ML20117F217
| ML20117F217 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 05/10/1996 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-96-002, IEB-96-2, NUDOCS 9605170262 | |
| Download: ML20117F217 (8) | |
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Station Support Department s
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A NRCB No. 9642 10CFR50.54(f)
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PECO NUCLEAR r= *= c-"v
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Nuclear Group Headquarters I
A UNIT of PECO fNrRGY 965 Chesterbrook Boubvard Wayne, PA 19087-5691 1
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May 10,1996 i
Docket Nos. 50-277 1
50-278 50-352 50-353 4
License Nos. DPR-44 i
DPR-56 a
NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 4
Response to NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, i
or Over Safety-Related Equipment" Gentlemen:
By letter dated April 11,1996, the NRC issued Bulletin (NRCB) No. 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core or Over Safety-Related Equipment." This Bulletin requests that licensees review their plans and capabilities for handling heavy loads (e.g.,
spent-fuel dry storage casks, and reactor cavity biological shield plugs) in accordance with i
existing regulatory guidelines [specifically NUREG-0612 (Phase 1) and Generic Letter (GL) 85-11]
and with their licensing basis as previously analyzed in the Final Safety Analysis Report (FSAR).
Also, this Bulletin requires licensees to report to the NRC whether and to what extent they have 4
complied with the requested actions contained in this Bulletin and provide a written response i
within 30 days of the date of this Bulletin.
Att&ched is PECO Energy's response to NRCB 96-02 for Peach Bottom Atomic Power Station, l
Units 2 and 3, and Limerick Generating Station, Units 1 and 2. Each reporting requirement is
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restated in the attachment followed by our response This letter is being submitted under affirmation in accorrfance with 10CFR50.54(f), and the required affidavit is enclosed.
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9605170262 960510 l
PDR ADOCK 05000277
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May 10,1996 Page 2 If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, fo G. A. Hun 0er, Jr.
Director - Licensing Attachment Enclosure cc:
T. T. Martin, Administrator, USNRC, Region I (w/ attachment & enclosure)
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachment & enclosure)
W. L Schmidt, USNRC Senior Resident inspector, PBAPS (w/ attachment & enclosure) i
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. COMMONWEALTH OF PENNSYLVANIA ss.
f COUNTY OF CHESTER D. B. Fetters, being first duly sworn, deposes and says:
That he is Vice President of PECO Energy Company; that he has read the foregoing response to NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment," for Peach Bottom Atomic Power Station, Units 2 and 3, and Umerick Generating Station, Units 1 and 2, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
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Vice President Subscribed and sworn to before me this /d day of 1996 w'
udL Nota Public j
Notarial Seal Ma Lou Skrocki. Notary Public rin Twp., Chester County My Comm;ssion Expires May 17,1999 f.:
her, Penrn/vana tumtion of rh 1
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f ATTACHMENT Peach Bottom Atomic Power Station, Units 2 and 3 Umarick Generating Station, Units 1 and 2 Response to NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment" i
Attachment Page 1 of 4 Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Response to NRC Bulletin 9602 On Apru 11,1996, the NRC issued NRC Bulletin (NRCS) No. 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment,' to alert licensees for nuclear power reactors to the importance of complying wth existing regulatory guidelines associated with the control and handling o' heavy loads at nuclear power plants whNe the plant is operating (in all modes other than cold shutdown, refueling and defueled). The Bulletin noted that some licensees have moved or are planning to move heavy loads, such as spent fuel shipping casks, transfer casks, and reactor cavity biological shield blocks, during plant operations, and, if these loads experience uncontrolled movement or are dropped on safety-related equipment, the impacted equipment may be unable to perform its functions. A specific example noted in the Bulletin involved a licensee who was scheduled to begin moving spent fuel in dry storage casks weighing 100 tons. The NRC audited the 10 CFR 50.59 evaluations performed by the licensee in support of the proposed actMties and determined that the proposed tasks represented an unreviewed safety question. This determination was based on the facts that the actMty involved loads heavier than previously analyzed in the FSAR, that the load drop had not been evaluated over the entire load path and that the possibuity of a load drop in the reactor buHding whue the reactor is at power could result in consequences that are greater than those previously postulated in the FSAR. Therefore,10CFR50.59 required that the licensee submit an application for a license amendment to the NRC for review and approval pursuant to the requirements of 10 CFR 50.90.
