ML20209C533
| ML20209C533 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon |
| Issue date: | 10/31/1983 |
| From: | Jensen S EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML16340C148 | List:
|
| References | |
| CON-FIN-A-6457, FOIA-86-151, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NUDOCS 8311020411 | |
| Download: ML20209C533 (40) | |
Text
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y 44 CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS 7
PACIFIC GAS AND ELECTRIC DIABLO CANYON UNIT 2 (PHASE.1)
Docket No. 50'323 Author S. A. Jensen Principal Technical Investigator T. H. Stickley Published October 1983 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Under DOE Contract No. DE-AC07-76IO01570
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,a ABSTRACT s-The Nuclear Regulatory Commission (NRC) has requested that all nuclear plants, either operating or under construction, submit a response of compliancy with NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants." EG&G Idaho, Inc., has contracted'with the NRC te tialuate the responses of those plants presently under construction.
This report contains EG&G's evaluation and recommendations for Diablo Canyon Unit 2.
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>f' EXECUTIVE
SUMMARY
Diablo Canyon Unit 2 does not totally comply with the guidelines of NUREG-0612.
In general, information is insufficient in the following areas:
Information on special lifting devices was insufficient to verify o
compliance with ANSI N14.6-1978.
The main report contains recommendations which will aid in bringing the above item into compliance with the appropriace guidelines.
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CONTENTS ABSTRACT............................................................
1 EXECUTIVE
SUMMARY
11 1.
INTRODUCTION....................................................
1 1.1 Purpose of Review.........................................
1 1.2 Generic Background........................................
1 1.3 Plant-Specific Background.................................
3 2.
EVALUATION AND RECOMMENDATIONS..................................
4 2.1 Overview..................................................
4 2.2 Heavy Load Overhead Handling Systems......................
4 2.3 Guidelines................................................
6 3.
CONCLUDING
SUMMARY
19 3.1 Applicable Load Handling Systems..........................
19 3.2 Guideline Recommendations.................................
19 4.
REFERENCES......................................................
21 TABLES 2.1 Category 1 overhead handling systems............................
5 3.1 NUREG compliance matrix.........................................
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CONTROL OF HEAVY LOADS AT NUCLEAR POWER PLANTS PACIFIC GAS AND ELECTRIC DIABLO CANYON UNIT 2 (PHASE I) 1.
INTRODUCTION 1.1 Purpose of Review This technical evaluation report documents the EG&G Idaho, Inc.,
review of general load-handling policy and procedures at Diablo Canyon Unit 2.
This evaluation was performed with the objective of assessing conformance to the general load-handling guidelines of NUREG-0612
" Control of Heavy Loads at Nuclear Power Plants" [1], Section 5.1.1.
This constitutes Phase I of a two phase evaluation.
1.2 Generic Background Generic Technical Activity Task A-36 was established by the U.S.
Nuclear Regulatory Commission (NRC) staff to systematically examine staff licensing criteria and the adequacy of measures in effect at operating nuclear power plants to assure the safe handling of heavy loads and to recommend necessary changes to these 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 NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants." Tha staff's conclusion from this evaluation was that e'.isting 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 acci/ents and should be upgraded.
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In order to upgrade measures for the control of heavy loads, the staff developed a series of guidelines designed to achieve.a two phase objective using an accepted approach or protection philosophy. The first portion of the objective, achieved through a set of general guidelines identified in NUREG-0612, Article 5.1.1, is to ensure that all load-handling systems at nuclear power plants are designed and operated such that their probability of failure is 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 providedy in addition to those required for all load-handling systems, to ensure that the potential for a load drop is extremely small (e.g., a-single-failure proof crane) or (b) conservative evaluations of load-handling accidents indicate.that the potential consequences of any load drop are acceptably small. Acceptability of accident consequences is quantified in NUREG-0612 into four accident analysis evaluation criteria.
The approach used to develop the staff guidelines for minimizing the potential for a load drop was based on defense in depth and is summarized as follows:
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Provide sufficient operator training, handling system design, load-handling instructions, and equipment inspection to assure reliable operation of the handling system o
Define safe load travel paths through procedures and operator training so that, to the extent practical, heavy l
loads are not carried over or near irradiated fuel or safe shutdown equipment I
o Provide mechanical stops or electrical interlocks to prevent movement of heavy loads over irradiated fuel or in proximity to equipment associated with redundant shutdown paths.
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e' Staff guidelines resulting from the foregoing are tabulated in Section 5 of NUREG-0612.
1.3 Plant-Specific Background On December 22, 1980, the NRC issued a letter [3] to Pacific Gas and Electric (PG&E),the applicant for Diablo Canyon, requesting that the applicant review provisions for. handling and control of heavy loads at Diablo Canyon, evaluate these provisions with respect to the guidelines of NUREG-0612, and provide certain additional information to be used for an independent determination of conformance to these i
guidelines.
On July 29, 1983, PG&E provided the initial respor:se [4]
to this request.
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2.
EVALUATION AND RECOMMENDATIONS 2.1 Overview The following sections summarize Pacific Gas and Electric's review of heavy load handling at Diablo Canyon Unit 2 accompanied by EG&G's evaluation, conclusions, and recommendations to the applicant for bringing the facilities more completely into compliance with the intent of NUREG-0612.
The applicant has indicated the weight of a heavy load for this facility (as defined in NUREG-0612, Article 1.2) as 1813 pounds.
12. 2 Heavy Load Overhead Handling Systems This section reviews the applicant's list of overhead handling systems which are subject to the criteria of NUREG-0612 and a review of the justification for excluding overhead handling systems from the above-mentioned list.
