane along with desig-nated lifting devices. In order to control future heavy loads to be handled over or.near spent fuel.or required safe shutdown equipment, the procedures governing the operat' ion of the Reactor Building Crane, Monorails, and Portable Hoists will require the guidelines of NUREG 0612 be invoked by either specific maintenance procedures or by attachment to maintenance orders / work packages prior to movement of heavy loads in these areas. Of 17 procedures listed,16 have been written and approved. Some revisions are needed to incor-parate additional commitments contained in the October 15, 1982, response.-

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. EG&G Evaluation Both recognition and action is progressing effectively.

C. EG&G Conclusions and Recommendations

, (1) It is concluded that planned actions upon completion, before fuel is handled in the plant, will comply with the requirements of Guideline 2.

2.3.3 Crane Operator Training [ Guideline 3, NUREG-0612, Article 5.1.1(3)]

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" Crane operators should be trained, qualified, and conduct them-selves in accordance with Chapter 2-3 of ANSI B30.2-1976, 'Over-head and Gantry Cranes' [5]."

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%. The Applicant's Statement

, Operator training, qualification, an.d conduct will be in com-pliance with the requirements of ANSI B30.2-1976 for :pera- -

tion of overhead traveling cranes. Operators of varicus types of cranes will be trained and qualified to the appro-priate standard for the specific type of equipment to be used. Records of personnel training and qualification will ,

be retained. This training program will be administered by the Nuclear Ope, rations Training Group. The training program will be implemented prior to fuel loading and those indivi-duals operatirg cranes / hoists will be qual 1fied prior to involvement with any post-criticality heavy-load-handling event.

B. .EG&G Evaluation The ANSI B30.2 Chapter 2-3 and appropriate standards for specific other types of equipment being used as the guide for selection and training, meets the general require ents for Guideline 3.

• C. EG&G Conclusion and Recommendations Upon completion of the planned actions, Detroit Edisor Company will be in compliance with Guideline 3, at Enrico Fermi Unit 2.

2.3.4 Special lifting Devices [ Guideline 4, NUREG-0612, Article:5.1.1(4)] -

"Special lifting devices should satisfy the guidelines of ANSI N14.6-1978, ' Standard for Special Lifting Devices for Ship;ing Containers Weighing 10,000 Pounds (4500 kg) or More for Nu: lear Materials' [6]. This standard should apply to all special 10

lifting devices which carry heavy loads in areas as defined 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 design. 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 Applicant Statements To date, there are only three lifting devices provided for the handling of heavy loads that would fall within the guide-lines of ANSI N14.6-1978, as defined in NUREG-0612. These are the RPV Head Strongback, the Dryer / Separator lifting device, and the Vessel Head Insulation Spreader Beam. A design review conducted by the designer, General Electric, finds that the RPV Head Strongback and Dryer / Separator lift-ing device are in full compliance with the strength criteria of Section 3.2 of ANSI N14.6-1978; taking into account the combined static and dynamic load forces. However, certain components in these lifting devices do not meet the addi-tional strength criteria of Section 6.2 for single-failure-proof systems. Although General Electric recommwndations do not find it practical to modify all of these components to meet this criteria, this is still being reviewed by Detroit Edisen Company. Action determined by this review on any pos-sible modifications or additional analyses will be initiated prior to fuel load and will be completed prior to the use of these devices after initial criticality.

The Vessel Head Insulation Spreader Beam is being designed to achieve compliance with the ANSI N14.6 strength criteria for combined static and dynamic load forces.

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c> c The Spent-Fuel Cask handling system is accepted as single-failure proof and is addressed in detail in the Enrico Fermi

_ FSAR, Section 9.1.4.2.1. .. ._ _ _ _ _

All other special lifting devices and slings will be pur-chased to ensure that the , equirements of ANSI N14.6-1978 -

and ANSI B30.9-1971 are satisfied.

4 B. EG&G Evaluation -

The applicant has complied with the requirements of Guide-line 4, except for those components failing to meet Sec-tion 6.2 of N14.6.