Accordingly, NRCB 9642 requires that all holders of operating licenses for nuclear power reactors review plans and capablities for handling heavy loads whHe the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) in accordance with existing regulatory guidelines and determine whether the activities are within the licensing basis. If necessary, a license amendment request should be submitted. NRC8 96-02 also requests that licensoes determine whether changes to Technical Specifications (TS) wNi be required in order to allow the handling of heavy loads (e.g., the dry storage canister shield plug and associated lifting devices) over fuel assemblies in the spent fuel pool.
In addition, NRC8 96-02 requires that all licensees of nuclear power reactors provide a written response within 30 days of the date of the bulletin as stipulated in the " Required Response" section. Each reporting requirement is restated below followed by PECO Energy's response for PBAPS, Units 2 and 3, and LGS, Units 1 and 2.
Reoortina Reauirement 1 For licensees planning to implement activities involving the handling of heavy loads over spent fuel, fuel in the reactor core, or safety-related equipment within the next 2 years from the date of this bulletin, provide the following:
A report, within 30 days of the date of this bulletin, that addresses the licensee's review of its plans and capabRities to handle heavy loads whue the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) in accordance with existing regulatory guidelines. The report should also indicate whether the activities are within the licensing basis and should include, if necessary, a schedule for submission of a license amendment request. Additionally, the report should indicate whether changes to Technical Specifications wHl be required.
i Attachment Page 2 of 4
Response
PECO Energy is rsviewing its plans and capabuities for handling heavy loads at PBAPS, Units 2 and 3, and LGS, Units 1 and 2, whBe the reactors are at power as requested in this NRCS 96-02. This effort involves reviewing the following licensing basis documentation associated with moving heavy loads at PBAPS and LGS.
PBAPS and LGS Heavy Load Program (i.e., NUREGM12 implementation) documentation.
Applicable NRC Safety Evaluation Reports (SERs).
PBAPS and LGS Updated Final Safety Analysis Reports (UFSARs).
Applicable heavy loads implementing procedures.
Applicable commitments.
Heavy Loads Training Program requirements.
l To date this review has determined that NUREG-0612, Phase 1, commitments are being effectively l
Implemented at PBAPS and LGS. Actions have been taken to enhance some of our original commitments ( e.g., training), and most NUREG-0612, Phase ll, actions were retained (e.g., height and weight restrictions, and electrical interlocks on Reactor Buuding cranes and Pump Structure crane).
Also included in this review were other or new type of load lifts that have been performed since the issuance of the NRC SERs. This review involved evaluating previous 10CFR50.59 Reviews prepared in support of heavy load movements at PBAPS and LGS.
l One specific heavy load activity presently being reviewed at both PBAPS and LGS is the lifting of the reactor cavity biological shield plugs whHe the units are operating. The reactor cavity shield plugs are moved in preparation for refueling outages at PBAPS and LGS whHe at low power (i.e., less than 25%
power). Lifting of the shield plugs Is also used at PBAPS for calibration of the load cell of the Reactor i
BuHding crane during plant operation. The Reactor Bulding cranes at PBAPS and LGS meet single-falure proof requirements, although the associated lift points on the shield plugs do not meet the single faBure proof criteria. The lifting of the reactor cavity shield plugs does meet NUREG-0612, Phase I, guidelines and Generic Letter 85-11 which stated that the implementation of NUREG-0612 Phase I, has provided sufficient protection such that the risk associated with potential heavy load drops is acceptably small. As a result, past reviews determined that this activity was within the scope of the approved heavy loads program. Therefore, the possiblity of a load drop was deemed not significant, and no rigorous load drop analysis was performed to evaluate the potential consequences of a load drop of a shield plug on an operating reactor area. However, in light of the recommendations specified in NRCB 96-02, we have determined that additional evaluation is necessary to support the lifting of reactor cavity shield plugs while at low power at PBAPS and LGS in order to adequately address the Requested Actions stipulated in this Bulletin to ensure there is no unreviewed safety question. If required by this additional evaluation, a load drop analysis would be performed to determine if there would be an unreviewed safety question.