2.2.1 Scope
" Report the results of your review of plant arrangements to identify all overnaad handling systems from which a load drop may result in damage to any system required for plant shutdown or decay haat removal (taking no credit for any interlocks, technical specifications, operating procedures, or detailed l
structural analysis) and justify the exclusion of any overhead handling system from your list by verifying that there is sufficient physical separation from any load-impact point and any safety-relsted component to permit a determination by inspection that no heavy load drop can result in damage to any system or component required for plant shutdown or decay heat removal."
i A.
Summary of Applicant's Statements The applicant's review of overhead handling systems identified the cranes and hoists shown in Table 2.1 as those which handle heavy loads in the vicinity of irradiated fuel or safe shutdown eouipment.
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TABLE 2.1 CATEGORY 1 OVERHEAD HANDLING SYSTEMS Crane Description T
C-140-07 200 Containment Structure Polar Crane C-140-12 2T Reactor Head Stud Tensioner Monorail C-140-14 IST Missile Shield Hoist T
AF-140-08 125 Fuel Handling Area Crane T
AF-100-14 3 Monorail for Motor Driven Aux. Feedwater Pump 2-2 T
T-140-01 115 Turbine Building Bridge Crane T
T-140-02 115 Turbine Building Bridge Crane T
T-119-13 20 Monorail for Moisture Separator Reheater 2-2A I
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The applicant has also identified numerous other cranes that have been excluded from satisfying the criteria of the general guidelines of NUREG-0612. The first criteria used to exclude cranes was physical separation. The applicant defined physical separation "as horizontal offset between the load path and any target component at any elevation underneath the load, accounting for the width of the load and the target." Load-handling systems were also excluded "if the only component which could be damaged by the load drop would already be out of service for repair or maintenance." Systems carrying loads less than the defined heavy load of 1813 lb were also excluded.
The auxiliary building, intake structure and solid radwaste storage building are common to the two units at Diablo Canyon, and were covered in their entirety in PG and E's Unit I response; therefore, they were not covered here. The turbine building was covered from column 19 south.
B.
EG&G Evaluation The applicant has used criteria consistent with the intent of NUREG-0612 to exclude cranes from satisfying the criteria of the general guidelines.
C.
EG&G Conclusions and Recommendations On basis of the information available, EG&G concludes that the applicant has included all applicable hoists and cranes 1
in their list of handling systems which must comply with the requirements of the general guidelines of NUREG-0612.
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.m 2.3 General Guidelines d
This section addresses the extent to which the applicable handling systems comply with the general guidelines of WUP.EG-0612, Article 5.l.1.
EG&G's conclusions-and recommendations are provided in summaries for each guideline.
The NRC has estabitshed seven general guidelines whien must be met in order to provide the defense-in-depth approach for the handling of heavy loads.
These guidelines consist of the following criteria from Section 5.1.1 of NUREG-0612:
o Guideline 1--Safe Lord Paths o
Guideline 2--Load Handling Procedures Guideline 3--Crane Operator Training o
o Guideline 4--Special Lifting Devices Guideline 5--Lif tir.g Devices (not specially designed) o Guideline 6--Cranes (Inspection, Testing, and Maintenance) o o
Guideline 7--Crane Design.
These seven guidelines should be satisfied for all overhand hacdling systems and programs in order to handle h.eavy loads in the vicinfty of the reactor vessel, near spent fuel in the spent-fuel pool, or in other areas where a load drop may damage safe shutdown systems.
The succeeding paragraphs address the guidelines individually.
2.3.1 Safe Load Paths [ Guideline 1, NUREG-0612, Article 5.1.1(1)]
" Safe load paths should be defined for the movement of heavy loads to minimize the potertial for heavy loads, if dropped, to i
impact irradiated fuel in the reactor vessel and in the spent-fuel pool, or to imps.ct safe shutdown equipment.
The path should follow, to the extent practical, structural floor members, beams, etc., such that if the load is dropped, the structure is more likely to withstand the impact.
These load paths should De defined in procedures, shown on equipment layout drawings, and i
clearly marked on tne floor in the area where the load is to be r
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Deviations from defined load paths should require written alternative procedures approved by the plant safety review committee."
A.
Summary of Applicant's Statements PG&E included in their response several drawings showing load paths for the cranes listed in Table 2.1.
The applicant also stated that these " load paths were determined with the objective of avoiding the spent-fuel pool, the reactor cavity, and other safety-related equipment where possible." The applicant stated that detailed procedures will identify areas of exclusion and other administrative requirements.
The lifting procedure (s) will require the rigger-in-charge to provide visual aid to the crane operator.
B.
EG&G Evaluation PG&E has developed and shown-load paths on equipment layout drawings for all of the applicable cranes. While marking the load path on the floor is not mentioned by the i
applicant, they have stated that visual aid kill be provided by the rigger-in-charge with the help of detailed drawings.
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C.
EG&G Conclusions ar.d Recommendations Procedures ar.d safe load paths for heavy loads at Diablo Canyon Unit 2 are consistent with the intent of Guideline 1 l
based on the information provided by PG&E.
2.3.2 Load-HandjingProcedures[ Guideline 2,NUREG-0612, Article l
5.1.1(2)]
" Procedures should be developed to cover load-handling operations
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for heavy loads that are or could be handled over or in proximity to irradiated fuel or safe shutdown equipment. At a minimum, 8
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procedures should cover handling of those loads listed in Table 3-1 of NUREG-0612.
These procedures should include:
identification of required equipment; inspections and acceptance criteria required before movement of load;.the steps and proper sequence to be followed in handling the load; defining-the safe path; and other special precautions."
A.
Summary of Applicant's Statements PG&E uses a general procedure for handling heavy equipment (PG&E Nuclear Plant Administrative Procedure C-702).
They also stated that additional procedures " identify major lifts, handling, interlocks, and other administrative requirements."
B.
