ML20090K029

Control of Heavy Loads at Nuclear Power Plants,Comanche Peak Steam Electric Station,Unit 1 & 2 (Phase I - Draft)

ML20090K029
Person / Time
Site:	Comanche Peak
Issue date:	03/31/1984
From:	Yen T EG&G, INC.
To:	NRC
Shared Package
ML20090K032	List: ML20090K029
References
CON-FIN-A-6457, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NUDOCS 8405230577
Download: ML20090K029 (45)

Text

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o o ENCLOSURE 1 i

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CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS COMANCHE PEAK STEAM' ELECTRIC STATION, UNITS 1 AND 2 (PHASE I - ORAFi)

Oceket Nos. 50-445, 50-446 Author T. C. Yen Principal Technical Investigator T. H. Stickley Published March 1984 EG&G Idaho, Inc.

, Idaho Fall,, Idaho 83415 Prepared for the U.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 plants, either operating or under construction, submit a response of compliancy with NUR5G-06'2, " 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 Comanche Peak Steam Electric Station Units I and 2.

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SUMMARY

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Comanche Peak Units 1 and 2 do not totally comply with the guidelines of NUREG-0612. In general, compliance is insufficient in the following areas:

f o Development of load paths is not yet complete and there is no plan to mark the load paths on the floor, o The proposed method for estimating the dynamic load may be subject to misinterpretation. Two cranes are rated as havin; :ne capacities equal to the weights of loads to be carried, but it is not indicated if the dynamic effect has been taken into consiceration.

o Cranes are not indicated as designed per all of the incicatec regulatory requirements.

. Th.e main recort contains recommendations which will aid in bringing

, the above items into compliance with the appropriate guidelines.

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CONTENTS ABSTRACT .......................................................... .. 11 EXECUTIVE

SUMMARY

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

2. EVALUATICN AND RECOMMENDATIONS .................................. 4 2.1 Overview ................................. . . . . . . . . . . . . . 4 2.2 Heavy Load Overhead Handling Systems . . . . . . . . . . . . . . . . . . . . . 4 2.3 General Guidelines ............. .......................... 8 2.4 In'terim Protection Measures ...................... ........ 21

3. CCNCLUDING

SUMMARY

.............................................. 25 3.1 Applicable Load-Handling Systems ....... .................. 25 3.2 Guideline Recommendations ................................. 25 2.3 Interim Protection ....,.................................... 29 3.4 Summary ................................................... 29 .

4 REFERENCES ................................ ..................... 30 TABLES 2.1 Nonexempt Heavy Load-Handl ing Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

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3.1 NUREG-0612 Compliance Matrix .................................... 26 iv S

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CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS CCMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 (PHASE I - ORAFT)

1. INTRODUCTION 1.1 Purpose of Review This technict.1 evaluation report documents the EG&G Idaho, Inc.,

review of general lead-handling policy and procedures ac Comanche Peak Units 1 and 2. This evaluation was performed with the cojective of assessing conformance to the general load-har.dling guicelines of

.',UREG-C612 " Control of Heavy Loads at Nuclear Power Plants" [1],

Section E.1.1.

1.2 3eneric Backereund Generic Tecnnical Activity Task A-36 was estaolished 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 these measures. This activity was initiated by a letter issued by the NRC staff on May 17, 1978 [2], to all power reactor applicants, requesting information concerning the control of heavy loads near spent fuel.

The results of Task A-36 were reported in NURE3-0612, " Control o' Heavy Loads at Nuclear Power Plants." The staff's conclusion fecm tnis 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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In order to uograde measures for the control of heavy loads, the staff.

ceveloped a series of guidelines designed to ac.'teve 5 a two phase objective using an acceoted approach or protection chiloscohy. The first portion of the objective, achieved through a set of general guidelires 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 uniformly 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 proviced,

'n addition to those required for all loac-handling systems, to enst re tnat tne potential for a load drop is extremely small (e.g., a single-failure-: roof crane) or (b) conservative evaluations of loac-nandling accidents incicate that the potential consequences of any load drop are acceptably small. Accepta:iility of accicent c:nsequences is quantified in NUREG-0612 into four accicent analys's evaluation criteria.

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The approach used to develop the staff guidelines for minimicing the 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 l 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 t

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o Provide mechanical stops or elettrical interlocks :: prevent movement of heavy leads over . irradiated fuel or in proximity to equipment associated with redundant snutdown' paths.

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

1.3 Plant-Scecific Background On December 22, 1980, the NRC issued a letter [3] to Texas Utilities Ger.erating Company (TUGC), the acplicant for Comanche Peak reques, ting that the applicant review provisions for hancling and centrol of heavy leads at Cemanche Peak Units 1 and 2, evaluate these provisions witn respect to the guidelines of NUREG-0612, and provide certain acditional information to be used for an independent determination of conformance to these guidelines. On August 7, 1981, TUGC rovicec the initial response [4] to this request. Additional information was

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provided on October 8,1981[5]. After EG&G's preliminary evaluation [12), TUGC sub=itted two revisions of the initial response on March 1, 1982 and June 8, 1983 [10,11].

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2. EVALUATION AND RECOMMENDATIONS 2.1 Overview The following sections summari:e Texas Utilities Generating Comoany's (TUGC) review of heavy load handling at Comanche Creek Units 1 and 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. TUGC's review of the facilities dcas not differentiate between the two units so it is assumed that both units are of identical design. The applica bas indicatec the weight of a heavy load for this facility (as definac in NUREG-0512, Article 1.2) as 2150 lbs.