C. EG&G Conclusions and Recommendations Until Detroit Edison's reviews are complete and a course of action is determined, EG&G cannot make judgments on the adequacy of the components under'studyt Other special lifting devices comply with Guideline 4.

2.3.5 . Lifting Devices (Not Specially Desicned) [ Guideline 5, NUREG-0612, Article 5.1.1(5))

" Lifting devices that are not specially designed should be installed and 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 of the static and maximum dynamic load. The rating identified on the sling should be in '

terms of the ' static load' which 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. Summary of Aoplicant Statements

, Slings used for construction.wil.1,not be retained for handling of heavy loads around critical equipment after the plant is operational.

The requirements of-the stress design factor will include the maximum static and dynamic loads as defined by NUREG-0612. Any single-failure proof handling system will also meet the requirements of NUREG-0612, Section 5.1.6.

Additionally, the static rating of each sling will be clearly marked on the sling as well as any information which might restrict the sling to only certain cranes and loads.

B. EG&G Evaluation The planned future actions for lifting devices will, upon completion as stated, meet the requirements of Guideline 5.

C. EG&G Conclusions and Recommendations Completion of the pending purchase and labeling requirements will bring Enrico Fermi Plant 2 into compliance with Guideline 5.

2.3.6 Cranes (Inspection, Testino, and Maintenance) [ Guideline 6 2 NUREG-0612, Article 5.1.1(6))

"The-crane should be inspected, tested, and maintained in accord-ance with Chapter 2-2 of ANSI B30.2-1976, ' Overhead and Gantry Cranes,' with the exception that tests and inspections should be performed prior to use where it is not practigal to meet the frequencies of ANS.I B30.2 for periodic inspection and test, or 13 1

where frequency of crane use is less than the specified inspec-tion and test frequency (e.g., the polar crane inside a PWR con-tainment may only be used every 12 to 18 months during refueling

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operations, and is generally not accessible during power oper-

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ation. 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 Applicant Statements The reactor building crane, main and auxiliary hoists, crane inspection, testing, and maintenance procedures will comply with the guidelines in ANSI B30.2-1976, Chapter 2-2. Should any deviations from this standard be required,' they will be equivalent to the requirements of ANSI B30.2-1976. The requirements of this standard will be incorporated into the Reactor Building Crane General Maintenance Procedures No. 35.000.120. This procedure will be written prior to f;e1 loading.

- For all other overhead _ hoists, inspection, testing, and maintenance procedures will comply with ANSI B30.16-1973, Chapters 1.2 and 2.2.

B. EG&G Evaluation Since procedures are to be written and since ANSI-B30.2 Chapter 2-2 or B30.16 will be used for conformance guides, the specified guideline can be met. Both of the ANSI '

documents conformance requirements include inspection, testing, and maintenance.

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C. EG&G Conclusions and Recommendations

, Upon completion of the. procedure wtjting for plant cranes and hoists inspection testing and maintenance requirements and follow-up action, Enrico Fermi Plant 2 will be in compliance with Guideline 6.

2.3.7 Crane Deston [ 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 B30.2-1976, ' Overhead and Gantry Cranes,' and of CMAA-70, ' Specifications for Electric Overhead Traveling Cranes' [8]. An alternative to a specification in ANSI B30.2 or CMAA-70 miy be accepted in lieu of specific compliance if the intent of the specification is satisfied."

A. Summary of Applicant Statements The reactor building main crane is the only single-failure-proof crane at tne plant site. The Enrico Fermi 2 Atomic Power Station FSAR, Section 9.1.4.2.1, describes the single-failure proof design features incorporated in the 125-ton crane. -

The Fermi 2 Reactor Building Crane was designed under the EOCI No. 61, " Specifications for Electric Traveling Cranes."

