ML20117E074

Provides Response to NRC Bulletin 96-002, Movement of Heavy Loads Over Spent Fuel,Over Fuel in Reactor Core or Over Safety Related Equipment

ML20117E074
Person / Time
Site:	San Onofre
Issue date:	05/14/1996
From:	Marsh W SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-96-002, IEB-96-2, NUDOCS 9605150382
Download: ML20117E074 (8)

Text

i l

S "'

Southem Califomia Edison Company P. O. BOX 128 SAN CLEMENTE, CALIFORNIA 92074-0128 WALTER C. MARSH TELEPHONE MANAGER OF NUCLEAM HEOULATORY AFFAIRS (734) 368-7501 l U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 Response to NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety Related Equipment"  ;

San Onofre Nuclear Generating Station j Units 2 and 3  ;

INTRODUCTION  ;

This letter provides the Southern California Edison (Edison) response to NRC l Bulletin 96-02. Edison has completed reviewing the l handling heavy loads while the reactor is at powerin(plans and other all modes capabilities than for cold shutdown (Mode 5), refueling (Mode 6), and defueled) for San Onofre Units 2 and 3. Enclosure 1 to this letter is a table that lists the heavy load lifts that could occur over spent fuel, over fuel in the reactor core, or i over safe shutdown equipment while the reactor is at power. The table 1

l identifies whether or not we currently plan to perform the lift within the j next two years. However, unplanned and unforeseen lifts may become necessary to meet operational or maintenance needs. Enclosure 2 is a list of references that constitutes the licensing basis for Units 2 and 3, as it pertains to NUREG 0612. Enclosure 3 is a list of references that constitute the licensing basis for Unit 1, as it pertains to NUREG 0612.

REQUIRED RESPONSE TO BULLETIN 96-02 i All lifts listed in Enclosure 1 are within the current licensing basis for

[ Units 2 and 3. However, Edison is planning to change the Mode in which the l 480V transformer, Item 8 on the enclosed table, may be replaced. In the past Edison performed the transformer replacement while the plant was in a shutdown mode as stated in the correspondence listed in Enclosure 2. Recently, a

10 CFR 50.59 safety evaluation was performed to allow the transformer l- replacement during Mode 1. This safety evaluation determined that the potential drop of a transformer from either jib hoist 1 or 2 would not be credible using NUREG-0612 single failure protection criteria. Two independent n.n.o. um .. .w. ,-,.i. a

.. i-, un . .l.50.0.r ... _ .e , . .. . .

9605150382 DR 960514~

ADOCK 05000361 PDR [V>h

l

< . \

Document Control Desk hoists are to be used for this lift. Each hoist is capable of holding the entire. load during a seismic event.

Edison's plant safety review committee has reviewed the revised load path and mechanisms for performing the transformer replacement during Mode 1, based on the guidance in NUREG 0612. The committee's review found the new load path and movement methods to be acceptable. However, based on the guidance.in Bulletin 96-02, to use this new loadpath a license amendment application will i be required because this load path is included in our current licensing basis. I Having the ability to perform the 480V transformer replacement during plant '

operation would be cost effective. Therefore, Edison will be requesting j approval of this change as a Cost Beneficial . License Action. Edison now plans j to submit an amendment request to the NUREG 0612 licensing basis by August 30, 1996, and request NRC approval by March 3, 1997.

Edison does not have a dry cask facility, nor'do we plan any spent fuel transfers in the'next two years, and Edison has determined that no technical specification change or other license amendment is required at this time concerning either aspect of fuel handling involving fuel casks.

CLARIFYING INFORMATION i

Edison's review of the heavy loads program revealed the following two areas from the NRC Safety Evaluation Report (SER) (Reference 1 of Enclosure 2) that need clarification:

1) The enclosed heavy loads table does not. include empty hooks or the associated load block as separate lifts to be performed during modes 1 through 4. This approach is consistent with the heavy load tables as listed in the SER and the other references listed in Enclosures 2 and 3.

Edison does not consider a drop of an empty hook and its associated load block as credible due to the high factors of safety in design and programmatic provisions to prevent two blocking. The weight of load blocks, hooks, and rigging are included in the consideration of potential drop consequences for loads that are greater than 1500 pounds in accordance with NUREG 0612 criteria. On all cranes other than the containment polar crane, empty hooks and loads weighing less than 1500 pounds are considered routine lifts and do not receive special consideration or treatment as heavy loads. Plant procedures do impose specific restrictions on moving, raising, and lowering an empty hook or a hook with loads up to 1500 pounds over the open reactor vessel when fuel is in the vessel. This practice on Units 2 and 3 is consistent with Reference 7 of Enclosure 3, and employs the same rational as that approved for the Unit 1 heavy load program, which specifically identifies this exception to NUREG 0612 in that an empty hook and its associated load block are not considered to be heavy loads at i San Onofre.

l l

l

. _ . , _ _ - _ ~ _ _ - . , , _. _ . - _ _

l Document Control Desk l

2) The SER requires all safe load paths to have permanent or temporary markings. There are areas that are difficult or impractical to mark.

