ML20086H665

Control of Heavy Loads at Nuclear Power Plants,Beaver Valley Nuclear Power Plant Unit 2 (Phase I), Draft Technical Evaluation Rept

ML20086H665
Person / Time
Site:	Beaver Valley
Issue date:	11/30/1983
From:	Friederichs S, Frierderichs S EG&G, INC.
To:	NRC
Shared Package
ML20086H667	List: ML20086H665
References
CON-FIN-A-6457, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NUDOCS 8401190528
Download: ML20086H665 (45)

Text

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I ENCLOSURE 1 p.

e i C0r4 TROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS BEAVER VALLEY NUCLEAR POWER PLANT UNIT 2 (PHASE I)

Docket No. 50-412 Author S. L. Friederichs Principal Technical Investigator T. H. Stickley Pub'lished November 1983 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 >

Prepared for the ll.S. Nuclear Regulatory Commission Under DOE Contract No. DE-AC07-76IDO 1570 FIN No. A6457 ,

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' ' ABSTRACT The Nuclear Regulatory Commission (NRC) has requested.that all nuclear

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plants, either operating or under construction, submit a response of compliancy with NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants." EG&G Idaho, Inc., has contracted with the NRC to evaluate the responses of those plants presently under construction. This report contains EG&G's evaluation and recommendations for Beaver Valley Nuclear Power Plant, Unit 2.

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SUMMARY

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Beaver Valley Nuclear Power Plant Unit 2 does not totally comply with the guidelines of NUREG 0612. In general, compliance is insufficient in the following areas:

o Safe load paths o Special lifting devices o Lifting devices (Not Specially Designed)

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

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• CONTENTS i .

ABSTRACT ........................'..................................... 11 EXECUTIVE

SUMMARY

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

2. EVALUATION AND RECOMMENDATION'S .................................. 4

,2.1 Overview .................................................. 4 2.2 Heavy Load Overhead Handling Systems ......................

4 l 2.3 General Guidelines ........................................ 10 2.4 Interim Protection Measures ............................... 21 l

3. CONCLUDI.4G

SUMMARY

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3.1 Applicable Load-Handling Systems .... ..................... 24 L

3.2 Guideline Recommendations ................................. 24 3.3 Interim Protection ........................................ 28 3.4 Summary ................................................... 28

4. REFERENCES....................................................... 29 TABLES 2.1 Nonexe npt 'ieavy Load-Handl ing Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.2 Exempt Heavy Load-Handl i ng Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.1 NUREG-0612 Compliance Matrix .................................... 26 I

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CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS BEAVER VALLEY NUCLEAR POWER PLANT UNIT 2 (PHASE I)

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 Beaver Valley Nuclear Power Plant, Unit 2. This evaluation was performed with the objective of assessing conformance to the general load-handling guidelines of 'NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants" [1], Section 5.1.1.

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

Nuclear Regulatory Commission (NRC) staff.to systematically examine staff applicant 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 t'hese measures. This activity was initiated by a letter issued by the NRC staff on May 17, 1978 [2], to all power reactor applicants, requesting informatior. .

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.

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1' l ' In order to upgrade measures for the control of heavy leads, the staff I developed a series of guidelines designed to achieve -a two phase objective using an accepted approach or protection philosophy. The first portion of the objective, achieved through a set of general guidelines identified in NUREG-0612, Article 5.1.1, is to ensure that all load-handling systems at nuclear power plants are designed and operated such that their probability of failure is unifonaly small and appropriate for the critical tasks in which they are employed. The second portion of the staff's objective, achieved through guidelines identified in NUREG-0612, Articles 5.1.2 through 5.1.5, is to ensure that, for load-handling systems in areas where their failure might result in significant consequences, either (a) features are provided, in addition to those required for all load-handling systems, to ensure that the potential for a load drop is extremely small (e.g., a single-failure proof crane) or (b) 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 NUREG-0612 into four accident analysis evaluation criteria.

The approach used to develop the staff guidelines for minimizing the potential for a load drop was based on defense in depth and is summacized as follows:

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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 paths through procedures and operator training so that, to the extent practical, heavy loads are not carried over or near irradiated fuel or safe shutdown equipment o Provide mechanical stops or electrical interlocks to prevent movement of heavy loads over irradiated fuel or in proximity to equipment associated with redundant shutdown paths. _.- -

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

1.3 Plant-Specific Background On December 22, 1980, the NRC issued a letter [3] to Duquesne Light Company, the applicant for Beaver Valley Nuclear Power Plant, Unit 2 requesting that the applicant review provisions for handling and control of heavy loads at Beaver Valley Nuclear Power Plant, Unit 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 August 16, 1983, Duquesne Light Comp'any provided the initial response [4] to this request.