However, additional, upgraded criteria included in the later CMAA 70-1976 specification was already a part of the manufacturer's design practices. As part of the recent Det roit Edison submittal, analyses were included to show that CMAA criterion that differ from EOCI-61 have been satisfied concerning:

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o Design stress shall not exceed 20% of the published average ultimate strength of the material

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o' Welding design and procedure conform to AWS D14.1 and -*

material conforms to ASTM A-36 o Impact allowance minimum is 15% of rated capacity of hoist for speeds up to 30 FPM o Twisting moments due to overhanging loads and lateral

• forces acting eccentric to the horizontal neutral axis of a girder are calculated based on distance between the load c of g and the girder section shear center o Longitudinal stiffener is_ to be located 0.4 times the distance from the compression flange inner surface to the neutral axis o- b/c ratios between 38 and 52, girder allowable compressive stress values are less than EOCI-61 criteria o Diaphragm plate thickness is sufficient to keep the trolley wheel load-bearing stress within 26.0 ksi o Allowable vertical stresses without impact shall be 14.4 ksi tension or compression o ' Rated capacity load plus the bottom block weight divided by the number of parts of rope must not exceed s20% of the published rope breaking strength

• o -The drum shall be designed to withstand c,ombined crushing and bending loads 16

o . Minimum drum groove depth is 3/8 x rope diameter (minimum drum groove pitch is 1.14 + rope diameter or rope diameter + 1/8 in., whichever is less)

Horsepower rating of gearbox gearing.shall be based

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o upon AGMA Standards o Holst motion, holding brakes meet minimum specified torque requirements _

o Bridge and trolley bumpers shall be rigidly mounted and capable of stopping the crane within specified deacceleration limits o Provides criteria that addresses static control o Provides for protection to prevent motors from restarting upon restoration from a power loss until control handles are brought to the off position. ~

For all other overhead hoists listed by Fermi 2, CMAA 70 and ANSI B30.2 are not the applicable standards for these hoists. ANSI B30.16-1973 is the applicable standard. The recirculating pump hoists design does conform to this standard. The remaining hoists, which

, are not yet purchased, have been specified to conform to ANSI B30.16.

B. EG&G Evaluation The applicant has provided adequate information to show that Fermi 2 meets Guideline 7. ,

C. EG&G Conclusion and Recommendation Fermi 2 is in compliance with Guideline 7, EG&G has no recommendations.

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4 12 . 4 Interim Protection Measures

, The NRC staff has established (NUREG-0612, Article._5.3) that six measurts should be initiated to provide reasonable assurance that '

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

o Heavy load technical specifications o Special review for heavy loads handled over the core.

Applicant implementation and evaluation of these interim protection measures is contained in the succeeding paragraphs of this section.

2.4.1 Interim protection Measure 1 - Technical Soecifications

" Licenses for all operating reactors not having a single-failure-proof overhead crane in the fuel-storage pool area should be revised to include a specification comparable to Standard Tech-nical Specification 3.9.7, ' Crane Travel - Spent-Fuel Storage Pool Building,' for PWRs and Standard Technical Specification 3.9.6.2,

' Crane Travel ' for BWRs, to prohibit handling of heavy loads over 1

fuel in the storage pool until implementation of measures which l satisfy the guidelines of Section 5.1."

A. Summary of Licensee Statements The Applicant is not operational at the Fermi 2 plant and '

t interim protection was not addressed.

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8. EG&G Evaluation

, None ._ _ , _ . _

C. EG$GConclusionsandRecommendations None 19

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3. CONCLUDING

SUMMARY

3.1 Aeplicable lead-Handling Systems Based on the information supplied, EG&G concludes that the list of cranes and hoists provided by the Detroit Edison as being subject to ,

the provisions of NUREG-0612 is adequate (see Section 2.2.1).

However, the justifications for excluding cranes not included should ,

be available in the event of an audit. .

3.2 Guideline Recommendations Compliance with the seven NRC guidelines far heavy load handling (Section 2.3) is progressing satisfactorily at Fermi 2. This  !