2.2 Heavy Load Overherc Handline Systems This section reviews the applicant's list of overneac handling systems wnich are subject to the criteria ef NUREG-0612 and a review of the

, justification for excluding overhead handling systems from the above mentioned list.

2.2.1 Scoce

" 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 racuired 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 evernead 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 require,d for plant shutdown or decay heat removal."

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A. Summary of Aco11 cant's Statements The applicant's review of everhead handli.1g. systems

. icentified the cranes and hoists shewn in Table 2.1 as these which handle heavy loads *in the vicinity of irradiated duel or safe shutdown equipment.

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t TABLE 2.1. II000 EXEMPT HEAVY LOAD llANDI ING SYSILMS--COMANClli. CHilk UNilS I AND 2 Ettes/Hg h ee Cra!Ie/Ho_tn U.L._Mi I tur;. <>Il I _ .19ca de L _u gyieuun__

i j ' 3. Fuel nullding overhead cearou CPX-MESCIC-01 130- I I *s s ein t slu t t eling Alsovo 860 et i 2. Contalsteent auxiliary upper CPI-Mi SCCA-O l 5 Cont.sisimont Building 90*> rt-6 in, c ranes CP2-MESCCA-01

3. Containme/t polar cranes CPI-Mf SCPP-01 l'15-20 Contalomont flui ld lag 950 f t ~l ist.

, CP2-ME SCP P-01

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II . Moderating MM and letdown CP I-M( MIICH- 16 2 chiller MM holst Sal'nguards Building 831 ft-6 in.

CP2-ME MIOCH-16

5. C . :n:xt cooling water pump CPX-M(MHCal-04 4 Auxl a lary nasildtsig 810 ft-6 les, helst

' 6. Safety related challer hoist CPI-MI MetCH-04 A 3 Aesw illary Heellding ~//n rt (Single-railuro-Prcor) CP2-MI MitCil-04 A

7. Centrirugal charging pumps CPI-MIMescil-01, 02 4 Auxiliary Basildleig 880 ft-6 in, hoist CP2-MlHitcal-Oi, 02

8. Containment fuel hansiling CPI-MLSCCT-01

, bridge crane CP2-MESCCr-01 1 Containesuit flullding Above 860 ft

, g. Aux i l la ry reedwe te r pump CPI-Ma setCH- 5 3, 14 4 Sareguards Desliding

'] hoist pump)

(electric motor driven CF2-Mt milch- 5 3, 14 790 ft-6 in.

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'4 10. Auxillary feedwater pump CPI-M( Metcal- 12 3 Saregesards nullding i; hoist (turbine driven pump) 790 rt-6 in, CP2-MtMelCH-12

11. Auxillery ri t ter helst CPX-M( MilWH-04 'a Auxiliary liasilding 8',2 rt-6 in.

12. Reactor coolant pumps helst CPI-M( MetCil-42 45 Containe(nit fluilding

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CP2-MtMilCll-42 905 ft-9 in.

13. Diesel generator (piston) CPI-Mt Mescal-3 7 38 i Saruguards nullding heist 810 TL-6 in, Cl 2-MI MilCll-3 F. 38

-: p 14. Spent reaal pool HX helst CPX-MIMilCal-43, 44 a l iso l lis i ld ing als (L-9 in.

15. Service water traveling CPX-MI MeeCil- 82 2:1 Distsido or survico screen hoist and jib crane CPX-SWi llSG-01 838 ft 3 watur intako streacture t

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TABLE 2.1. (continued)

• C.sge.sc e ty j Gratie/HELELMe** Cr an.n/ll*t tiL_Lih Pl!*8nt r. . f insibl . . . i nem t hat' . I t!!vit t heft it -

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-- ' 16. Isesidual heat reenval llX CPI-m MICll-4 7, 59 to Sailogenarils tinilding

' and Contalesment Spray a33 1t-6 dre.

System helst ,

1 j 17. Mair. steam safety valves CPI .lW MHCH-48, R9, $3, Si l Saraginards fluildirig 880 FL-6 in, q helst CF2-MtMICH-48, sg, e $o, Si l" '

38. Service water intake C PX-tK SCW-01 1 1/2 service water intake structure crane Above 196 ft si t uc tie re l 19. Centainment dome access CPI-M SCMP-01 1 Canitainenset pullding i

rotating platrere helst 1000 ft

C P2-Mt

SCH P-G l 1 20. reae

Inandling Isridge crane 1BM-IHSCfD-01 2

{ (f asel Desilding) fisol fluilsfing Alsovo 860 l' t i ~ 21 Aeraseling eachine IllX-I NSCMC-01 2 Canitairement aluilding Abovo 860 ft

{ (Contalsement test iding) ICX-lHSCMC-Ol l

22. Service water Intelse stop CPX-MI MetCH-61 8 Sorvico water intake 789 FL-9 in, gate helst s t rasc Luro

23. Anexiilary riIter heist CPX-MLMHWh-04A 9 Anexiiiary puiiding

( Single-r a i lure-Preer) 852 rL-6 in.

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24. Miscellenseess feelst CPM-MimlCll-72 2 fuel llesi ld ing 838 ft-9 in.

25. assidesel healI removal pseep CP I-M H18C01-08 3 Sa fegina rd s Bui ld ing 773 ft peoist CP2-MtMetCH-09

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The applicant'has also. identified numerous other cranes that have been excluded from satisfying the criteria of the ,

1 general guidelines of NUREG-0612.

S. EG&G Evaluation The safety injection pump hoist is omitted while the auxiliary building filter hoist is restored in the revised list of nonexempt cranes [11] wi,thout explanation.