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2. EVALUATION AND RECOMMENDATIONS 2.1 ,0verview ,

The.following sections summarize Duquesne Light Company's review of heavy load handling at Beaver Valley Nuclear Power Plant, Unit 2 accompanied by EG&G's evaluation, conclusions, and recommendations to the applicant for bringing the facilities more completely into compliance with the intent of NUREG-0612. Duquesne Light Company's review of the facilities does not differentiate between the two units so it is assumed that both units are of identical design. The applicant has indicated the weight of a heavy load for this facility (as defined in NUREG-0612, Article 1.2) as 2000 pounds.

2.2 Heavy Load Overhead Handling Systems This section reviews the applicant's list of overhead handling systems which are subject 'o c 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 dFop 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 handling: system from your list by verifying that there is' sufficient physical separation from any load-impact point and any safety-related component to permit a determination by inspection that no heavy load drop can result in damage to any system or component required for plant shutdown or decay heat removal."

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'A . Summary of Applicant's Statements The applicant's review of overhead handling. systems .

identified the cranes and hoists shown in Table 2.1 as those ,

which handle heavy loads in the vicinity of irradiated fuel or safe shutdown equipment.

The applicant has also identified numerous other cranes that have been excluded from satisfying the criteria of the general guidelines of NUREG-0612. These are indicated in Table 2.2.

The applicant indicates in the Beaver Valley Pow'er Station-2 Final Safety Analysis Report that the following design bases apply'to the overhead Heavy Handling System.

1. Heavy load lifting devices are designed to avoid the dropping of their loads during the lifting operation.

2. Handling equipment is designed to avoid the dropping of fuel handling devices and lifting rigs during the lifting operations.

B. EG&G Evaluation BVPS-2 has reviewed their overhead Heavy Load Handling Systems and appears to have indicated all cranes. The reviews of the safe load paths were quite comprehensive.

The statements of intent to comply with the guidelines were in most cases very brief, but positive with no or little discussion.

BVPS-2 has not made a direct definition of a heavy . 4d.

However from the FSAR it is deduced that a heavy load is one in excess of 2000 lbs. (Fuel element--1600 lbs, handling . . _____

tool--400 lbs.)

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I NON EXEMPT HEAVY LOAD llANDLING SYSTEM BEAVER VALLEY NUCLEAR

, TABLE 2.1 I POWER PLANT UNIT 2 .

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- Load Equipment Capacity Weight i j ltem '

i (No.) (No.1 (Tons) Identification Heavy Load Handled [10011 I -

l 1 2CRN-201 Bridge No. 334 Po l a r Cra ne a. Reactor vessel head and attachment 130.0 f Trolley 1 167/15 k

Trolley 2 167

b. Reactor vessel internals (upper) 40.0

c. Reactor Vessel inte rna l s ( l owe r) 130.0

, d. Reactor cavity water seal 8.0

e. Reactor coolant pump-motor - 40.0

• f. Reactor coolant system loop isolation 15.0 valva 1 9 Reactor head lif ting rig spreader 3.5 assembly

h. Reactor containment operating floor 7.5 plugs

4. CRDM missile shield 34.0 J. CRDM support structure 8.0  :

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k. Ventilation fans 1.0 i Il j

l. Ventilation supply ducting (to CRDM) 0.9 [I 3.6

m. Skid carriors (full) f,i .

n. Removable rail and beam 1.15 )

o. Removable platform north and south 3.0 I

p. Internals lifting rig assembly 10.5

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r. Residual heat removal heat exchangor 9.4 i.

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s. Residual heat removal pump 3.9

t. Polar cranes bottom block and hook 5.4

u. Regenerative heat exchangor 3.5 d 9 6

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6-TABLE 2.2. EXEMPT HEAVY LOAD-HANDLING SYS{ EMS BEAVER VALLEY NUCLEAR POWER PLANT UNIT 2 Item Equipment '

r (No.1 (No.1 identification Location

! I 1 2FNR-CRN-244 CRDH drive assembly monorail Reactor Containment Building 2 2MHK-CRN-240 Radwaste bridge crane Condensate Polishing Building 3 2MHK-CRN-241 Demineralizer ri t ter monorail Condensate Polishing Building -

4 2CRN-35 Stop log monorail system Alternate intake Structure S 2CRN-232 Cooling tower pump house crane cooling Tower Pump House 6 2CHN-208 Solid wasto handling crano Waste Handling Building i

7 2CRN-202 Turbine room crane Turbine Building 8 2MHT-CRN-239A,B Condenser water box cover removal hoist Turbine Building  :