-conclusion is represented in tabular form as Table 3.1. Specific

. recommendations to aid in compliance with the intent of these guidelines are provided as follows: ]

Guideline Recommendation

1. (Section 2.3.1) Safe Lead Paths

a. Complete the plans for safe load paths where practicable. Where j ,

impractical, use the other

! temporary means as planned and Enrico Fermi Plant 2 will be in compliance with Guideline 1.

e 20 f - .,-._.

e TABLE 3.1. ENRICO FERMI A10MIC POWER PLANT UNil 2, NUREG 0612 COMPLIANCE MATRIX Weight Guideline 1 Guideline 2 Guideline 3 Guideline 4 Guideline 5 Guideline 6 Guideline 7-or Crane Special trane-Test Equipment Heavy loads Capacity Safe Load Operator Lifting and Ibstonation (tons) (tons) Paths Procedures Training Devices Sllnes inspection Crane Desten Rea. Bldg Crane Main Shield Plugs & 24 more 125 C R R I R R C 9 Holst Rea. Bldg. Crane Aux Maint Tools & 3 more 5 C R R C R R C lbist NLS Torus flatch NLS Floor Itatches 5 C R R C R R C lbist itPCI Iloist ,HPCI Floor Shield Plug 12 C R R C R R C HCIC lbist Floor Hatches & Turbine 10 C R R C R R C RHR Pumps-Div. 1 Itatches & Motors 16 C R R C R R C B' set Holst e

RHR Pumps-Div. B' sat Hatches & Motors 16 C R R C R R C rv. Holst RHR Pumps-Div. I Hatches & Motors 16 C R R C R R C a

ist Fl. Ibist RHR Pumps-Div. 11 Hatches & Motors 16 C R R f R R C ist Fl. Ibist h&S Recir. Pump MG Set Fluid Dr. 25 C R R C R R i C lbtsts MG Stes, N, C, & 5 m Set Fluid Dr. 12 C R R C R R C lbists MG Set Fluid Dr. MG Set Fluid Dr. 20 C R R C R R C i N&S lbist CRD Repair Holst CRD Transfer Cask 3 C R R C R R C Core Spray Div 1. Ist F1. Hatches 16 C R R C R R C lloist Core Spray Div II. Basement laa tches 16 0 R R C R H C lbtst 4

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. TABLE 3.1. (continued)

Weight Guideline 1 Guideline 2 Guideline 3 Guideline 4 Guideline 5 Guideline 6 Guideline 7 or Crane Special Crane-Test Iquit wnt licavy loads Capacity Safe Load Dperator Lifting and .

Deslanation (tons) (tons) Paths Procedures Training Devices 51Ines inspection Crane Desten Diesel Gen. Div. I

• 2 C R R C R R- C-N&S Holst (2 each)

Diesel Gen. Div. 11

• 2 C R R C R R C N&S Holst (2 each) ,

Diesel Cen. NCC

• 1 C R R C R R C Div. I Holst (2 each)

• C R C Diesel Gen. MCC 4 C R R R Div. II Holst (2 each)

Vent. Eqpt. Rs.

• 8 C R R C R R C Holst m Cranes listed as N exempt from analysis because they cannot handle heavy loads are not included here. .

C = Licensee action conplies with NUREG-0612 Guideline. I NC = Licensee action does not comply with NUREG-0612 Guideline

• R = Licensee has proposed revisions / modifications designed to comply with NUREG-0612 Guideline.

I = Insufficient information provided by the Licensee. (

• To Be Determined by Ut111ty l e

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Guideline Recommendation

2. (Section 2.3.2) Load-Handling Proc.edures_

a. Planned actions upon completion, before fuel His handled in the plant, will meet the requirements of Guideline 2.

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3. (Section ;2.3.3) Crane Operator Training

a. Upon completion of the reported training plans Enrico Fermi Plant 2 will be in compliance with

' Guideline 3.

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4. (Section 2.3.4) Special Lifting Devices

a. Detroit Edison Company should complete reviews of certain compone.its, determine a course of action, and Tslifre that Guideline 4isfuilymot.

5. (Section 2.3.5) Special. Lifting Devices

a. Complete the planned purchase of new lifting devices to assure their availability in time to have them properly labeled

~

before needed for fuel-4 a

23 g - r,--w ,~ y .-o- ,-r-,- g , -~w >,,-,-,,,--g --n - -- -c- , ve-- -

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Guideline Recommendation

,, handling, or use during reactor operations. This will assure compliance with Guideline 5. .

