ML20248E753
| ML20248E753 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/02/1998 |
| From: | Thomas K NRC (Affiliation Not Assigned) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| IEB-96-002, IEB-96-2, TAC-M95566, NUDOCS 9806030437 | |
| Download: ML20248E753 (11) | |
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nr UNITED STATES g
j NUCI. EAR REGULATORY COMMISSION j
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WASHINGTON, D.C. 20666-0001 o%,,,g /
June 2, 1998 l
Mr. Gany L Randolph Vice President and Chief Nuclear Officar Union Electric Company Post Office Box 620 4
Fulton, Missouri 65251
SUBJECT:
COMPLETION OF LICENSING ACTION FOR NRC BULLETIN 96-02,
" MOVEMENT OF HEAVY LOADS OVER SPENT FUEL, OVER FUEL IN THE REACTOR CORE, OR OVER SAFETY-RELATED EQUIPMENT"- CALLAWAY PLANT, UNIT 1 (TAC NO. M95566) l
Dear Mr. Randolph:
On April 11,1996, the U.S. Nuclear Regulatory Commission (NRC) issued NRC Bulletin (NRCB) 96-02," Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment," to all holders of operating licenses. The NRC issued NRCB 96-02 for three principal reasons:
1.
Alert addressees to the importance of complying with existing regulatory guidelines associated with the control and handling of heavy loads at nuclecr power plants,.
t 2.
Request that all addressees review their plans and capabilities for handling heavy loads in accordance with existing regulatory guidelines and within tnelr licensing basis as previcusly analyzed in the final safety analysis report, and 3.
Require addressees to report to the NRC whether and to what extent they have complied with the actions requested in this bulletin.
The bulletin also requested that Union Electric Company determine whether current activities were within the licensing basis and to submit a license amendment request as necessary.
l Union Electric Company responded to NRCB 96-02 for the Callaway Plant by letter dated l
May 10,1996. This letter provided both the information requested and the responses required l
by NRCB 96-02. NRC staff review of the responses to NRCB 96-02 finds that, overall, the
- responses are acceptable; therefore, TAC No. 95566 is closed. Enclosed is a summary of the staff's review of responses to NRCB 96-02.
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Mr. Garry L. Randolph
-2 June 2, 1998 The NRC will continue to review the issue of heavy loads through an ongoing Task Action Plan i
for heavy loads. Any additionalinformation required for the completion of the Task Action Plan will be obtained on a plant-specific basis.
If you have any questions regarding this matter, please contact me at (301) 415-1362.
Sincerely, Original Signed By l
Kristine M. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects tilliV Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosure:
Review Summary cc w/ encl: See next page DISTRIBUILQB:
Docket File P. Ray.
PUBLIC ACRS' PDIV-2 Reading File BThomas EGA1 WBateman KThomas i
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Document Name: CAL 95566.Itr l
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DATE 056G98 05/# /98 hl/98 OFFICIAL RECORD COPY l
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l Mr. Garry L.'Randolph June 2, 1998
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cc w/enet:
Professional Nuclear Mr. Otto L. Maynard Consulting, Inc.
President and Chief Executive Officer 19041 Raines Drive Wolf Creek Nuclear Operating Corporation Derwood, Maryland 20855 P.O. Box 411 Burlington, Kansas 66839 Gerald Chamoff, Esq.
Thomas A. Baxter, Esq.
Mr. Dan 1. Bolef, President Shaw, Pittman, Potts & Trowbridge Kay Drby, Representative 2300 N. Street, N.W.
Board of Directors Coalition Washingtoit, D.C. 20037 for the Environment 6267 Delmar Boulevard Mr. H. D. Bono.
University City, Missouri 63130 Supervising Engineer Quality Assurance Regulatory Suppori Mr. Lee Fritz Union Electric Company Presiding Commissioner.
Post Office Box 620 Callaway County Court House Fulton, Missouri 65251 10 East Fifth Street Fulton, Missouri 65151 U.S. Nuclear Regulatory Commission i
Resident inspector Office Mr. Alan C. Passwater, Manager
' 8201 NRC Road Licensing and Fuels Steedman, Missouri 65077-1302 Union Electric Company Post Office Box 66149 Mr. J. V. Laux, Manager St. Louis, Missouri 63166-6149 Quality Assurance Union Electric Company Post Office Box 620 Fulton, Missouri 65251 Manager-Electric Department Missouri Public Service Commission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission i
Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 1
Mr. Ronald A. Kucera, Deputy Director j
Department of Natural Resources P.O. Box 176 Jefferson City, Mis'ouri 65102 s
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SUMMARY
OF THE STAFF'S REVIEW OF LICENSEE RESPONSES l
TO NRC BULLETIN 96-02 Introduction The following summarizes the results of the staff's review of licensees' responses to NRC 1
Bulletin (NRCB) 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor l
Core, or Over Safety-Related Equipment," dated April 11,1996, and its associated Requests for l
Additional Information (RAI). The bulletin reminded licensees of their responsibilities for
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ensuring that heavy load-handling operctions cro performed safely, it also requested that l
licensees review their plans and capabilities for handling heavy loads, and ensure that their i
load-handling operations are in accordance with existing regulatory guidelines and the plant's licensing basis. Also requested was that licensees identify and present schedules for licensing
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actions needed to support implementation of their heavy load-handling operations involving j
spent fuel dry storage casks. The licensees also were to provide schedules for moving dry storage casks. The RAI requested that selected licensees evaluate the hazards associated I
with an in-plant tip-over of spent fuel dry storage casks that could dislodge the cask lid and spent fuel elements.