EG&G Evaluation The applicant states that load-handling procedures have been developed at the Diablo Canyon Nuclear Plant.
These procedures were also stated to contain the information specified in the guideline.
C.
EG&G Conclusions and Recommendations Diablo Canyon Unit 2 is consistent with Guideline 2 in that procedures have been developed by the applicant to meet the j
criteria of this guideline, i
2.3.3 Crane Operator Training [ Guideline 3, NUREG-0612, Article 5.1.1(3)]
" Crane operators should be trained, qualified, and conduct i
themselves in accordar,ce with Chapters 2-3 of ANSI B30.2-1976,
' Overhead and Gantry Cranes' [5].".
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A.
Summary of Applicant's Statements PG&E stated that " training courses, operator certification, and procedures to control operator conduct all meet the requirements of ANSI B30.2-1976 without exception. A training course for qualifying crane operators, " Maintenance Training Course M-21," has been developed as " Nuclear Plant Administrative Procedure B-750."
8.
EG&G Evaluation Based on the applicant's response, training courses, operator certification, and conduct are consistent with this guideline.
C.
EG&G Conclusion and Recommendations Diablo Canyon Unit 2 procedures and requirements are consistent with the requirements of Guideline 3 based on the information provided.
l 2.3.4 Special Lifting Devices [ Guideline 4, NUREG-0612, Article 5.1.1(4)]
"Special lifting devices should satisfy the guidelines of ANSI N14.6-1978, ' Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More for Nuclear Materials' [6). This standard should apply to all special lifting devices which carry heavy loads in areas as defined above.
For operating plants, certain inspections and load tests may be accepted in lieu of certain material requirements in the standard.
In addition, the stress design factor stated in Section 3.2.1.1 of ANSI N14.6 should be based on the combined maximum static and dynamic loads that could be imparted on the i
handling device based on characteristics of the trane which will be used.
This is in lieu of the guideline in Section 3.2.1.1 of l
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ANSI N14.6 which bases the stress design factor on only the weight (static load) or the load and of the intervening components of the special handling device."
A.
Summary of Applicant's Statements The applicant identified three special lifting devices that must conform with ANSI N14.6 requirements.
They were the reactor vessel head lifting device, the reactor internals lifting device, and the reactor vessel inspectica tool lifting device.
The applicant eliminated several special lifting devices either because "they do not carry loads over safe-shutdown components or spent fuel, or... that no load drop caused by their failure could adversely affect safe-shutdown capability or the integrity of exposed fuel."
l The applicant has evaluated the reactor vessel head lifting device and the reactor internals lifting device.
Conclusions of their. evaluation are as follows:
" Item-by-item evaluation of the RPV Head and Internals Lifting Devices shows that, in general, the rigs meet the intent of the ANSI N14.6-1978 standard.
Some of the operation and maintenance procedures will be modified to comply with ANSI requirements.
"The results of the detailed stress evaluation showed that the computed stresses are, in general, well within the AISC allowable stresses, and in many cases, these are only a fraction of the ultimate strength of the material.
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stress design factor requirements of ANSI N14.6-1978 are not l
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completely satisfied; nevertheless,...the rigs are considered to have safe load-handling capability.
"PG&E plans to contract out the reactor vessel inspection to specialized contractors,~and to require the contractor's RVIT lifting device to comply with all applicable portions of ANSI N14.6."
B.
EG&G Evaluation The applicant identified three special lifting devices.
In EG&G's judgment, PG&E's evaluation of these three devices is consistent with the intent of this guideline and the requirements of ANSI N14.6 with the following exception:
The reactor vessel head lifting device and the reactor internals lifting device have not been subjected to a test' load greater than their rated load. ANSI N14.6 requires a s
150% overload test. A test greater than 100% of rated load should be performed even if the full 150% is not possible.
A typical test to demonstrate proof of workmanship might be in the 120-125% range.
PG&E evaluation showed that in some cases the stress design ~
factors of ANSI N14.6 are not satisfied.' However, the l
design factors in all cases meet AISC allowables.
EG&G feels that for the few cases where ANSI N14.6 stress design factors are not satisfied, a testing and inspection program I
withspecialattentiontothosepartswhich$avelower safety factor is consistent with the intent of the guideline.
Also, procedures to reduce:the possibility of impact or dynamic loads should be used for these devices.
l Those special lifting devices which are excluded from '
ANSI N14.6 evaluation on the casis of redundancy of I
equipment over which thsy operate should be evaluated by l
PG&E.
Since redundancy in some cases is accomplished by l
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" U procedures which may fail because of human'or mechanical failures, and since.the requirements of NUREG-0612 are based on protection in depth, EG&G feels that elimination of some special lifting devices on the basis of redundancy of system over which they operate is inconsistent with the intent of this guideline.
C.
EG&G Conclusions and Recommendations Diablo Canyon Unit 2 does not now fully comply with the requirements of Guideline 4 and ANSI N14.6-1978.
Compliance with this guideline should be complete for each special lifting device before it is used to lift a heavy load near fu'el or safety-related equipment.
In order to comply or to justify noncompliance, EG&G recommends that the applicant perform the following:
(1) Evaluate special lifting devices not evaluated due to redundancy of equipment over which they are used.
(2) Perform an adequate overload test for special lifting devices to ensure that adequate strength has been attained in the lifting devices.
(3) Reduce the possibility of overstress in the lifting devices with low safety factors by reducing the possibility of impact loads through the use of procedures which may use lower crane speeds, load paths which reduce the possibility of impact, and any other procedure which may reduce dynamic load possibilities.
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2.3.5 Lifting Devices (Not Specially Designed) [ Guideline 5, NUREG-0612, Article 5.1.1(5)]
" Lifting devices that are not specially designed should be installed and used in accordance with the guidelines of ANSI B30.9-1971, ' Slings" [7].