9 2MHT-CRN-242 CCS heat exchanger removal hoist Turbine Building 4 h 10 2MHP-CRN-222 Weste gas charcoal Turbine Building i Bed tank monora il Auxilia ry Building 11 2MHP-CRN-237 Waste gas surge tank monorail Auxilia ry Building l

12 2MHP-CRN-225 Charcoa l delay bed Aux i l ia ry Bu l,ld ing Degassi fied monora il 13 2MHP-CRN-238A,B Access slab moncrall Auxiliary Building

14 2MHz-CRN-243 Electrical Equipment and Service Building .

installation monorail * '

15 2fMR-CRN-205 Refueling manipulator crano Reactor Containment Building 16 2FNR-CRN-212A,B,C Stud tensioner hoists Reactor Containment Building 17 2FNR-CRN-234A,8 Upender winches Fuel Transfer Canal Area 18 2FNR-CRN-236 Caseous vaste filter monorail Auxiliary Building o

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4. EG&G Conclusions and Recommendations Since there is no-information to the contrary, EG&G concludes that the applicant has included all applicable hoists and cranes in their list of handling systems which must comply with the requirements of the general guidelines of NUREG-0612.

2.3 General Guidelines

, This section addresses the extent to which the applicable handling systems comply with the general guidelines of NUREG-0612, Article 5.1.1. EG&G's conclusions and recommendations are provided in summaries for each guideline.

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:

e o Guideline 1--Safe Load Paths o Guideline 2--Load-Handling Procedures o Guideline 3--Crane Operator Training i

o Guideline 4--Special Lifting Devices o Guideline 5--Lifting Devices (not specially designed) o Guideline 6--Cranes (Inspection, Testing, and Maintenance) o Guideline 7--Crane Design.

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. These seven guidelines should be satisfied for all overhead handling

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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 tne 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 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 paths should be defined in procedures, shcwn 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 committee."

A. Summary of Applicant's Statements The applicant has provided Figures 1 through 5 comprising 16 sketches identifying the location of safe load paths, spent fuel, and safe shutdown equipment in the Containment Building, the Fuel and Decontamination Building, the Auxiliary Building, and the Cable Vault Area. Figures IA ,

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and 18 are plant views at two elevations of the Containment - - - - ~ ~ ~

Cuilding showing safe shutdown equipment and piping /ecg/c g/

at these elevations. These figures are used-in conjunction with written procedures to define safe load paths in these areas.

Figures 2A through 2H indicate the safe load paths for all heavy loads determined to be. handled inside the Containment Building.

Figures 3A, 38, 4A through 4C, and Figure 5 indicate the location of safety related equipment, piping, and the safe . . - . . . . -

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l and Decontamination Building, the Auxiliary Building, and the Cable Vault Area.

With regard to measures taken to ensure that load handling operations remain within safe load paths, including procedures, if any for deviation from these paths, the applicant states the following

" Administrative procedures will include the general guidelines and evaluation requirements of NUREG 0612. The safe load paths shown in this report will be used as the load handling paths. Any deviation from these operational procedures will require an approval procedural change." [10]

B. EG&G Evaluation The applicant has indicated that administrative procedures controlling the conduct of load handling operations will include the general guidelines and evaluation requirements of NUREG 0612.

There is no specific mention that load paths will be marked on the floors; However judging by the number of paths .

indicated for the Containment Building, it appears that overlapping of load paths may make floor marking of all load paths confusing and impractical. If this is the case, alternate ways of marking a load path should be developed.

C. EG&G Conclusions and Recommendations

1. The applicant has not fully satisfied the intent of this guideline in that no comment has been offered regarding floor markings of the load paths.

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2. If floor markings are not practical, alternative ways .

of path marking should be developed. An alternative means of mark.ing the load path during a load transfer might be the use af temporary ribbon barriers.

3. The applicant should indicate,his alternative to permanent floor marking of the load paths, if an alternative is necessary.

2.3.2 Load-Handling Procedures [ Guideline 2, NUREG-0612, ,

Article 5.1.1(2)]

" Procedures should be developed to cover load-handling operations for heavy loads that are or could be handled over or in proximity to irradiated fuel or safe shutdown equipment. At a minimum, procedures should cover handling of those loads listed in Table 3-1 of NUREG-0612. These procedures should include:

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

A. Summary of Applicant's Statements The applicant has prepared a table of heavy loads that will be carried by each crane using Table 3.1-1 of NUREG 0612 as a guideline. TheseareindicatedinaTable1[10].- - ----- -

The applicant states " Load Handling procedures will be written as necessary to ensure compliance with NUREG 0612.