4 C. EG&G Conclusions and Recommendations j The applicant should indicate if the safety injection pump

hoist handles heavy loads in the vicinity of the irradiated fuel or safety shutdown equipment. If it does, it should be listed in Table 2.1 and the hazard of a loac drop from this i' hoist should be evaluated.

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-. 2.3 General Guidelines t

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 j summaries for each guideline. ,

j l l The NRC has' established seven general guidelines which must be met in l order to provide the defense-in-depth _ approach for the hancling of '

heavy loads. These guidelines consist of the following' criteria from I i

Section 5.1.1 of NUREG-0612:-

i- o Guideline 1--Safe Load Paths o Guideline 2--Load-Handling Procedures t

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! o Guideline 3--Crane Operator Training o Guideline 4--Special Lifting Devices I

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

l l 7hase seven guicelines snould be satisfiec 'or all overreac Parc!*ng systems and programs in orcer to handle heavy loads in the v'tinit y :!

ne reactor vessel, near spent fuel in the spent-fuel pool, o* in other areas 'where a load drop may damage safe shutdown systems. *he succeeding caragraons accress the guidelines individually.

2.3.1 Safe '.nc paths iGuideline 1, NUREG-0612, Article 5.1.1(1)1

" Safe lead paths should be defined for the movement of heavy Icads to minimi:e the potential for heavy loads, if dropped, to 1mpact irradiated fuel in the reactor vessel and in the I spent-fuel pool, or to impact safe shutdown equipment. The patn '

'should follow, to the extent practical, structural floor members, beams, et::,, such that if the load is dropped, the structure is i

more likely to withstand the impact. These load paths should be

- defined in procedures, shown on ecuipment layout drawi'ngs, and  !

clearly marked on the floor in the area where the lead is to be handled. Deviaticns from defined load paths should require written alternative procedures aporoved by the plant safety review cor.mittee."

l l A. Summary of Aeolicant's Statements

" ' Safe load areas' (areas serviced by a particular crane in which a-load drop will not result in damage to shutdown or decay heat removal equipment or spent fuel) have been ".

identified where applicable for the cranes listed in (Table 2.1). Equipment handled by these cranes will be 0 .

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transported whenever possible within the identi'iec safe load areas." ' '

" Safe Icad areas" for 9 of the 25 listed in Table 2.1 are  ;

marked on s.b91tted drawings. For the remaining hetsts, t e

• establishment of safe load areas is not appitcable, since the hoists generally travel along a single moncrail which  !

allows the hoist to follow only one possible path. ,

"All ' safe load areas' and ' safe load paths' wi'l te identified by drawing."

" ' Safe lead paths' will also be identified and esta:11shes t

, for 1 cads 94ndled outside safe Icad areas prior te initial  !

fuel load to ensure the safe coeration of the crane curing maintenance and normal operation of the plant."

" ' Safe Icac paths' will be defined in the CPSES maintenan:e procedure as attachments to load handling procecures.

Procedures will be approved and handled in accordance with CpSES station procedures, as directed by the Station Operation Review Committee. Deviation from this maintenance '

procedure or load path will be handled in accordance with procedures governing deviation or revisions of safety

,related procedures, as directed by the Station Operation Review Committee."

8. EG&G Evaluation As pointed out in (12), the idea of " safe load areas" is not

• completely sound. A safe lead path should be established for each heavy load to be moved. If several loads are moved .

'through the same area, this area constitutes a composite ,

load path which :ould be defined as a " safe load area."

Otherwise, this guideline does not call for identifying the 4

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" safe lead areas." There is no need for the a:cifcant :

establish the safe lead path and the safe lead area separately.

For defining the safe lead path, the applicant has reg't: tad .

to indicate if the path will be painted on the ficer in the l area of load movement.

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C. EG&G Conclusions and Rec

mmendations t

The acolicant's acti:n is rot fully consistent its tna intent of NUREG-0612, Article 5.1.1(1). For establisedng l tne' safe load paths, the a:citcant should censicer:

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(1) Oefining 4, definite ca:M, not a general area, #: P  ;

transcorting eatn heavy toad.

i (2) Marking the load pa:n on the floor for easy identification by the crane operator.

I' 2.3.2 Load-Handline Procedures fGuideline 2. NVREG-0612.

Article 5.1.l(2)1

" Procedures should be developed to cover load-handling operations for to i, rradiated heavy loadsfuel that areshutdown or could be handled over or in =reximity or safe equip:aent. At a mintmwn, procedures should cover handling of those loads listed in Tacle 3.1 of NUREG-0612. These procedures shculd incluce:

r identification of required equipment; inspections and accostance l

L criteria required before movement of load; the ' steps and p*:cer sequence to be followed in handling the load; defining the safe l

t path; ard other special precautions."

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A. Summary of Acolicant's Statements ,

"For some heavy loads, it mcy be necessary to operate outside the safe load aren and transport the load over or near plant shutdown or decay heat removal equipment or spent fuel. For these loads and all oversize loads, special precautions or procedures will be utilized with the purpose of minimizing the risk of a heavy load, drop in these areas.

o The procedure will consist of load drop prevention measures, -

such as a list of required equipment, inspection, acceptance  ;

criteria for the movement of the load, sequence of steps, etc. These procedures will be available for NRC review."

8. EG&G Evaluation  ;

The applicant's statements imply that the development of tse load hancling procedures is covered by the designation of the " safe load areas."

1 TUGC has committed to providing procedures in accordance with Guideline 2. .

C. EG&G Conclusions and Recommendations

, e Based upon the information supplied EG&G considers that Comanche Peak units 1 and 2 are consistent with the intent of Guideline 2.