However, in selecting the proper sling, the load used should be the sum of the static and maximum dynamic load.
The rating identified on the sling should be in terms of the ' static load' which produces the maximum static and dynamic load. Where this restricts slings to use on only certain cranes, the slings should be clearly marked as to the cranes with which they may be used."
A.
Summary of Applicant's Statements The applicant states that all slings used at Diablo Canyon Unit 2 meet or exceed the requirements of ANSI B30.9-1971, except that approximately half of the slings were proof-tested and tagged since they had not been tagged prior to the applicant's initial response.
The applicant also states that dynamic loads are accounted for in sling marking and use.
B.
EG&G Evaluation The applicant's response provides sufficient information for EG&G to state that they are consistent with Guideline 5.
C.
EG&G Conclusions and Recommendations
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The Diablo Canyon Nuclear Plant is consistent with Guideline 5.
2.3.6 Cranes (Inspection Testing, and Maintenance) [ Guideline 6, NUREG-0612,' Article 5.1.1(6)]
"The crane should be inspected, tested, and maintained in accordance with Chapter 2-2 of ANSI B30.2-1976, ' Overhead and l
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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_PWR containment may only be used every 12 to 18 months during refueling operations, and is generally not accessible during power operation. ANSI B30.2, however, calls for certain ir,spections to be performed daily or monthly.
For such cranes having limited usage, the inspections, test, and maintenance should be performed prior to their use)."
A.
Summary of applicant's Statements Crane. inspection, testing, and maintenance meets or will i
meet the requirements of ANSI B30.2 except for certain test frequencies which cannot be met due to-inaccessibility as i
noted in NUREG-0612 Guideline 6.
B.
EG&G Evaluation The applicant states that PG&E's crane inspection, testing, and maintenance program is based on ANSI B30.2-1976.
C.
EG&G Conclusions and Recommendations The Diablo Canyon Nuclear Plant Unit 2 is consistent with Guideline 6.
The crane inspection, testing, and maintenance programs are based on the requirements of ANSI B30.2-1976.
2Property "ANSI code" (as page type) with input value "ANSI B30.2-1976.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3.7 Crane Design [ Guideline 7, NUREG-0612, Article 5.1.1(7)]
"The crane should be designed to meet the applicable criteria and guidelines of Chapter 2-1 of ANSI B30.2-1976, ' Overhead and l
Gantry Cranes,' and of CMAA-70, ' Specifications for Electric I
Overhead Traveling Cranes' [8]. An alternative to a i
specification in ANSI B30.2 or CMAA-70 may be accepted in lieu of specific compliance if the intent of the specification is satisfied."
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A.
Summary of Applicant's Statements Bridge cranes at Diablo Canyon were designed prior to publishing of CMAA-70 and Chapter 2-1 of ANSI 30.2-1967.
The main code used in their design was the " Specification for Electrical Overhead Traveling Cranes for Steel M.ill Service," Association of Iron and Steel Engineers Standard No. 6 (tentative) dated May 1, 1969.
Specific differences, between the design codes used and those required by Guideline 7, identified by the applicant include the following:
(1) Welding on the cranes was done in accordance with AWS D.2.0 rather than AWS D.14.1.
(2)
Impact loading reautrements are different, but all the cranes conform to the CMAA 70 specification at their rated capacity.
(3) CMAA 70 requires higher moments of inertia for longitudinal stiffeners than the AISE code, but load testing has not indicated any problems.
(4) Nominal allowable stresses vary between the before-mentioned standards.
The applicant justified some differences by comparing crane use and loading criteria between the standards and by stating that cranes have been successfully tested to 125% of rated capacity.
(5) Mechanical differences in required horsepower, tolerances for wheels, and clearances between wheels and rails were also noted and deemed not to be l
significant.
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Monorails and hoists which do not fall into classifications of which CMAA 70 and ANSI B30.2 apply were compared to other similar codes and standards.
The monorails and hoists were stated to satisfy the requirement of these stan,dards, except for one monorail which does not satisfy AISC allowable stresses. The monorail is being modified to satisfy the AISC requirements.
B.
EG&G Evaluation The cranes at Diablo Canyon Nuclear Plant Unit 2 were procured to industrial standards of the time.
Based on PG&E's comparison of differences, EG&G would concur that the cranes which PG&E included in their response meet the intent of Guideline 7.
Monorails and other cranes which do not easily fall into the classifications for which CMAA 70 and ANSI B30.2 apply were l
compared to similar standards, and were stated to comply with those standards, or that modifications were being done to ensure compliance.
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C.
EG&G Conclusions and Recommendations Diablo Canyon Unit 2 overhead bridge or gantry cranes are consistent with Guideline 7 on the basis of compliance to AISE Standard No. 6 criteria.
Information available on design standards for the majority of the cranes listed as being subject to the guidelines shows that they are consistent with standards comparable to those specified by the guideline.
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o-3.
CONCLUDING
SUMMARY
3.1 Applicable Load-Handling Systems The list of cranes and hoists supplied by the applicant as being subject to the provisions of NUREG-0612 is adequate (see Section 2.2.1).
3.2 Guideline Recommendations Compliance with the seven NRC guidelines for heavy load-handling (Section 2.3) are partially satisfied at Diablo Canyon Unit 1.
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.
Diablo Canyon Unit 2 is consistent with this guideline'.
2.
(Section 2.3.2) a.
Diablo Canyon Unit 2 is consistent with this guideline.
3.
(Section 2.3.3) a.
Diablo Canyon Unit 2 is consistent with this guideline.
4.
(Section 2.3.4) a.
Evaluate special lifting devices not presently evaluated, b.
Perform an adequate overload test for special lifting devices.
c.