Maintain documentation to confirm the adequacy of ,

the lifting deyice rating.

6. (Section 2.3.6) Crane Inspection, Testing, and Maintenance

a. Complete the planned procedures and their application for crane inspection, testing, and maintenance and Enrico Fermi Plant 2 will be in compliance with Guideline 6.

7. (Section 2.3.7) Crane Design

a. None.

l l 3.3 Interim Protection i .

EG&G's evaluation of information provided by the Applicant indicates that the following actions are necessary to ensure that the six NRC staff measures for interim protection at Fermi 2 are met:

Interim Measure Recommendation l

The Fermi 2' plant is not in operation so interim requirements do not apply. .

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4. REFERENCES 4

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

2. V. Stello, Jr. (NRC)

Letter to all licensees.

Subject:

Request for Additional Information on Control of Heavy Leads Near Spent Fuel NRC, 17 May 1978

3. USNRC Letter to Detroit Edison.

Subject:

NRC Request for Additional Information on Control of Heavy Loads Near Spent Fuel NRC, 22 December 1980 4a. Detroit Edison Letter to USNRC.

Subject:

Control of Heavy Loads Over or in Proximity to Irradiated Fuel. Mr. Harry Tauber, V. P. E ,ineering &

Construction, December 3, 1981 4b. Detroit Edison, same as 4a updated to June 3, 1982.

4c. Detroit Edison, same as 4a and 4b updated to October 15, 1982.

5. ANSI B30.2-1976

" Overhead and Gantry Cranes"

6. ANSI N14.6-1978

" Standard for Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or more for Nuclear Materials."

7. ANSI B30.9-1971 -

" Slings"

8. CMAA-70

" Specifications for Electric Overhead Traveling Cranes."

25

1. 0""

• U.S. NUCLEA A REGULATORY COMMISSION BIBLIOGRAPHIC DATA SHEET EGG-HS-6191 4 TITLE AND SUBTITLE 2. (Leave bim*/

Control of Heavy Loads at Nuclear Power Plants, Enrico Fermi Atomic Power Plant, Unit 2 (Phase I) 3. RECIPIENT'S ACCESSION NO.

t AursORisi 5- ^ ' ' " ' ' RT C MPLETEo C. R. Shaber " "

T. H. Stickley arch 1983

9. PERFORMING ORGANIZATION NAME AND MAILING ADORESS //actuar lea Codel OATE REPORT ISSUED MONTH '

lvEAR Mav 1983 cG&G Idaho, Inc. , 7t ,,,, ,,, ,

Idaho Falls, ID 83415 8.ILeave N m ki

'2. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS ItacIvor I<a Coort ,

Division of Systems Integration Office of Nuclear Reactor Regulation si. riN No.

U.S. Nuclear Regulatory Comonssion Washington, DC 20555 A6457 13 TYPE OF REPCRT PE RICO COVE RED //sclusive asa,sl 15 SUPPLEMENTARY NOTES 14. ILeave smal

16. ABSTRACT '200 =ordt or wul The Nuclear Regulatory Commission (NRC) has requested that all nuclear plants either operating or under construction submit a response of compliance' 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 Enrico Fermi Atomic Power Plant, Unit 2.

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s 17 < E Y WORDS AND DOCUMENT ANALYSIS 17a DESCRIPTORS 1:'s, ICENTIFIE RS'OPELENDE D TERMS ,

18. AV AILABILITY ST ATEVENT 19. SE CURITY CLASS /Ta<s reporrt 21 NO OF PAGES Make available only as specifically approved Unclassified by program office. 20 W Q'ssiYfe [ '#'#' 'S l N asc E Oa %t 335 .n su

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ENCLOSURE 3 :

4 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 overall compliance 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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GUIDELINE I SAFE LOAD PATHS Exception !

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 relatedequipment combined with the design of the floor over which heavy loads are carried indicates that for a number of lif ts there 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 lift 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 BWR'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 guideline only under circumstances where there is no safety related equipment located beneath the l

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.