2.3.3 Crane Oserator Trainine fGuideline 3. NUREG-0612.

Article 5.1.1(311

" Crane operaters should be trained,' qualified, and conduct themselves in accordance with Chapter'2-3 of AN51830.2-1976, '

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'OverheadandGantryCranes'(6)" .

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A. Summary of Appiteant's Statements

" Crane operators will.be trained, qualified, and will conduct themselves in accordance with Chapter 2-3 of ANSI B30.2-1976 " Overhead and Gantry Cranes.'"

Procedures governing crane operator training qualifications i

and conduct will be available for NRC review prior to fuel Ioad."

l 8. EG&G Evaluation The applicant has commi,tted to compliance with guideline 3.

l l C. EG&G Conclusions and Recommencations Based upon the information provided, EG&G considers Cemanche Peak units 1 and 2 to be consistent with guideline 3. "

2.3.4 Special Liftina Devices (Guideline 4. NUREG-0612.

Article 5.1.1(411 ,

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' "$pecial If fting devices should satisfy the gi.idelines of ANS!

N14.6-1978, ' Standard for Special Lifting Devices for Shipping Cortainers Wei j Materials' (7)ghing . This 10,000 Pounds standard (4500 should app'y kg)toorallMore specialfor Nuclear lifting devices which carry heavy loads in areas as defined above. For operating plants, certain inspections and loac tests may be acceptec in lieu of certain material requirements in the i . standard. In addition, the stress design factor stated in

$ection 3.2.1.1 of AN51 N14.6 should be based on *.he combined maximum static and dynamic loads that could be imparted on the handling device based on characteristics of the crane which will be used. This is in lieu of the guideline in Section 3.2.1.1 of AN$! N14.6 which bases the stress design factor on only the weight (static load) or the load and of the intervening l

components of the special handling device."

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- i A. Summary of Applicant's Statements "Although a special lifting device for a spent fuel shipping container weighing 10,000 lbs or more has not yet been procured, ANSI N14.6-1978 and NUREG-0612 Guidelines for l special Itfting devices will be invoked when this device is i

obtained. Although it is anticipated at this time that the standards for the lifting devices will be met, it may later be determined that alternatives to the standard are l required. In that event, written notification will be made to the Nuclear Regulatory Commission describing the alternatives and their equivalency in terms of load handling l reliability."

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" Reactor vessel head and reactor internals lifting rigs meet ,

the intent of ANSI N14.6-1978 and NUREG-0612 for design,

! fabrication, assembly and operation. The analysis for these devicesisprovidedin[theWestinghousereportWCAP-10156]"

l-1 "These rigs meet the intent of mentioned NUREG and AN$1 standard for design, faerication, assembly and operation,

! but do not meet all the specific load verification testing.

l The proposed alternate testing was included in Section 6 of '

WCAP-10156."

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."The failed fuel assembly lifting tool has been deleted from i Table 4of(ReportWCAP.9198]becauseourreviewindicated that this tool is not required."

InTableA-4(11),theapplicantindicatesthatspecial lifting devices will be used only on: '

(1) Spent fuel cask (2) Reactor vessel head e

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' (3) Reactor internals .

B. 'EG&G Evaluation j

l The information related to the proposed alternate 1 sad i verification testing of the rea'ctor vessel head and reactor internals lifting rigs has not been provided for review.  !

The applicant was reminded that dynamic loads must be

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considered for calculating the stress design factors (12),

but this requirement is left unaddressed in the applicant's latestsubmittal(11).

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EG&G Conclusions and Recomendations The applicant's information indicates a partial consistency -

with the intent of this guideline. Additional actions are recommended: i

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(1) Provide information on the proposed load verification testing for reactor vessel head and reactor internals lifting devices, and demonstrate that the alternate I testing methods are. consistent with the intent of the R

ANSI N14.6 testing procedures.

(2) For the design of the special lifting devices.

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calculate the ANSI N14.6 specified design safety factors with the combined maximum static and dynamic

• loads.

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l 2.3.5 Liftine Devices (Net ! m ially Destaned) fGuideline 5.

• L NURES-0612. Article 5.1.1ti)1 , . r "1.ifting devices that are not specially designed should be installed and used in accordance with the guidelines of i

ANSI 830.9-1971,'llings'(4). However in selecting the proper sling, the lead used should be the sum o,f the static and manimum .

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dynamic load. The rating identified on the sling should be in i terms of the ' static load' which produces the maximum static and r dynamic load. Where this restricts slings to use on enly certain  ;

c rar-e f,, the slings should be clearly marked as to the cranes with I which they may be used." .

t A. Summary of Applicant's Statements '

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" Lifting devices that are not specially desigred for use with heavy loads, as defined by NUREG-0612, will comply with the guidelines of ANSI 930.9-1971." -

" Sling ratings will be identified en the sling in terms of the static Icad, *nich produces the maximum static and dynamic lead; (i.e., Icad x 0.005 x hoist soeed

• maximum I static Icac). Where this restricts slings to use on only 1 certain cranes, tr.e slings will be clearly marked as to the cranes with whics they may be used."

b S. EG&G Evaluation.

r For calculating the dynamic load, the applicant has failed

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• to specify the unit for hoist speed.

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I C. EG&G Conclusions and Recommendations

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'The applicant's pecposed action is not completely consistent with the intent of this guideline. The unit of the hoist speed used for calculating the dynamic load should be '

clearly stated, e.g.' feet / minute, s

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l 2.3.6 Cranes (Inseectton. Testino, and Maintenance) TGuideline 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 inspection and test, or where frequency of crane use is less than the specified inspection and test frequency (e.g., the polar crane inside a RWR 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 ins;ections, test, and maintenance should be performed prior to their use)."