Reduce the possibility of large impact load for the special lifting device having low safety factors.
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Guideline Recommendation 5.
(Section 2.3.5) a.
Diablo Canyon Unit 2 slings are consistent with this guideline.
6.
(Section 2.3.6) a.
PG&E's crane inspection testing and maintenance program is consistent with this guideline.
7.
(Section 2.3.7) a.
Cranes and hoists at Diablo Canyon Unit 2 are consistent with the intent of this guideline.
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TABLE 3.1 DIABLO CANYON COMPLf UICE MATRIE Weight Guideline i Guideline 2 Guideline 3 Guideline 4 Guideline 5 Guideline 6 Guideline i
or Equipment Crane Special Crane-Tes t Capacity Safe Load Operator Lifting and Designation Heavy Loads (tons)
Paths Procedures Training Devices Slings Inspection Crane Dest C-140-01 Containment Polar Crane (200T C
C C
C C
Gantry) i 1.
Reactor head w/CROM 172.5T C
C l
lifting device NC 2.
Upper internals w/
77.5I C
C MC Ilfting device 3.
Lower internals w/
142.5T C
C NC lifting device 4.
Missile shleid 17T C
C C
5.
Internals lifting 7.5T C
C NC device 6.
Reactor head 12.5T C
C NC Ilfting device 7.
Reactor coolant 3.8T C
C pump motor 8.
Reactor coolant 43.8T C
C 1
pump internals
- 9.
Reactor coolant 6.4T C
C I
pump flywheel I
- 10. Reactor coolant 1.5T C
C C
pump hatch
- 11. Containment fan 2T C
C C
cooler motor
- 12. Head bolts and 5.4T C
C C
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TA8tE 3.1 (Continued)
Welqht Guideline 1 Guideline 2 Guideline 3 Guideline 4 Guideline 5 Guideline 6 Guideline 7 i
or Crane Special Crane-Test Equipment Capacity Safe Load Operator Lifting and Designation Heavy Loads (tons)
Paths Procedures Training Devices Slines Inspection Crane Design _
- 13. Reactor vessel 5.25T C
C C
inspection tool
- 14. Main hoist load 7.3T C
block CF-140-06 Tensioner 1.3T C
C C
i HegdStudTensioner C
C (2 Manorall)
AF-140-06 i
C C
C Fuel Handling 4
C C
1 Area Crane
( 12 5I Bridge) 1.
New fuel in 3T C
C shipping containers 2.
Spent-fuel 67.5T C
C shipping cask Main hoist load 2.5T C
block AF-100-14 C
C C
Motor Driven C
C Avulliar Pumps (3{ Feed j
Pump 2.0T C
C C
I Motor 2.3T C
C C
I
TA8tE 3.1 (Continued)
Weight Guideline I Guideline 2 Guideline 3 Guideline 4 Guideline 5 Guideline 6
%5deline or Crane Special Crane-Test Equipment Capacity Safe Load Operator Lifting and Deslenation Heavy Loads (tons)
Paths Procedures Training Devices Silnes Inspection Crane Desit T-340-01 and -W C
C C
I C
C 2-Il5 Turbine Building Bridge Cranes 1.
Generator rotor ITT C
C C
(% each crane) 2.
Exciter housing 8.5T C
C C
t
.3.
Exciter 40T C
C 1
C i
4.
LP turbine 22T C
C C
crossover tee 1
5.
LP rotor 100T C
C 1
i 6.
C I
i f
7.
HP outer cover 85T C
C I
a 8.
F.W. pump turbine gT C
C C
cover 9.
F.W. pump turbine 1.9T C
C C
rotor
- 10. LP turbine outer 70T C
C C
cover II. LP turbine 28T C
C I
g cylinder cover he. I
- 12. LP turbine 57.5T C
C C
cylinder cover m.2 1
- 13. Turbine bearlag 2T C
C I
C covers (man) f
- 14. Turbine blade 4.25T C
C i
C l
rings
- 15. Mobile crane 20T C
C C
l
TABLE 3.1 (Continued)
Weight Goldeline 1 Guideline 2 Guideline 3 Guideline 4 Guideline 5 Guideline 6 Guideline 7i or Crane SpecIal Crane-Test Egulpment Capacity Safe Load Operator Lifting and Destration Heavy Loads (tons)
Paths Procedures Training Devices Sitnes Inspection Crane Design
- 16. Condensate pump 5.5T C
C C
notor
- 17. Main ho}st load 3T C
block 3 T-119-13 C
C C
C C
Mol:ture Separator R
ater leo. 2-2 A (20 lbnorall)
J High pressure tube 14.5T C
C C
C C
bundle Low pressure tube g.85T C
C C
C C
bundle C = Applicant action' compiles with HIREG-OE12 Guideline.
Inc = Appilcant action does not comply with IItREG-GE12 Guideline.
R
= Applicant has proposed revisions / modifications designed to comply with IRREG-lM12 Guideline.
I = lasufficient information provided by the Applicant.
1 1
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REFERENCES 1.
NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, NRC.
2.
V. Stello, Jr. (NRC), Letter to all applicants.
Subject:
Request for Additional Information on Control of Heavy Loads Near Spent Fuel, NRC, 17 May 1978.
3.
Subject:
NRC Request for Additional Information on Control of Heavy Loads Near Spent Fuel, NRC, 22 December 1980.
4.
J. O. Schuyler (PG&E), Letter to F. J. Miraglia, Jr. (NRC).
Subject:
Control of Heavy Loads Diablo Canyon Unit 2, PG&E, 29 July 1983.
5.
ANSI B30.2-1976, " Overhead and Gantry Cranes."
6.
ANSI N14.6-1978, " Standard for Lif ting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or more for Nuclear Materials."
7.