Approaches 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 lifts detailed direct-lons are prepared and approved for developing safe load paths which include 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 c - .. _ _ _ _ _ . _ _ . _ _ . _ _ _ _ . . _ _ _ _ _ . _ _ _ _ . _ _ _ , _ _ _

.. Appro:ches Inconsist:nt 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 cese of the operator it has the additional function of avoiding undesirable distractions whin handling suspended loads (e.g., trying to read procedural steps or drawings while coateolling the crane). This feature should also be seen as a provision necessary to corrplete 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.

Approaches 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 lift to ensure that it is clear, refers to the safe load path guidance during the lift and provides direct-lon 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 lift the appropriate load path is tamporarily 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 lift.

In either case reasonable engineering judgement would indicate that in certain specific lifts marking of safe load paths is unnecessary due to physi:al constraints on the load handling operation (e.g., simple hoists, monorails, or very short lifts 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.

l Exception 3 Obtaining written alternative procedures approved 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.

3 P . - ... - - - - - -

' Discussion The purpose ci this portion cf thl guideline is to ensure that devintions from established safe load paths receive a level of review appropriate to their safety significance. In general 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 recogni::ed, however, that issues associated with plant safety are the responsibility of an individual licensee plant safety review committee (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.

Approach inconsistent With this Guldeline 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.

4

GUIDELINE 2 LOAD HANDLING PROCEDURES .

No significant exceptions to this guideline have been encountered.

Occasionally a question arises concerning the need for individual procedures for each lif t. In general, it was not the purpose of this guideline to require separate procedures for eachRVhead, lif t (e.g., lif t. A reasonable core internals, approach fuel cask and isuse to p)rovide separateforprocedures a general procedure handling for each majo other heavy loads as long as load specific details (e.g., load paths, eqiApment requirements) are provided in an attachments or enclosures.

A 5

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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 shift.

Discussion '

This requirement (ie. not a recommendatien) of ANSI B30.2 is imp :. ant 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 eequirement will force them to test all control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those features generally known as controls (ie. holst, bridge, and trolley motion controllers).

Approaches Consistent With this Guideline Exceptions that clearly indicate that all normal controls (holst, bridge, and trolley motion contro!Iers) will be tested at the start of each shift and that the purpose of not committing to "all" controls is to avoid a misunderstanding concerning other control devices.

Approaches 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 shift.

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.I , GUIDELINE 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 des!gned 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 special lif ting device carrying a load within the jurisdiction of NUREG 0612.

Consequently it seems appropriate that for special lifting devices subject to NUREG 0612 it should be able to be demonstrated that, from a design r,tandpoint, 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 lif ting 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 or, 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 lifting device and prepared a list of critical components whose repair or replacement should be performed under controlled conditions.

Approaches Inconsistent With This Guideline l 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 liklihood of workmanship shortcomings is remote.

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Approaches Consistent With This Guideline The licensee has evaluated the lifting 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 J load. l l

Although a 150% 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%).

Approaches 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 full 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-lally 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 operationallifts 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. -

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'; GUIDELINE 5 LIFTING DEVICES NOT SPECIALLY DESIGNED  ;

Exemption 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 book 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 all load 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.

Approach Consistent With This Guideline The licensee has evaluated the potential routine dynamic loading for lifting 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 cranes 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.

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).(1). 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.)) 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 remote from upper travel limits. Such criteria should recognize that the need for upper travel limit switch protection may be preceeded by a control system failure and consequently should conservatively allow for operater response time and potential 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 i the discretion of the operator or implies that such a test will be required only if operat-

lons are planned in close proximity to the hook upper travel limit.

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• . GUIDELINE 7 CRANE DESIGN

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Exception

• Occasionally a licensee has Indicated that the overhead electric travelling cranes employed at a site were purchased prior to the pub!Ication 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 desi ;n l

and, consequently, can be assumed to provide an acceptable standard of mechan cal, \

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 (EOCl 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 IIcensee then to make a systematic comparison of their crane design with the requirements of current standards and determine If additional design features are appropriate.

1 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 1nconsistent 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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