Any deviation from these operational procedures will require an approved procedural change. Procedures for the lifting of heavy loads will incorporate the guidelines of NUREG 0612. [10].

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The applicant has indicated that load handli.ng procedures will be developed that will ensure compliance with NUREG 0612. EG&G considers the applicant to have met the intent of this guideline.

C. EG&G Conclusions and Recommendations Based on brief statements by the. applicant, EG&G considers the applicant to have met the intent of this guideline.

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

" Crane operators should be trained, qualified, and conduct themselves in accordance with Chapter 2-3 of ANSI B30.2-1976,

' Overhead and Gantry Cranes' [6]."

A. Summary of Applicant's Statements The applicant states that " operator training, qualification, and conduct will be in compliance with the requirements of

' ANSI B30.2-1976." [10].

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B. EG&G Evaluation The applicant provides no additional information to that stated above and no exceptions to ANSI B30.2-1976 are indicated.

C. EG&G Conclusions and Recommendations Based on the information provided, EG&G Idaho concludes that Beaver Valley Power Station Unit.2 has satisfied the intent of this guideline.

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. 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 Shipping Containers Weighing 10,000 Pounds (4500 kg) or More for Nuclear Materials' [7]. This standard should apply to all special lifting devices which carry heavy loads in areas as 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's Statements i

The applicant states that the two lifting devices indicated in, Table 1 [10], the reactor Head Lifting Device and the Internals Lifting Rig Assembly were both designed prior to the publishing of the ANSI N14.6-1978 or ANSI B30.9-1971 standards. They were designed to the American Institute of Steel Construction AISC specifications. These specifications require that the devices be capable of lifting two times the designated loads. In addi ti'on ,- the - ---~_ .

devices were preoperationally tested to 125% of the maximum load which they will be required to withstand during normal use.

B. EG&G Evaluation The applicant has listed in Table I [10] two lifting devices. No distinction was made between Special Lifting Devices and Lifting Devices (Not Specially Designed). It is y e e *me e -m+

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. . assumed that both lifting devices listed, the Vessel Head l Lifting Devices and the Internals Lifting Rig Assembly are Special Lifting Devices. The devices are not designed to l ANSI N14.6-1978. It is not known whether the loads used in l

the design were based on the combined static and dynamic loads.

The applicant has not adequately reviewed their special lifting devices.

EG&G reco.nmends that the applicant perform a point by point review to ANSI N14.6-1978 with special attention to the following sections 3.1.1 through 3.1.4 3.2.1, 3.2.4 through 3.2.6 3.3.1, 3.3.4 through 3.3.6 4.1.3, 4.1.4 through 4.1.7, 4.1.9 5.1.3 through 5.1.8, 5.2.1, 5.2.2 5.3.1, 5.3.2, 5.3.4, 5.3.6, 5.3.7 EG&G feels that the intent of this guideline has not been fully satisfied.

EG&G feels that the special lifting devices and their associated problems are of such importance that the applicant should address this as a special section to their compliance with the guidelines concerning the device.

C. EG&G Conclusions and Recommendations

- EG&G concludes that the applicant has not adequately addressed this section. The devices have not been designed in accordance to the requirement of ANSI N14.6-1978 and there is not enough information to make a comparison of the AISC design specification to that of ANSI-N14.6-1978. The .. - ---

16

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. . safety factors indicated will not meet those specified by

~

N14.6-1978. -

The applicant should review the design of the lifting devices to N14.6-1978 as indicated in Section 2.3.48.

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

" Lifting devices that are not specially designed sh'ould be installed and usi.d in accordance with the guidelines of ANSI B30.9-1971, ' Slings' [8]. 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 oniy certain cranes, the slings should be clearly marked as to the cranes with which they may be used."

. A. Summary of Applicant's Statements The applicant has not provided any specific information regarding this guideline in any of the 3 documents supplied for review.

B. EG&G Evaluation The applicant has not addressed this guideline and therefore the intent of this guideline is not satisfied.

EG&G believes lifting devices and associated lifting problems are of such importance that they should be addressed in special sections regarding their compliance with guidelines concerning the devices. ,

EG&G wishes to point out that stress design factors are based on the combined maximum static and dynamic loads.

17 t -

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4 .

. . Each sling should also be properly identified as to lifting capacity, applicability to specific load handling operation, and any restrictions in its use.

C. EG&G Conclusions and Recommendations

- EG&G concludes that BVNPP-2 is not in compliance with the intent of NUREG 0612 Section 5.1.1(5). The applicant should I address this guideline in a separate section. The section should include both the maximum static and dynamic load stress of each loading device compared to calculated ard tested load strength. Also any load limitation, specific crane usage restrictions or any limiting factor should be properly assessed for each sling. Each sling should be properly identified.