A. Summary of Acelicant'r Statements l " ANSI B30.2-1976, Chapte* 2-2, will be invoked with rescoct to crane inspections, test and maintenance.

With respect to Section 2-2.1.1.1 cf ANSI B30.2, cranes located within containment will be inspected every scheduled refueling outage in accordance with the requirements of ANSI B30.2. This is necessary because periodic inspections during power operations are impractical due to high radiation levels in containment.

These measures will be implemented prior to fuel handling.

procedures and inspection records will be retained and available for NRC review "

8. EG&G E61uation As stated, the applicant has committed to implement the .

measures consistent with the intent of this guideline prior to fuel handling, and to retain the procedures and the inspection records for review.

17 -

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r C. EG&G Conclusions and Recemmendations Based on the information provided EG&G considers tnat Comanche Peak units 1 and 2 are consistent witn tne intent of guideline 6. '

2.3.7 Crane Desien (Guideline 7, NUREG-0612, Article 5.1.!(7)1 "The crane shoutc be designed to meet the applicable criteria and guidelines of Chapter 2-1 of ANSI B30.2-1976, ' Overhead anc Gantry Cranes,' and of CMAA-70, ' Specifications for Elect *1c OverheadTravelingCranes'(9]. An alternative to a s:ecification in ANSI B30.2 er CMAA-70 may e ac:s: tee in :teu of specific compliance if the in ent of the specificatien is satisfied."

A. Su- a y of a::14: ant's 5:ste eets "Ta:le A-3 lists tne load nandling systems tcentified in Ta:1e A-1 and tre applicaele coces and stancarcs as '

s:ecified in :ne C;$ES Ecuipment Purenase $cecificatio9s.

, In all cases, the crane cesign comoltes with tne guicolines of CMAA Specification 70 and Chapter 2-1 of AN$1 B30.2-1967 and all hoists are designed in accordance with sne requirements of ANSI B30.16-1973."

,TacleA-3(11)isarevisedversionofTable3inthe applicant'searlyresponse(10). In Table 3, the applicant indicated that all nonenempt cranes were designed ser AN3! B30.2-1976 Chapter 2-1 or to the criteria of both CMAA-70 and AN51 830.2, Chapter 2-1. In response to EG&G's comments (12)onthespecifiedweightofaheavyloadand .

rated capacities of sone cranes, the applicant statsst e

I s

14

• p . . . . . . . . . . . . . . .. . . _ _ . _ - . _ .-

"The term ' heavy load' is defined in NUREG-0612 as a lead whose weight is greater than the combined weight of a single spent fuel assembly and its handling tool. For Cp5ES, this 1 weight is approximately 2,150 lbs." .

i

" Table 4 of Reference (10] has been corrected to eliminate i

thediscrepanciesconcerningratedcapacityofcranes(in question]andtheirmaximumloads. (See Attachment A.

TableA-4(11])."

8. EC&G Evaluatten AsshowninTableA-3(11),theapplicanthasapparently

lassi'fe: the overhead load handling systems into two cate; cries: cranes and hoints. Even though a hoist may run on a meno* ail, it is not considered as a crane. All the

.e meac load handling systems designated as hoists are specifisc to meet the criterta of AN5! B30.16-1973:

"c.s .eac hoist (uncerhung)", not the criteria of C.vAA-70 and AN5! B30.2-1976 specified by this guideline. Cranes are

! cesigned according to the criteria of ANSI B30.2-1967 instead of AN51 B30.2-1976. In the opinion of EG4G, the use of AN5! B30.16-1973 in Iteu of CMAA-70 and Chapter 21 of l AN5! B30.2-1976 is not entirely appropriate. Some arest of crane design discussed in CMAA-70 and Chapter 2-1 ef ANSI B33.2-1976 are not Covered in AN5! B30.16-1973. For enamole, Chapter 2-1 of AN5! B30.2-1976 includes guicolines for construction of runways and supporting structure, whereas ANSI B30.16-1973 does not. Since the design of the runways and supporting structure usually is based on ,

time tested engineering practice,,the applicant only needs to state the codes and standards stipulated in the design specifications. As an alternative, the applicant may review AN5! B30.11-1980 for applicability to app 1tcant's crane design. Inasmuch as there exist only some minor differences f

19 '

. 4 n. .m - . . wn- nec=> w # rA n

. l l

• I l

between the 1947 edition and the 1974 edition of ANSI 830.2, j the use of the 1967 version in Iteu of the 1976' edition for  !

crane design is acceptable.  !

L As pointed out in EG4,G previous evaluation (12), some cranes j should betong to the enemot category.

Intheapplicant'slatestsubmittal(11),thefollowingsix  !

cranes are still itsted as noneuempt cranes, even though the  ;

manimum weights (Table A-4 (11]) carriec by these cranes are all less than 2150 lbs:

(1) Containment fuel handling tridge crane l (2) Main stou safety valve Mot st (3) Contains, ant dome access rotating platform moist l

(4) Safety related chiller notit i i

(5) Refuelingmachine(containmentbutIdtng)

(

(4) Olesel generator (piston) hoist.

Pending further review by the sositeant, these cranes a o included in Table 2.1.

Basedentheinformationprovidedin(11),theloadcarrying l capacities of *

(1) Residual heat removal pump heist (2) Olesel generater (pisten) heist '

I e

S e

20 .