ANSI B30.9-1971, " Slings."
8.
CMAA-70, " Specifications for Electric Overhead Traveling Cranes."
(
20
] '*
ENCLOSURE SYNOPSIS OF ISSUES ASSOCIATED WITH NUREG 0612 The following informadon is provided to identify exceptions or interpretations related to verbatim comp!!ance with NUREG 0612 Guide!Ines that have occurred during the course of this review. For each of the major Guidelines specific exceptions tre identified, a discussion concerning the underlying objective of that Guideline is provided, and approaches felt to be consistent and inconsistent with that guideline cre identified. While each such exception has been handled on a case by case basis, tnd has been considered in light of overall compliance with NUREG 0612 at a particular plant, the toples are of a nature general enough to be of interest to other plants.
6 4
1
GUIDELINE I SAFE LOAD PATHS Exc ptPn 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 loads are carried Indicates that for a number of lifts there is no preferred load path.
_ Discussion The purpose of this portion of Guideline ! is to ensure that the paths over which heavy loads are carried have been developed and approved in advance ci 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 sltuation
, 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, alth> ugh in excess of the welght specified for classification as a heavy load, are actually miscellan-eous or maintenance related loads for which it is impractical to identify a specific 1:ydown area which can be fixed from outage to outage. Conversely there are a number cf loads for which specific laydown areas have been allocated in the original plant d2 sign 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, genera!!y 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 i
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 avolded, a second line of defense can then be provided by Intervening barriers such as floors or the provision of additional lif ting device redundancy or safety factors. Considering the foregoing, the use of oxclusion areas, rather than safe load paths,is consistent with this g0ldeline only under circumstances where there is no safety related equipment located beneath the crea 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 squipment 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 electrica!
systems provided to support decay heat removal.
Approaches Consistent With This Guideline Specific safe load paths are prepared and approved for major components for which hazardous areas are well established. For miscellaneous lifts load corridors are estab!!shed 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 fer which hazardous areas are well established. For miscellaneous lif ts detailed direct-i lens are prepared and a? proved for developing safe load paths which include floor i
plans showing the locat;on 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 i
cnd may change from outage to outage.
2
Appreach s Inconsistent With this Guide!Jne.
Use cf limited exclusion trsas in c:ntcInmsnt which m:rsly prehlbitId the carrying cf henvy loads dir:ctly cv:r the cora or specific components and allow l
full load handling party discretion in other areas.
Exception 2 In the opinion of the licensee marking of load paths on the floor is impractical. This may be caused by the general use of temporary floor coverings which would cover the load path markings, or, due to the number of loads involved, l
o requirement for multiple markings which could confuse the crane operator.
t i
i i
Discussion The purpose of this feature of Guideline 1 is to provide visual aids to assist the operator and supervisor in ensuring that designated safe load paths ane 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 j
steps or drawings while controlling the crane). This feature should also be seen as j
a provision necessary to complete a plan for the implementation of safe load paths.
j 5peelfically it provides some additional assurance that, having spent the time and effort to develop safe load paths, those paths will be followed.
Approaches Consistent With this Guideline i
Rather than mark load paths a second member of the load handling i
party (that is, other than the crane operator)is made responsible for assuring that the des!gnated safe load path is followed. This second person, a signalman is typically j
en4 on cab operated cranes, checks out the safe load path prior to the lif t to ensure that it is clear, refers to the safe load path guldance during the lif t and provides direct-len to the operator and that the load path is followed. To support this approach the deles and responsibi!!!!es of each member of the load handling party should be clearly j
defined.
Prior to a llf t the appropriate load path is temporarily marked (rope, pylons, etc.) to provide a visual reference for the crane operator. In cases where i
the load path cannot be marked (e.g., transfer of the upper internals in a PWR) temporary l
or permanent match marks can be employed to assist in positioning the bridge and/or trolley during the lif t.
i In either case reasonable engineering judgement would Indicate 1
l that In certain specific lif ts marking of safe load paths is unnecessary due to physical i
ccnstraints on the load handling operation (e.g., simple holsts, monoralls, or very short lif ts where movement is limited to one coordinate axis in addition to the vertical).
Approaches Inconsistent With this Guideline I
Positions which in effect do not recognize the need for realistically j
providing visual aids to the crane operator and imply that, for a!! !!f ts, the operator wl!] remember the load path from review of procedures or by reference to a drawing.
Exception 3 l
Obtaining written alternative procedures approved by the plant safety review committee for any deviations from a safe load path is considered too l
cumbersome to accommodate the hand!!ng of maintenance loads where laydown areas i
may have to change or load paths altered as a result of unanticipated maintenance l
requirements.
l
i. '-
The purpose of this portion cf this guideline is to ensura that devintions frem cstchlished safa land paths r:c2iv2 o 12v;l cf ravi2w cpprcprinta to their safsty significence. In gen;rd it is highly desirsb!2 that once safa 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 plant safety are the responsibility of an Individual licensee plant safety review committee (or equivalent) and the details of their excercizing this responsibility should be within their jurisdiction.
Approach Consistent With this Guideline A plant safety review committee (or equivalent) delegates the respon-sibility for approving temporary changes to safe load paths to a person, who may or may not be a member of that committee, with appropriate training and education in the area of plant safety. Such changes are reviewed by the safety review committee in the normal course of events. Any permanent alteration to a safe load path is approved by the plant safety review committee.
Approach inconsistent With this Guideline Activities which in effect allow decisions as to deviations from i
safe load paths to be made by persons not specifically designated by the plant safety j
review committee.
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' ' GUIDELINE 2 LOAD HANDLING PROCEDURES
~*
Na significant excaptions to this guideline have been encountered.