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

( "The crane should be inspected, tested, and maintained in accordance 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 practical to meet the frequencies of ANSI B30.2 for periodic jnspection 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 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's Statements The applicant has made the following brief statement regarding this guideltne " Crane inspection testing, and maintenance procedures will comply with 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." [10].

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. . The applicant has indicated in general terms in the FSAR Section 9.1.5.6 tests and cranes, the shop testing, and the maintenance checking items to be performed on the Polar Crane, the Spent Fuel Cask Trolley, Mo' tor-Driven, Platform Crane, the Screenwell Crane, and the Monorail Systems.

. B. EG&G Evaluation i

The applicant has indicated that the crane inspection, testing and maintenance programs will be in accordance with ANSI B30.2-1976. No schedules of testing or inspection in maintenance have been projected at this time.

EG&G also wishes to call to the applicant's attention that specific plant operations may require alteration from Anti 830.2-1976; for example periodic inspections may noL

& .<ays be possible as scheduled. Therefore alternate proposals are necessary and they must be approved prior to being put into effect. EG&G concludes that the applicant has satisfied the intent of this guideline.

C. EG&G Conclusions and Recommendations Based on the information provided the applicant i,ntends to _ _ _ _

inspect, test, and maintain cranes in accordance with ANSI B30.2-1976. EG&G therefore concludes that the applicant has satisfied the intent of this guideline.

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

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

19

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.A . Summary of Aoplicant's Statenients The Spent Fuel Cask Trolley (crane 2MHF-CRN-215) and the

-MotorDrivenPlatformwithHoists'fNr Fuel Building (2MHF-CRN-227) have been designed to comp,1y with the guidelines of CMAA 70 and ANSI B30.2-_1976.

The Polar Crane (2CRN-201) war designed to comply with ANSI B30.2-1967 and CMAA 70< The 4pecification and design of the Polar Crane were reviewed for compliance with the

,,'1976 ANSI Standard. It was found that the 1967 standard

~

'l conformed to th,at o.f 1976 except for the energy absorbing capacity required to 'Stop th trolleys with power shut off.

3, ,

s The B30.2-1976 standard requires that trolley bumpers have

-r. energyabsorbingY2pacityadequatetostepthetrolleywith

_ , power shut off atia speed at least'50% of rated load speed n A' while the ANSI B30.2-1967 standard required a trolley speed s ' "of only'40% 'of, rated load s' peed. This design variation is

~

not considered to have a significant effect on the handling of heavy load,s by the Polar Crane. [10]

s

_ t% .!he Containme'nt Polar. Crane was purchased in 1973. The designratedlead'ofthebridgeexceedsthemaximumcritical_ _.__

. The Polar Crane Bridge

.]oad b{ a factor of over 2.5 to 1.

- 'C~T is ratet at 396 tasiand the main hoists at 198 tons for the

'l .construciion phriod7 [ The~ crane bridge is rerated to a 334 t\ncapacityandthemainhoiststoa167toncapac;.yafter

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the construction-lifts are completed.

1, Monorail' systems are designed to (MMA) No. 61.

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The Screenwell Cr ne is designed to E0CI specification no. 61 an'd ANSI B30.2-1967.

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. ,B. EG&G Evaluation .

The applicant has . indicated that the cranes.are designed to meet the applica,ble ciiteria and guidelines of Chapter 2-1 of ANSI B30.2-1976, and CMAA 70. The applicant also intends that in the event that compliance with the above cannot be

, , provided, a demonstration of actual design equivalency will be provided.

-C. EG&G Conclusions and Recommendations Based on the information provided EGaG Idaho concludes that BVNPS Unit 2 has satisfied the intent of Guideline 7

!. NUREG 0612, Article 5.1.1 (7).

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-2,4 " Interim-Protection Measures -=

The NRC staff has established (NUREd-0612, Article 5.3) that six measures should be initiated to provide reasonabl'e assurance that j 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.

j Applicant implementation and evaluation of these interim protection s

measures is contained.in the succeeding paragraphs of this section.

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,2.4.1, gerini Protection Measure 1--Technical Specifications

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"Licen'ses for all' cperating reactors not having a single-failure proof over'nead crane in the fuel storage pool area should be revised to include-a specification comparable to Standard Technical 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 fuel in the storage pool until

.' implementation of; measures which satisfy the guidelines of

. Section 5.1." - e A. Summary of A,pplicant's Statements

_.ts a

Not l6c/</ esse l B. M S Evaluation i

~ tune C. EG&G Conclusions and Recommendations Ofobeanf mud be m cashfance wN A$c y ypun=hkas of Abar4 CC/2 bev4,r e Hje. epopeen/ u

- u.sof speeAme}

2.4.2 Int'erim Protection Measures 2, 3, 4, and 5 - Administrative Controls' -

~

"Prceadural or administrative measures [ including safe ~ load paths, 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]." .