, , , .. ,, e .. -me e*s * ;r s*** _M*-*'**** '

• """**** * * *^ * "# #'

l

[

are rated as equal to the loads to be handled. The applicant has not indicated if the specified loads are

! static loads or combined static and dynamic loads. If they <

are static loads, these two cranes are stt11 underrated.

1 C. EG&G Conc 1vstons and Recommendations I

At present, the crane design at Comanche Peak Steam Electric Station is not in complete conformance to the intent of  ;

NUREG 0612 Article 5.1.1(7). For the appitcant's further effort EG&G recommends the following:

(1) If the criteria other than those specified by this guideitne were used for crane design, provide information to o onstrate that the intent of this '

gutteline is satisfies in every respect.

I.

(2) Re enamins the esatmum loads and rated capacities to

• t l

cetermine if suf ficient safety margin for some cranes to carry the comeined static and dynamic loads has been provided and if some cranes should be categorized as exempt cranes.

B 2.4 Inteetm 8 otection Measures '

t

The NRC staff has estat1tshed (NUREG 0612, Article 5.3) that sta l measures should be initiated to provide reasonable assurance that l .

handling of heavy loads will be performed in a safe manner until final l tmplementation of the general guidelines of NUAEG 0412, Article 5.1, j .

is complete. Four of these sta interim measures consist of general L Guideline 1, Safe Lead paths: Guideline 2. Lead-Hand 1tng Precedurest

! Guideline 3. Crane Operater Training; and Guideline 4 Cranes .

l (Inspection. Testing,andMaintenance). The two remefning interim l

measures cover the following crt'teria o Heavy lead technical speelficattens g .

t 0 e t t 4 s. * ,4. Et c e e as . - w- x49 e 4 ,i pig - @ @ w- ,,;.,, ;, Q + g - @ @ 5 a f (.

i*

. j l

o Special review for heavy loads handled over the core.

l Applicant impleu ntation and evaluation of these interin p*::ection ressures is contained in the succeeding paragraphs of this section.

l 2.4.1 Interim protection Measure 1--Technical Specifications

" 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 comparab'e to Stancard Technical Specification 3.9.7, ' Crane Travel - Spent Fuel Storage Pool Building,' for PWRs and Standard Technical

, Specification 3.7.6.2. ' Crane Travel ' for Ms, to or:Stoit l

1 nandling of heavy loacs over fuel in the storage pcol .ntti implementation of measures which satisfy the guideltres of Section 5.1."

A. 35--ary of Aooticant's Statements The interim protection measure has not been accressed. '

H.

B. EG&G Evaluation l No evaluation is possible.

l C. EG&C Conclusions and Recommendations

'This masure should be addressed before plant operation, if the implementation of the guidelines of Section 5.1, NUREG-0412, is not completed at that time.

2,4,2 Interia protection Measuren 2. 3. 4. and 1 - Administrative ,

Centeeln ,

"Pruedural er seministrative measures (including safe lead paths, lead-handlin crane inspection)..g precedures, trene operater training, and. can be acco 9

4 I

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-- ~ ~ - ---

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~ -

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- x' 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 Acolicant's Statements.

Summaries of applicant's statements are contained in discussions of the respective general guidelines in Sections 2.3.1, 2.3.2, 2.3.3, and 2.3.6, respectively.

B. EG&G Evaluations, Conclusions, and Recommendations EG&G evaluations, conclusions, and recommendatter.s are contained in discussions of the respecti.ve general guidelines in Sections 2.3.1, 2.3.2, 2.3.3, and 2.3.6.

2.4.3 Interim Protectien Measure 6--5:ecial Review for Heavy L:ats Ofer the Core .

"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 L

4 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 2

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, A. Summary of Acolicant's Statements she applicant's statements concerning th'is interim protection measure appear in an early response [4]. No additional information is provided in the later submittals[10,11].

t B. EG&G Evaluation i

The applicant has indicated that this interim protection measure will be implemented before fuel is handled over the

~

core at.the facility.

C. E3&G Conclusions As statec in [12], the applicant's planned. action satisfies the intent of Interim Protection Measure 6.

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3. CONCLUDING

SUMMARY

3.1 Acolicable load-Handlino Systems The list of cranes and hoists supplied by the applicant as being subject to the provisions of NUREG-0612 is incomplete (see Section 2.2.1 C).

3.2 Guideline Recommendations Compliance with the seven NRC guidelines for heavy load ha.-dling (Section 2.3) are. partially satisfied at Comanche Peak Units 1 and 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. Complete the development of safe load oaths for all heavy loads and mark the paths on the floor in the areas where loads are to be handled.

2. Section 2.3.2 a. Consistent with guideline 2.

3. Section 2.3.3 a. Consistent with guideline 3.

4 Section 2.3.4 a. Provide verification that special lifting cevices used on heavy load lifts meet the intent of ANSI N14.6-1978 as appended by NUREG-0612 Section 5.1.1(4) concerning dynamic effects.

5. Section 2.3.5 a. Redefine the method for computing the dynamic

, loads.

6. Section 2.3.6 a. Consistent with guideline 6.

. 7. Section 2.3.7' a. Provide information to supplement ANSI B30.16-1973 and ANSI B30.2-1967 to demonstrate that the requirements of this guideline are met in every respect. ~

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Guideline Recommendation

'b .

Re-examine the information in [11] to determine

+

if some cranes mentioned in Section 2.3.7 should be given the exempt status and if the capacities of two other cranes are underrated.