Some changes of original commitments have been identified during this current review; however, we consider these changes to be minor. Additional evaluations are being performed to ensure that these issues are resolved.
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Attachment Page 3 of 4 Future actMties, at PBAPS and LGS, involving the handling of heavy loads near spent fuel, fuel in the reactor core, or safety-related equipment within the scope of NRCB 96-02 wil be evaluated on a case-bymase basis. Based on the results of these evaluations, the appropriate actions wHl be taken as required by NRCB 96-02.
Other heavy load lifts occur during power operations on the refuel floors at PBAPS and LGS. However, these load irs are performed within the height and weight restrictions noted in our heavy loads procedures or are rigged such that they meet the criteria for a single-faHure proof equivalent lift.
Therefore, we consider these lifts to be within the existing analysis for heavy loads at PBAPS and LGS and thereby satisfy the requested action described in NRCB 96-02.
At this time there appears to be no need to request changes to the PBAPS, Units 2 and 3, and LGS, Units 1 and 2, Technical Specifications.
Reoortina Reauirement 2 For licensees planning to perform activities involving the handling of heavy loads over spent fuel, fuel in the reactor core, or safety-related equipment whue the reactor is at power (in all modes other than cold shutdown, re8ueling, and defueled) and that involve a potential load drop accident that has not previously been evaluated in the FSAR, submit a license amendment request in advance (6-9 months) of the planned movement of the loads so as to afford the staff sufficient time to perform an appropriate review
Response
Based on PECO Energy's review of its plans and capablities to handle heavy loads whHe the reactor is at power, and the Requested Actions stipulated in NRCB 96-02, we have determined that further review is necessary to facultate lifting of the reactor shield plugs at low reactor power conditions (e.g., below 25% power) in preparation for refueling outages at PBAPS and LGS. As indicated above, PECO Energy wHl continue to evaluate, on a case-by-case basis, any heavy load lifts that are made during power operations at PBAPS and LGS against the recommendations delineated in this Bulletin, and if necessary, submit the appropriate license amendment request.
Reoortino Reauirement 3 For licensees plannirh to move dry storage casks over spent fuel, fuel in the reactor core, or safety-related equipment whHe the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) include in item 2 above, a statement of the capablity of performing the actions necessary for safe shutdown in the presence of radiological source term that may result from a breach of the dry storage cask, damage to the fuel, and damage to safety-related equipment as a result of a load drop inside the faculty.
Response
PECO Energy does not anticipate using dry storage casks in the next two years; therefore, a statement regarding the capabulty of performing the actions as described in Reporting Requirement 3 above is not considered necessary at this time. However, in the event dry storage casks are used in the future at PBAPS, Units 2 and 3, or LGS, Units 1 and 2, an analysis wHI be performed and wHl consider the capabutty to perform the actions necessary to achieve safe shutdown as discussed in the above Reporting Requirement.
Attachment Page 4 of 4 Reocrtina Reauirement 4 For licensees planning to perform activities involving the handling of heavy loads over spent fuel, fuel in the reactor core, or safety-related equipment while the reactor is at power (in all modes other than cold shutdown, refueling, and defueled), determine whether changes to Technical Specifications will be required in order to allow the handling of heavy loads (e.g., the dry storage canister shield plug) over fuel assemblies in the spent fuel pool and submit the appropriate information in advance (6-9 months) of the planned movement of the loads for NRC review and approval.
Response
PECO Energy has reviewed planned actMtles associated with handling heavy loads as described in Reporting Requirement 4 above for PBAPS, Units 2 and 3, and LGS, Units 1 and 2, and determined that no changes to Technical Specifications are necessary at this time to facilitate the handling of heavy loads over fuel assemblies in the Spent Fuel Pool.
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