A. Summary of Aaplicant's Statements <

Summaries'of applicant's stat'ements are contained in .

discussions of the respective general guidelines in j Sections 2.3 1, 2.3.2, 2.3.3,- and - 2.3.G', respectively.

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, .B. EG&G Evaluations, Conclusions, and Recommendations EG1G evaluations, conclusions, and recommendations are contained in discussions of the respective general guidelines in Sections 2.3.1, 2.3.2, 2.3.3, and 2.3.6.

7 2.4.3 Interim Protection Measure 6--Special Review for Heavy Loads

! Over the Core i "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: (a) review of procedures for installation of rigging or lifting devices and movement of the load to assure that sufficient detail is provided and that instructions are clear and concise; (b) 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; (c) appropriate repair and replacement of defective components; and (d) verify that the crane operators have been properly trained and are familiar with specific procedures used in handling these loads, e.g., hand signals, conduct of operations, and content of procedures."

A. Summary of Applicant's Statements Not cy&ms sed

~ ~ ~ '

B. EG&G Evaluation none C. EG&G Conclusion Opp /scanf Mu.sh be m de*I)pbance w'b jwdeleer of ACscq o&i2 heAm )fa esey,md a s-< opw-Aen t

23

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3. CONCLUDING SUkMARY 3.1 Applicable load-Handling Systeag t

The list of cranes and hoists supplied by the applicant as being subject to the provisions of NUREG-0612 is apparently complete (see Section 2.2.1).

3.2 Guideline Recommendations Compliance with the seven NRC guidelines for heavy load handling (Section 2.3) are not satisfied at Beaver Valley Power Station-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 a. Not consistent with intent of Guideline 1.

2. Section 2.3.2 a. Consistent with intent of Guideline 2.

3. Section 2.3.3 a. Consistent with intent of Guideline 3.

4. Section 2.3.4 a. Not consistent with intent of Guideline 4.

5. Section 2.3.5 a. Not consistent with intent of Guideline ,5.

6. Section 2.3.6 a. Consistent w'.th intent of Guideline 6.

24

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. Guideline Recommendation

7. Section 2.3.7 a. Consistent with intent of Guideline 7. .

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/ s e TABLE 3.1. BEAVER VALiRY POWER STATION UNIT 1 AND 2 NUREG-0612 COMPLI ANCE MATRIX Cuidelinos Capacity dating Load Weight .

Eauipment Designated (tons) Heavy Load Handled (Tons) 1_. g_ } h_ 2_ 6_ 1 Po la r c ra ne Bridge 334 (See Table 2.1) (See Table 2.1) NC C C NC NC C C i (2CRN-2011 Trolley 1 167/15 Trolley 2 167 Residual heat removal 5 Residual heat removal 3.9 NC C C NC NC C C pump (2MilR-CRN-207) pump Spent fuel cash trolle/ 125/30 Spent' fuel cask trolley 100.0 NC C C NC NC C C

( 2Milf-CRN-215 ) .

Movable platform with 10/10 New fuel shipping 3.0 NC 'C, C NC NC C C hoist (2MHF-CRN-227) container (upended f only)

Fuel pool heat 16.5 exchanger failed fuel storage can 1.5 f NC C C NC NC C C l Cable vaul t 'a rea $ Removable slabs 2.3 '

l monora i l ( 2MilB-CRN-250 ) Rod drive motor 3.8 -

l gene ra to rs 1

Primary Component 10/10 Frima ry component 17.5 NC C C NC NC C C f Cooling water 1 Cooling heat exchangers Mano ra i l s lleat exchangers ,

(2MHP-CRN-209A,8 Pipe chase 5 Removable slabs 4.5 NC C C NC NC C C Slab remova l monorail

( 2Mit P-CRN-210 )

Chemical and volume 5/5/5 Changing pumps 3.75 NC C C NC NC C C d

/ control pump removal monora i l s 2MHP-CRN (220 A,B,C)

Prima ry co,nponent 10/10 Primary component 17.5 NC C C NC NC C C Cooling heat exchange Cooling water mono ra i l (221A,B) Heat exchanger Auxilia ry Building 10 Removable slabs 9.75 NC C C NO NC C C Miscollaneous filter  ?. Cesium removal 0.95 decontamination Mono ra i l IX's (2MHP-CRN-223) . Mixed bed demineralizer 0.95 l 1.4 Debo ra t i ng Dem i ne ra l i ze r a 4