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 Comanche Peak Units 1 and 2 are met:

4

nterim Measure Recommendation

1. Section 2.4.1 Imple en: this interim measure before any spent fuel is stored in the s ent fuel pool if actions for complying with the guidelines of Section 5.1 of NUREG-0612 are not completed at that time.

5 2. Section 2.4.3 None.

3.4 Summary i

i The overhead head heavy load handling systems at Comanche Peak Units 1 and 2 partially meet the requirements of NUREG-0612, Section 5.1. The facilities fully meet the intent of Guideline 6. For all other

! guidelines, additional' information is needed to cover the areas that

, are inadequately addressed or unaddressed.

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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:

R e c'.e s t for Additional Information on Control of Heavy Loads Near Spent Fuel, 17 May 1978.

3. USNRC, Letter to Texas Utilities Generating Company.

Subject:

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

4 H. C. Schmidt Texas Utilities Services Inc. (TUSI), Letter to S. Burwell (NRC).

Subject:

Comaache Peak Steam Electric Station Control of Heavy Loads: NUREG-0612, August 7, 1981.

5. H. C. Schmidt (TUSI), Letter to S. Surwell (NRC).

Subject:

C:mancne Peak Steam Electric Station Control of Heavy Loads: NUREG-C612, Oc ober 8, 1981.

, 6. ANSI E30.2-1976, Overhead and Gantry Cranes.

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

8. ANSI 330.9-1971, Slings. *

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

10. H. C. Schmidt (TUSI), Letter to S. Burwell (NRC).

Subject:

Comanene-Peak Steam Electric Station Control of Heavy Loads: NUREG-0612, March 1, 1982.

11. H. C. Schmidt (TUSI), Letter to B. J. Youngblood (NRC).

Subject:

Comanche Creek Steam Electric Station, Occket Nos. 50-445 and 50-446, Final Response to NUREG-0612, June 8,1983.

I

12. B. W. Dixo'n (EG&G), Phase'I Interim Report.

Subject:

Control of Heavy Loads at Nuclear Plants-Comanche Peak Steam Electric Station Units 1 and 2, March 1982.

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ENCLOSURE 2 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 generai enough to be of Interest to other plants.

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. -GUIDELINE 1 SAFE LOAD PATHS 1

Exception 1 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 related' equipment combined with the design of the floor over which heavy Joads are carried indicates that for a number 'of lif ts there is no preferred load path.

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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 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 i

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-2

' ecus 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 m then be provided by intervening barriers such as floors or the provision of additional 4

lifting 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 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 l

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.

. Aporoacfies 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 i

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-i 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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Aopterches Inconsistent With this Guideline.

Use of limited exclusion areas in containment which merely prohibited the carrying of he'avy loads directly over the core or specific components and allow full lead 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 ret:;uirement for multiple markings which could confuse the crane operator.

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

} tot assist the operator and supervisor in ensucing 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 steps or drawings while controlling the crane). This feature should also be seen as

' a provisi::n necessary to complete a plan for the implementation of safe load paths.

5pec:iically it provides some additional assurance that, having spent the time and effort to develop safe load paths, those paths will be followed.

Accreaches 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 designa ed 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, rciers to the safe load path guidance during the lift and provides direct- ,

i ion to the operator and that the load path is followed. To support this approach the duties and responsibilities of each member of the Icad handling party should be clearly 4

defined.

Prior to a lift the appropriate load path is temporarily marked (repe,

. 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 ce permanent match marks can be employed to assist in positioning the bridge and/or

trolley during the lift.

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

short lif ts where movement is limited to one coordinate axis in addition to the vertical).

4 Acoroaches inconsistent With this Guideline i

Positions which in effect do not recognize the need for realistically i providing visual aids to the crane operator and imply that, for all lifts, the operator

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will remember the load path from review of procedures or by reference to a drawing.

Exception 3 .

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Obtaining written alternative. procedures approved by the plant l safety review committee for any deviations from a safe load path is considered too i

cumbersome to accommodate the handling of maintenance loads where laydown areas l i may have to change or load paths altered as a result of unanticipated maintenance j requirements, i j -

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. s Discussion The purpose of this portion of this guideline is to ensure that deviations 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 recognized, however, that issues associated with pint safety are the responsibility of an individual licensee plant safety review committee (or equivalent) and the details l of their excercizing this responsibility should be within their jurisdiction.

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Approach Consistent With this Guideline l

' - A piant 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 piant 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 Guideline Activities which in effect allow decisions as to deviations from  !

safe load paths to be made by persons not specifically designated by the piant safety review committee. ,

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- GUIDELINE 2 i.OAD HANDLING PROCEDURES i-

- No significant exceptions to this guidelirie have been encountered.

Occasionally a question arises concerning the need for individual procedures for each

' lift.. In general, it was not the purpose of this guideline to require separate procedures for each lift. A reasonable approach is to provide separate procedures fo. 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 enclosure 0

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. - . s 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 "necetsary for crane operation" will be tested at ine start of a shML -

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 all control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those features generally known as contrels (ie. hoist, bridge, and trolley motion controllers).

Acoroaches 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 will be made by the crane operator on the basis of what type of lift or direction of motion he expects for the forthcoming shift.

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GUIDELINE 4 SPECIAL LIFTING DEVICES Exception l' 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 1

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 avaHable to establish existing design stress margins and suppert future mainten-ance and repair requirements. ANSI N14.6 is an existing standard that provides require-

' ments supporting this goal for lifting device applications where the consequence of a fauure could be similar to that which could be expected in the event of the failure l of a special lifting 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 standpoint, they are as reliable as a device for which ANSI N14.6 was developed.