! Edison allows a second person who has physical possession of the i procedure with the safe load paths defined to " walk down" the lift and  ;

! guide the crane operator during the lift when permanent markings are

! impractical. This action is deemed as equivalent compliance since this

additional person takes the place of the temporary markings and ensures '

l the paths are followed. l If you have any questions in this matter, please call me. l l

Sincerely, I l

h$

Enclosures cc: L. J. Callan, Regional Administrator, NRC Region IV i J. E. Dyer, Director, Division of Reactor Projects, Region IV l K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 l

i

l

=

t ENCLOSURE 1 1

San Onofre Units 2 and 3 Heavy Loads During Modes 1 through 4 and Over or Near Spent Fuel or Safe Shutdown Equipment j i

Weight or Plan to Lif t i Design Included in within next Capacity Previous NRC 2 Heavy Loads by Crane (1) (tons) Submittels? years 7(n  :

1) --  : Containment Polar Crane (H

- 205/30/1 Yes CRDM Missile Shield Blocks (H 88. 5(H Yes Yes 2). '. Cask-Handling Crane (H 125/10 :Yes Irradiated Fuel Shipping Cask i

'8 125 Yes No Spend-Fuel Pool Gate (H 2.2 Yes No 3)'  : Turbine Gantry Crane, 225/60/20-' Yes Salt Water Cooling Pump Motor"8 3 Yes Yes Misc. LoadsIU"4 -- Yes Yes

4) . New Fuel, Handling Crane 5 Yes Spent-Fuel Pool Gate"8 2.2 Yes No

5) _ AFW Pump Bridge. Crane : 5 -. Yes AFW Pump Motor (Elec.)- 4.9 Yes No AFW Pump-(Elec.) 3.3 Yes No AFW Pump (Turbine) 2.5 Yes No

6) :CCW Pump Monorail 3 Yes.

CCW Pump Motor (H 3 Yes No Hatch Cover") 2.1 Yes No

7) Safety. Injection Pump Monorails 4 Yes HPSI Motor 2.9 Yes No LPSI Pump 3.8 Yes No LPSI Motor 2.8 Yes No Containment Spray Pump 3.8 Yes No Containment Spray Motor 2.8 Yes No Hatch Cover 2.9 Yes No

8)  : Penetration: Jib Hoists 1&2 6 Yes:

480V Transformer Core 3.5 YesOU Yes l.

Tendon Platfonn") 5 Yes Yes i

i

. . 1 l

l ENCLOSURE 1 l

Weight or Plan to Lift Design Included in within next Capacity previous NRC 2 Heavy Loads by Crane (1) (tons) Submittais7 years 7(" ,

1

9) TGC Side BoomOU 10 Yes '

Tendon Platform 5 Yes Yes  :

10) Diese! Bldg. Bridge Crane 3 Yes Diesel Generator Parts <3 See note 12 Yes

11) Charging Pump Monorails 5 Yes Charging Pump & Components <5 See Note 12 Yes Notes: 1) Load Block / Hook weights are not included in the tabulation of load weights. I Load Blocks and hook weights are considered in performing load drop evaluations. Loads less than 1500 lbs., excluding the weight of hooks and load blocks, are considered routine lifts and do not receive special consideration as heavy loads.

2) This column identifies lif ts currently being planned. The need to perform many of the lifts is contingent upon equipment performance and overhaul schedules. As such, those lifts that are indicated as 'No" may be performed if necessary per the current SONGS NUREG-0612 program.

3) The load block and hook (10 tons main /1.8 tons aux) with loads less than 1500 pounds may be moved during plant Modes 3 through 6.

4) Missile shield may be removed / installed during shutdown Modes 4, 5, and 6.

5) The Edison submittals and the NRC Safety Evaluation Report, the References of l Enclosure 2, contain an incorrect weight of 22.5 tons for the missile shield. l The correct maximum weight of 88.5 tons from Calculation C-257-06.07 is shown.

6) Cask Crane is physically incapable of passing over the spent fuel pool.

l However, emergency firewster tankers may be stored in the truck bay and are I required to be removed or declared out of service while crane operations are i made overhead. l

7) The cask crane does not pass over spent fuel or safe shutdown equipment.

However, the cask may contain spent fuel assemblies. Hence, it is included in this summary.

8) Gate removal / installation requires special rigging. The potential drop of a gate on the spent fuel racks is analyzed.