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3.3 , Interim Protection 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 Beaver Valley Nuclear Power Plant, Unit 2 are met:

Interim Measure Recommendation Interim measures were Opp /scanh mes/ k m cen po omace.

l ru//> S not addressed

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Not applicable 28

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

2 V. Stello, Jr. (NRC), Letter to all applicants.

Subject:

Reauest for Additional Information on Control of Heavy Loads Near Spent Fual, NRC, 17 May 1978. p ,, f,j,f d9., g

3. USNRC, Letter to /

Subject:

NRC Request for Additional Information on Control of Heavy Loads Near Spent Fuel, NRC, 22 December 1980.

4. Amarjit Singh, Letter to T. Stickley " Control of Heavy Loads-Case Reviews" Beaver Valley Nuclear Power Plant Unit 2, August 16, 1983.

5. Terence L. Chan, Letter to T. Stickley " Control of Heavy Loads-Case Reviews" Beaver Valley Nuclear Power Plant Unit 2, April 2, 1982.

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

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

~

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

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

10. Terence L. Chan, Letter to T. Stickley " Control of Heavy Loads-Case Reviews" Beaver Valley Nuclear Power Plant Unit 2, September 21, 1981.

l 29

-=____=_.___ - - - - '-- ~~ ~

{.,- . .

!  !. . ENCLOSURE 2 i -5

.o SYNOPSIS OF ISSUES ASSOCIATED WITH NUREG 0612' The fo!!owing 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 1 SAFE LOAD PATHS o

' Exception I

, 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 outagi to outage. Further, in some cases the location of safety related' equipment combined with the design of the floor over which heavy loads are carried indicates that for a number of lif ts there is no preferred load path. '

Discussion Tre purpose of this portion of Guideline 1 is to ensure that the paths over which heavy loads are carried have been developed and approved in advance ~

of the lif t and are based on considerations of safety. In particular it is provided to avoid the ad hoc selection of load paths by maintenance personnel since such a situation

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

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

A fundamental princi;.ai of NUREG 0612 is protection through defense in cepth. 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 gUi'deline only under circumstances where there is no safety related equipment located beneath the area accessible to the crane book 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 lif ts detailed direct-ions 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. -

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, _Approtchts Inconsistsnt With this Guidaline.

Use of limited exclusion areas in containment which merely prohibited

. the carrying of heavy loads directly over the core or specific components and allow full load handling party discretion in other areas. -

Exception 2 ,

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

Discussion The purpose of this feature of Guideline 1 is to provide visual aids

,. ' to assist the operator and supervisor in ensuring that designated safe load paths are actually followed. In the case of the operator it has the additional function of avoiding undesirable distractions while handling suspended loads (e.g., trying to read procedural s eps or drawings while controlling the crane). Tnis feature should also be seen as a provision necessary to complete a plan for the implementation of safe load paths.

Specifically it provides some additional assurance that, having spent the time and .

effort to develop safe load paths, those paths will be followed.

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 ad on cab eperated cranes, checks out the safe load path prior to the lif t to ensure that it is clear, refers to the safe load path guidance during the lift and provides direct-ien to the operator and that the load path is followed. To support this approach the cuties and responsibilities of each member of the lead handling party should be clearly defined.

Prior to a lift the appropriate load path is temporarily marked (rope, py!ons, 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 physical 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.

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.

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l Discussirn The purposa cf this portion of this guideline is to ensura that davistions from established safe load paths receive a level of review appropriate to their safety i

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significance. In general it is highly desirable that once safe load paths are established they are retajned and kept clear of interference rather than routinely. deviated from.

It.is recognized, however, that issues associated with plant safety are the responsibility -

of an individual licensee plant safety review committeeior equivalent) and the detalis i of their excercizing this responsibility should be witten their jurisdiction, j Aeproach 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 l in the normal course of events. Any permanent alteration to a safe load path is approved by the plant safety review committee.

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

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j 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 each liff. 'A reasonable approach is.to provide separate procedur_es for each major lif t (e.g., RV head, core internals, fuel cask) and use a general procedure for handling other heavy loads as long as load specific details (e.g., load paths, equipment requirements) are provided in an attachments or enclosures. ..

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GUIDELINE 3 CRANE OPERATOR TRAINING Exceotion * * '

The only exception occassionally encountered with respect to this .

Guideline other than fairly minor, site unique, exceptions has been a desire to deviate from the requirement of ANSI B30.2-3.1.7.o for testing of all controls before beginning a new shift. In some cases a licensee has qualified a commitment in this area by noting that only crane controls "necessary for crane operation" will be tested at the start of a shif t.