Acoroaches Consistent With This Guideline Although not originally specified to be designed in accordance with ANSI N14,6 the speciallif tirig device in question was provided by a reactor vendsr, 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 unavaUable, the preparation of a new stress report, the licensee has determined ,

that margins to material yield and ultimate strength are comparable to those specified 4 ..

in ANSI N14.6. Although not required of the lifting device vendor, the licensee has i

,. reviewed the design of the lifting device and prepared a list of critical components i

[. whose repair or replacement should be performed under controUed conditions.

r 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 not carry shipping containers of nuclear material v eighing more than 10,000 pounds, and thus need not comply with ANSI N14.6.

Exception 2

} No 150% overload test has been performeo 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 imi~.M.t contributor to the ability to assess the overall reliability of a device. Such a test syylements design reliability by demonstrating that the D device was properly fabricated or assembled and that a portion of the design se.fety margin has been demonstrated. Such proof of workmanship is particularly important for a fairly complicated device. It is recognized, however, that the specification i cf a 150% overload test is somewhat arbitrary and that, in some cases, the nature

( of the device is such that the lik11 hood of workmanship shortcomings is remote.

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i, Appreches Censistent With This Culdeerb -

The licensee has evaluated the lif ting device in question and has determined that design stress margins are substr.ntial. Further it has been established that the devlee 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

• Joad.

i Afthough a 130% overload test has not been performed the lifting device has been subjected to a manufacturer recommended overload to demonstrate proof of workmanship (typically 120-123%).

Acoroaches inconsistent With This Guideline See this topic for Exceptien 1 above.

Exception 3 The requirement of AN!I 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.

i Discussion i

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 lifting 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.-

i ially 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.

i-Approaches Consistent With This Culdeline Overload tests will be conducted but at a longer Interval,5 years, between tests to be consistent with the number of operational lifts required.

NDE of load bearing welds will be conducted at 3 year Intervals or, alternatively, load bearing welds will be examined through a program that ensures that a4Lwelds will be examined over a normal inservice inspection interval of 10 years 1

in a manner similar to that specified in the B&PV Code for Class 2 Component Supports.

l Aporoach Inconsistent With This Culdeline Continuing inspection will be limited to an annual visual examination of the device.

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CUIDELINE 5 LIFTING DEVICES NOT SPECIALLY DESIGNED Exception .

Licensees have taken exception to the re@lrement 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.

Discuss!'on The intent of this portion 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 hmk/ load accel-eration and deceleration. While it is acknowledged that, for operatIrg :haracteristics typical of cranes employed at nuclear power plants, these dynamic loa is are unlikely to be substantial, such a determination cannot be made generically. T rpleally the actual dynamic load due to hook / load acceleration or deceleration is a function of design hook speeds and the type of holst control system employed. It should also be recalled that ANSI B30.9 Is a general Industrial standard which appiles to all load handling cevices and does not in itself provide for any additional censervatism 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.

Aopreach Consistent With This Guldeline The licensee has evaluated the potential routine dynamic loading for lif ting devices not specially designed and feund 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 ver! fled 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 Culdeline 3 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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GUIDEI.INE 6 CRANE INSPECTION TESTING AND MAIN.TENANCE.

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 i

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 "

j vicinity of the limit switch are anticipated. ,

! Discussion

! While this issue is treated somewhat ambigously in ANSI B30.2 i j

(it is a recommendation in article 1.1.2 and a requirement in artic!e 3.2.4) It is important i

since two-blocking incidents are relatively significant contributors to load handling incidents. Further it should be noted that this test has been incorprated as a require- ,

i rnent cf 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, much a test clearly should not be made with the hook under load. Consequently if a shift change is made i with the hook loaded (this, by the way, is not a desireable practice and could be preclud-i ed through strict compliance with ANSI B30.2-3.2.3.j) a hoist limit switch test should i

not be performed. Second, there may-be circumstances where the nature of forthcoming l , 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 J

only in an area substantially removed from the upper travel limit, it would seem reason-i able to defer the limit switch test until the start of the next shift. If such an approach j is taken, however, it should be approached with care. Requirements for deferring i an upper limit switch test should accomodate the uncertainty associated with maintenance I plans and establish unambiguous criteria concerning what operations can be determined to be remote from upper trave 111mits. Such criteria should recognize that the need for upper travel limit switch protection may be preceeded by a control system failure l and consequently should conservatively allow for operater response time and potential j delays associated with emergency shutdown of the crane.

! Approach Consistent with This Guideline  !

j General compliance with this requirement. Certain specific provisions made for deferring upper limit switch testing under condl*lons that are not subject i

to opeyter interpretation.

1 Aooroaches Inconsistent With This Guideline i An approach that implies that a decmon to test or not is left to i the discretion of the operator or implies that such a test w!11 be required only if operat-l lons are planned in close proximity to the hook upper travel limit. >

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Occasionally a licensee has indicated that the overhead electric l travelling cranes employed at a site were purchased prior to the pubucation of CMAA-70 or ANSI B30.2-1976 and thus these standards should not be appUed.

Discussion -

'iTe 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 standard 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 l current standa-ds and, thus, not strictly comply with some details of these standards, t In general, though, current standards have evolved from predecesor standards in existence at the time of crane procurement (EOCI 61, ANSI B30.2 1967) and, since the later standards are not revolutiona.y, 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.

Accroach 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 lead handling reliability. In Instances where the current standard provides additional

.th e protection against the consequences of operater error or component failure licensee has proposed modifications which will result in a degree of load handling

. reliability similar to that provided in the current standard.

Approach Inconsistent 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 enougn now.

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