Occeslonally o quistion trises concerning the need for Individual procedures for eac1 lif t. In general, it was not the purpose of this guideline to require separate procedut es for each lift. A reasonable approach is to provide separate procedures for each major lif t (e.g., RV head, core internals, fuel cask) and use a general procedure for handling other heavy loads as long as load specific details (e.g., load paths, equipment requirenents) are provided in an attachments or enclosures.
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[ ^ ' CUlbELINE 3 CRANE OPERATOR TRAINING Exceotien 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 AN51 B30.2-3.1.7.o for testing of all controls before beginning a new shif t. In some cases a licensee has qualified a commitment in this area by noting that only crane controls "necessary for crane operation" will be tested at the start of a shif t.
Discussion This requirement (ie. not a recommendation) of ANSI B30.2 is important since crane control system failures are relatively significant contributors to load handling incidents. The only reason that can be seen for an exception in this area is a general aversion to the word "all". Specifically, it appears that some licensees fear that a commitment to this requirement will force them to test all control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those features generally known as controls (ie. holst, bridge, and trolley motion controllers).
Approaches Consistent With this Guideline Exceptions that cJearly indicate that all normal controls (holst, j
i 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.
I Approaches Inconsistent With This Guideline A response that implies that a decision to test or not test a normal control will be made by the crane operator on the basis of what type of lif t or direction of motion he expects for the forthcoming shift.
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GUIDELINE 4 SPECIAL LIFTING DEVICES
[
Exception 1 Some licensees have Indicated that their speciallifting devices wara 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 o reference to the title of that standard to reach a conclusion that the standard is n:t cpplicable, i
Discussion TE purpose of this section is to ensure that special lifting devices I
w;ra designed and constructed under controlled conditions and thet sufficient document-f ction is available to establish existing design stress margins and support future mainten-anca and repair requirements. ANSI N14.6 is an existing standard that provides require-m:nts supporting this goal for lif ting device applications where the consequence of a iciture could be similar to that which could be expected in the event of the failure of a special lifting device carrying a load within the jurisdiction of NUREG 0612.
Consequently it seems appropriate that for special lifting devices subject to NUREG 0612 it should be able to be demonstrated that, from a design standpoint, they are as rcliable as a device for which ANSI N14.6 was developed.
Approaches Consistent With This Guldeline Although not originally specified to be designedin accordance with ANSI N14.6 the special lif ting device in question was provided by a reactor vendor, in cccordance with appropriate quality assurance and quality control procedures, for a speciSc app!! cation associated with power plant components provided by that vendor.
Based on either the review of the original stress report or,if such a stress report is unavailable, the preparation of a new stress report, the licensee has determined that margins to material yield and ultimate strength are comparable to those specified in ANSI N14.6. Although not required of the lif ting device vendor, the licensee has r;vi;wed the design of the lifting device and prepared a list of critical components whose repair or replacement should be performed under controlled conditions.
Approaches Inconsistent With This Guldeline No information is available concerning the original design but it is prcbably 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 net ccrry shipping containers of nuclear material welghing more than 10,000 pounds, cnd thus need not comply with ANSI N14.6.
1Property "ANSI code" (as page type) with input value "ANSI N14.6.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Exception 2 No 150% overload test has been performed and, in the opinion of the licensee, such a test is impractical.
Discussion The performance of a load test in excess of the load subject to NUREG 0612 is an important contributor to the ability to asses; the overall reliability cf o device. Such a test supplements design reliability by demonstrating that the c2vico was properly fabricated or assembled and that a portion of the design safety margin has been demonstrated. Such proof of workmanship is particularly important for a fairly complicated device. It is recognized, however, that the specification cf a 150% overload test is somewhat arbitrary and that,in some cases, the nature ci th2 device is such that the likllhood of workmanship shortcomings is remote.
7
,e<
u Aporr'ches Consistent Uith This Guideline The lic:nsee has tvaluated the lif ting device in question and has det:rmined that design strcss margins ara substantial. Further it has been established that the device itself is uncomplicated and principally put together with mechanical joints such that an assembly error is highly unlikely. The use of welded joints is severly limited and where employed were performed in accordance with substantial quality comrols (eg AWS DI.1) including NDE. The device has been tested to 100% of rated load.
Although a 150% overload test has not been performed the lifting devjce has been subjected to a manufacturer recommended overload to demonstrate proof of workmanship (typically 120-125 %).
Approaches Inconsistent With This Culdeline See this topic for Exception 1 above.
Exception 3 The requirement of ANSI N14.6 for an annual 130% load test or full NDE is excessive. Both the load test (due to the inability to make the test lift within containment) and the NDE (due to the need to remove protective coatings) are impractical and not justified by the infrequent use of these devices.
_ Discussion A continuing inspe: tion program to assure the continued maintenance of safety margins incorporated in the o+1ginal design of the device is important to ce~.2 5: rate the reliability of specia: 1:f ting devices. It is recognized, however, that some devices employed in a nuclear powe plant, particularly those associated with refue!bg, are used under conditions of centrol and at frequencies of use that are substant-la. 'y less severe than that possible for the type of lifting device for which ANSI N14.6 was originally prepared. Consequent:y a reasonable relaxation of the inspection Interval seems appropriate.
Approaches Consistent With This Guideline Overload tests will be conducted but at a longer interval,5 years, between tests to be consistent with the number of operationallif ts required.
i NDE of load bearing welds will be conducted at 5 year intervals or, alternatively, load bearing welds will be examined through a program that ensures that all welds will be examined over a normalinservice inspe: tion interval of 10 years
- in a manner similar to that specified in the B&PV Code for Class 2 Component Supports.
Approach Inconsistent With This Guideline Continuing inspection will be limited to an annual visual examination ci the device.
6 9
L 8
GUIDELINE 5 LIFTING ' DEVICES NOT SPECIAl.LY DESIGNED g
Exception Licensees hav] taken cxception t] the requirement t3 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 loaoing.