Discussion This requirement (ie. not a recommendation) of ANSI B30.2 is important since crane control system failures are relatively significant contributors to load handling incidents. The only reason that can be seen for an exception in this area

. is a general aversion to the word "all". Specifically, it appears that some licensees fear that a commitment to this requirement will force them to test a!! control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those features generally known as controls (ie. hoist, bridge, and trolley motion controllers).

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

Acoroaches inconsistent With This Guideline A response that implies that a decision to test or not test a normal control wi!! 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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GUIDEI.INE 4 SPECIAL LIFTING DEVICES

. Exception 1

. , , Some licensees have indicated that their special lif ting devices ,

were designed and procured prior to the publication of ANSI N14.6 and therefore are -

not designed in accordance with that standard. This fact is sometimes combined with ~

a reference to the title of that standard to reach a conclusion that the standard is not applicable.

Discussion The purpose of this section is to ensure that special lifting 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 appliuations where the consequence of a failure could be similar to that which could be expected in the event of the failure of a special lifting device carrying a load within the jurisdiction of NUREG 0612.

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

Approaches Consistent With This Guideline Although not originally specified to be designed in accordance with ANSI N14.6 the special 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 de: ermined 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 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 ~

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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 130% overload test is somewhat arbitrary and that, in some cases, the nature of the device is such that the liklihood of workmanship s~hortcomings is remote.

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Approaches Consistent With This Guideline A The licensee has evaluated the lif ting device in question and has I determined that design stress margins are substantial. Further it has been established 1 that the defict 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 controis (eg AWS DI.1) including NDE. The device has been tested to 100% of rated load.

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.  :

i Exceotion 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 cemonst. ate the reliability of special lif ting devices. It is recognized, however, that some devices employed in a nuclear power plant, particularly those associated with refus!!rg, are used under condhions of control and at frequencies of use that are substant-Ia!!y Iess 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.

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

NDE of load bearing welds will be conducted at 5 year intervals y 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 l of the device.

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y n GUIDELINE 5 LIFTING ' DEVICES NOT SPECIALLY DESIGNED Exceotion Licensees have taken exception to the requirement to select slings in accor,dgnpe,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 Tne intent of this p~ortion of this Guideline, which also applies to special lif ting 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 nandling 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.

Accroach 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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i* GUIDELINE 6 CRANE INSPECTION TESTING AND MAINTENANCE.

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Exception The only exception occasionally encountered with respect to this Guidelind 5tHet 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 I 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 incorporead as a require-ment of OSHA in 29 CFR 1910.179.(n).(4).(i). It is recognized, however, that there may be circumstances where such a test is not prudent. First, such a test clearly should not be made with the hook under load. Consequently if a shif t change is made with the hook loaded (this, by the way, is net a desireable practice and could be preclud-ed through strict compliance with ANSI B30.2-3.2.3.j) a hoist limit switch test should not be performed. Second, there may be circumstances where the nature of forthcoming load handling operations indicates that the time (and minor risk) associated with this test is not justified. In particular if it is known that a hoist will not be used or used only in an area substantially removed from the upper travel limit, it would seem reason-able to defer the limit switch test until the start of the next shift. If such an approach is taken, however,it should be approached with care. Requirements for deferring an upper limit switch test should accomodate the uncertainty associated with maintenance plans and establish unambiguous criteria concerning what operations can be determined -

to be re:sote from upper travel limits. Such criteria should recognize that the need for upper travellimit switch protection may be preceedad by a control system failure and consequently should conservatively a!!c.v for o

- delays associated with emergency shutdown of the'perauer response time and potential crane. -

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

Approaches Inconsistent With This Guideline - -

An approach that implies that a decision to test or not is left to the discretion of the operator or implies that such a test will be required only if op, erat-ions are planned in close proximity to the hook upper travel limit.

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. GUIDELINE 7 CRANE DESIGN Exception Occasionally a licensee has indicated that the overhead electric -

travelling cranes employed at a site were purchased prior to the publication of CMAA-70 or ANSI B30.2-1976 and thus these standards should not be applied.

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

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

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

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

Acoroach Consisten 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 addit onal 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.

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

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ENCLOSURE 2 sw.,

Cooper North Anna 1 & 2 Crystal River 3 4 Rancho Seco D. C. Cook 1 & 2 s Surry 1 & 2

• Dresden 2 & 3 Trojan

• Ft. Calhoun Turkey Point 3 & 4 Haddam Neck Vermont Yankee Maine Yankee McGuire 1 & 2 '

• Monticello Zion 1 & 2 4 Palisades Duane Arnold c

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