9) Load is carried over an intervening structure protecting safety related or safe shutdown equipment.

l 10) These loads are not specifically identified in the submittals. Miscellaneous i loads less than 1500 lbs. are routine lif ts and can be moved without rest ri ct ions . Loads greater than 1500 lbs. must comply with safe load path requirements. Miscellaneous loads which are allowed to be carried over the saltwater pump building with lif t height restrictions include, but are not limited to traveling screens a rakes, mobile cranes, manlifts, saltwater cooling pumps, screen wash pumps, circulating water pump bellows, and roof pl ugs .

l

ENCLOSURE 1 l

In addition, 480V transformers are placed uptn the roof of the auxiliary building with lift height restrictions. The liit avoids passing over the saltwater pump building and only traverses an area of the auxiliary building where no safe shutdown equipment is located directly below. The auxiliary j building roof is also capable of withstanding a transfonner drop.

11) The load path for this lift is over a single train of the component cooling water system. In Reference 4 of Enclosure 2,~ the June 30, 1982 submittal, Edison stated that transformer replacements will only occur during cold shutdown. A 10 CFR 50.59 safety evaluation has been prepared to allow this lift during plant operation using two independent hoists to meet the single l failure' protection criteria of NUREG-0612.

12) Crane is an exempt load handling system based on design redundancy. A load drop by this lif ting devica would not damage multiple trains of safety related / safe shutdown equipment. In addition, when lifts are made over safe shutdown equipment, that equipment is declared cut of service.

l l

i i

l l

I l l r i L

l l

l 1

l l

l -

l l

ENCLOSURE 2 SAN ON0FRE UNITS 2 AND 3 NUREG 0612 CORRESPONDENCE

! Reference 1: Letter from George W. Knighton (NRC) to K. P. Baskin (Edison),

i dated August 27, 1984;

Subject:

Safety Evaluation Report Relating to Control of Heavy Loads (Phase I) at San Onofre Units 2 and 3 Reference 2: Letter from K. P. Baskin (Edison) to F. Miraglia (NRC), dated July 7, 1981;

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 Reference 3: Letter from K. P. Baskin (Edison) to F. Miraglia (NRC), dated April 30, 1982;

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 Reference 4: Letter from K. P. Baskin (Edison) to F. Miraglia (NRC), dated June 30, 1982;

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3-Reference 5: Letter from K. P. Baskin (Edison) to F. Miraglia (NRC), dated August 3, 1982;

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station tinits 2 and 3 Reference 6: Letter from K. P. Baskin to F. Miraglia (NRC), dated August 25, 1982;

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 Reference 7: NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, published July 1980.

l l

l l

l l

l ENCLOSURE 3 SAN ON0FRE UNIT 1 NUREG 0612 CORRESPONDENCE Reference 1: Letter from John A. Zwolinski, (NRC) to K. P. Baskin (Edison),

dated November 4, 1985;

Subject:

Control of Heavy Loads (Phase I)

, Reference 2: Letter.from K. P. Baskin (Edison) to D. M. Crutchfield (NRC),

l dated February 5, 1982;

Subject:

Control of Heavy Loads - l l San Onofre Unit 1 '

l l

Reference 3: Letter from K. P. Baskin (Edison) to D. M. Crutchfield (NRC),

{ dated February 22, 1982;

Subject:

NUREG 0612, Control of Heavy l Loads - San Onofre Unit 1 l Reference 4: Letter from K. P. Baskin (Edison) to D. M. Crutchfield (NRC),

l dated April 1,1982;

Subject:

Control of Heavy Loads -

San Onofre Unit 1 i

Reference 5: Letter from K. P. Baskin (Edison) to D. M. Crutchfield (NRC),

dated April 9,1982;

Subject:

Control of Heavy Loads -

San Onofre Unit I l Reference 6: Letter from R. W. Krieger (Edison) to D. M. Crutchfield (NRC),

l dated May 10, 1982;

Subject:

Control of Heavy Loads - ,

San Onofre Unit 1 i Reference 7: Letter from K. P. Baskin (Edison) to D. M. Crutchfield (NRC), I dated July 6, 1982;

Subject:

Nine Month Report, Control of  :

Heavy Loads - San Onofre Unit 1 l Reference 8: Letter from K. P. Baskin (Edison) to D. M. Crutchfield (NRC),

dated October 21, 1982;

Subject:

Control of Heavy Loads -

San Onofre Unit 1 Reference 9: Letter from K. P. Baskin (Edison) to D. M. Crutchfield (NRC),

dated January 19, 1983;

Subject:

Control of Heavy Loads -

San Onofre Unit 1 Reference 10: Letter from M. O. Medford (Edison) to J. A. Zwolinski (NRC),

(. dated January 19, 1983;

Subject:

Control of Heavy Loads -

San Onofre Unit 1 Reference 11: NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, published July 1980.

d

- - -