Discussion The intent of this portion of this Galdeline, which also applies to special lif ting devices under Guideline 4, is to reserve the ANSI B30.9 safety facters for accomodating sling wear and unanticipated overloads and avoid a reductien of this safety factor as a result of the routine dynamic loads inherent in hook / load accel-cration and deceleration. While it is acknowledged that, for operating characteristics typical of cranes employed at nuclear power plants, these dynamic loads are unlike'y to be substantial, such a determination cannot be made generically. TypicaUy the actual dynamic load due to hook / load acceleration or deceleration is a function of design hoek speeds and the type of hoist control system employed. It should also be recalled that ANSI B30.9 is a generalindustrial standard which applies to allload handling devices and does not in itself provide for any additional conservatism in consid-cration 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 dymamic loading is indeed significant accomodate it in their procedures for sling selection.
Moroach Consistent With This Guideline The hcensee has evaluated the potential routine dynamic loading for lif ti 1; devices not specially designed and found them to be a relatively small f raction (typi:a"y 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 esse having verified that routine dynamic loading of a specific hoist is indeed small the licensee has drawn the conclusion that revised selection criteria to accomodate such minor additional loads will not have a substantial effect on overall load handing reliability.
Approach Irconsistent With This Guideline Statement to the effect that dynamic Icads am accomodated in the tables of ANSI B33.9 with no indication that the licensee has a:sessed the actual dynamic loading imposed on cranes subject to NUREG 0612.
i 9
i
s,.,U GUIDE!.INE 6 CRANE INSPECTION TESTING AND MAINTENANCE, Exception The on!y 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 B30.2-1.1.7.a.2 and 3.2.4 for testing of hoist limit devices before beginning a new shift. In some cases a licensee has qualified a commitment In this area bf noting that this limit switch will be tested only if operations in the vicinity of the limit swltch are anticipated.
Discussion WElle this issue is treated somewhat ambigously in ANSI B30.2 (it is a recommendation in article 1.1.2 and a requirement in article 3.2.0 It is important since two-blocking incidents are relatively significant contributors to load harAling incidents. Further it should be noted that this test has been incorporated as a require-ment of OSHA in 29 CFR 1910.179.(n).(4).(i). It is recogn! zed, however, that there may be circumstances where su:h a test is not prudent. First, such a test clearly
.should not be made with the book under load. Consequently if a shift change is made with the hook loaded (this, by the way,is not a desireable practice and could be prec ud-ed through strict comp!Iance with ANSI B30.2-3.7.3.j) a hoist limit switch test should not be performed. Second, there may be circumstances where the nature of forthcoming load handling operations Ir41 cates that the time (and minor risk) associated with this test is not jur tified. In prticular if it is known that a holst will not be used or used only in an area substantaally removed from the upper travel limit, it would seem reason-able to defer the limit switch test until the start of the next shif t. If such an approach is taken, bewever,it should be approached with care. Requirements for deferring co upper limit switch test should acccmodate the uncertainty associated with maintenance p!ans and establish unambiguous criteria concerning what operations can be determined te be red.ote from upper travel limits. Such criter a should recognize that the need for upper trtvel14mit switch protectior, may be preceeded by a control system fal!ure and consequently should conservatively allow for operater response time and potential delays associated with emergency shutdown of the crar.e.
Approach Consistent W.th This Guldeline General compliaice with this regulaement. Certa!n specific provisions 4
made for def erring upper limit switch testing under conditions that are not subject to operater interpretation.
Aoproaches inennsistent Vith This Guldeline
~ An approach that J.iijilles that a decision to test or not is left to the discretinn of the operator or imp!!es that such a test will be recuired only !! operat-lons at1 planned in close proximity to the hook upper travel limit.
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V. CUIDE!.INE 7 CRANE DESIGN
. o Exception Occasionally a licensee has Indicated that the overhead electric travelling cranes employed at a site were parchased prior to the publication of CMAA-70 or ANSI S,30.2-1976 and thus these standards should not be applied.
Discussion Tne 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 mechan! cal, electrical, and structural reliability. It is also recognized, however, that cranes in operatlng plants may have been designed and procured prior to the publication of current standards and, thus, not strictly comply witn some detalls of these standards.
In general, though, current standards have evolved from predecesor stkndards in existence at the time of crane procurement (EOCI 61, ANSI B3t2-1967) and, since the later standards are not revolutionary, it is likely that cranes at nuclear power plants will provide a degree of reliability equ! valent to that provided by the current standards.
Such a general determination canos be made, however, by the staff since nuclear power plant cranes are usual'y unig e a:wf provIdod with s!te specific design features.
It is up to the licensee then to make a systematic comparison of their crgne design with the requirements of current standards and determine if additional design features are appropriate.
Approach Consistent Tith This Guideline The licensee has compared original crane procurement speelfications cr existing crane des!gns with the requirements of the referenced standards in areas offectir g lost handli: g reliability, in instances where the current standard provides c.titional protection against the consequences of operater error or component failure the licensee has proposed modifications which will result in a degree of load handling rellability similar to that provided in the current standard.
t
-_Approa6 Inconsistent With This Guideline Poshhns to the effect that the cranes satisfied standards in existence et the time of procurement and what was good enough then is good enough now.
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ENCLOSURE 2 Cooper North Anna 1 & 2 Crystal River 3 oRancho Seco D. C. Cook 1 & 2 e Surry 1 & 2 o Dresden 2 3 3 Trojan o Tt. Calhoun Turkey Point 3 & 4 Haddam Neck Vernent Yankee Maine Yankee McGuire 1 & 2 e Monticello Pion 1 & 2 a Palisades
,$uane Arnold I
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