This summary closes the staff's review of licensee responses to both the bulletin and the l
associated RAl. Future issues regarding the handling of heavy loads will be addressed generically under the Heavy Loads and Crane issues Task Action Plan (TAP) and on a plant-specific basis as needed. Plant-specific reviews needed in the future may require the staff to obtain additional information from individual licensees.
Backoround l
NRCB 96-02 was iscued as an urgent generic communication that requested licensees' responses to the following:
j (1) For licensees planning to carry out activities involving the handling of heavy loads ever j
spent fuel, fuel in the reactor core, or safety-related equipment within the next 2 years from the date of the bulletin, provide the following: A report within 30 days of the date of the bulletin that addresses the licensee's review of its plans and capabilities to handle heavy loads while the reactor is at power (in all modes other than cold shutdown, refueling, and l
defueled)in accordance with existing regulatory guidelines. State whether the activities are within the licensing basis and, if necessary, submit a schedule for requesting a license amendment. Additionally, indicate whether changes to Technical Specifications (TSs) are required.
(2) For licensees planning to perform activities involving the handiing of heavy loads over spent fuel, over fuel in the reactor core, or over safety-related equipment v.tiite the reactor l
l is at power (in all modes other than cold shutdown, refueling, and defueled) that involve a potential load drop accident that was rot oroviously evalusted in the Final Safety Analysis i
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. i Repcrt (FSAR), submit a license amendment request 6-9 months in advance of the planned movement of the loads to give the staff sufficient time to perform an appropriate review.
(3) For licensees planning to move dry storage casks over spent fuel, over fuel in the reactor core, or over safety-related equipment while the reactor is at power (in all modes other than cold shutdown, refueling, and defueled) include, in item 2 above, a statement of the capability of performing the actions necessary for a safe plant shutdown in the presence of.
a radiological source term that may result from a breach of the dry storage cask, damage to the fuel, or damage to safety-related equipment due to a load drop inside the facility.
(4) For licensees planning to perform activities involving the handling of heavy loads over spent fuel,' over fuel in the reactor core, or over safety-related equipment while the reactor j
is at power (in all modes other than cold shutdown, refueling, and defueled), determine whether changes to the TSs will be required 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 6-9 months in advance of the planned movement of the loads for l
NRC review and approval.
Discussion The levels of detail in the licensees' responses to NRCB 96-02 varied significantly. Although some licensees presented detailed information about ineir heavy load-handling operations, some licensees (Catawba, Crystal River, Farley, Indian Point 2, Salem, St. Lucie, Summer, Dresden, Fitzpatrick, Hope Creek, LaSalle, Qucd Cities, and WNP-2), either omitted information pertinent to the staff's review in their submittal or referenced previous submittals associated I
with NUREG-0612 " Control of Heavy Loads at Nuclear Power Plants." However, all of the licensees responded to the bulletin.
In response to the bulletin, all the licensees reviewed their plans and capabilities to handle heavy loads and indicated that their plans and capabilities are adequate. Some discussions about licensees' plans and capabilities to move heavy loads addressed the plant mode of operation (et power or during shutdowns), the type of crane used (non-single-fai:ure-proof, single-failure-proof, or upgraded cranes), and the methods and procedures for implementing the guidelines in NUREG-0612, Phase I. All the licensees indicated that their load-handling operations are in accordance with the guidelines in NUREG-0612, Phase 1.
The bulletin requested that licensees determine whether their load-handling operations are within the licensing basis of the plant. Some licensees stated that their operatione are within the licensing basis; other licensees committed to evaluate their licensing basis. Some licensees identified issues to be addressed with the NRC through licensing actions (amendment requests or 10 CFR 50.59 evaluations), and projected schedules for submitting the actions for NRC review. Following the responses to the bulletin, a few licensing actions have been reviewed l
and approved by the NRC concoming the bulletin. The issues involve proposed changes to l
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. TSs, scope changes to accident analyses, changes in loads and load paths, and updates to UFSAR requirements.
The bulletin also asked licensees to determine if their movement of heavy loads involves potential load drop accidents that were not evaluated previously in the FSAR and, if needed, submit a license amendment request. Most licensees stated that they move only analyzed loads. Some licensees indicated that they performed load drop or consequence analyses or both though the guidance in Generic Letter (GL) 85-11 cancelied the need to perform any analyses.' Some licensees committed to evaluate the heavy loads identified previously when they responded to NUREG-0612. Despite the analyses performed, all the liceneses stated that they satisfy the recommended guidelines in Section 5.1.1 of NUREG-0612.
Licensees moving heavy loads at power and using load drops and consequence analyses indicated that they have adequate capabilities to safely shut down the plant if a heavy load drop occurs causing a release of radiation or damage to safety-related equipment.
The bulletin also requested that licensees identify plans and schedules for moving spent fuel dry storage casks. Some licensees stated that they planned to move casks in the near future; other licensees indicated that they had not yet considered onsite dry cask storage.
Based on requests in the bulletin, the staff reviewed the licensees' responses to identify:
(1) plant mode durir the handling of heavy loads (at power or during plant shutdowns);
(2) type of crane used to lift heavy loads; (3) evaluation of the licensing basis for handling heavy loads, including planned licensing actions associated with heavy loads (i.e., license amendment requests); (4) plans and schedules for moving heavy loads (particularly spent fuel dry storage I
and transportation casks); and (5) the type of analysis performed (load drop analysis or i
consequence analysis or both). Although the bulletin did not specifically request this j
information, the staff believes that this type of information covers the areas of concem about the licensees' heavy load-handling operations. On the basis of its review, the staff noted the following points.
(1) Plant Mode Durina Load-Handlino Ooerations
, Review of the responses to the bulletin revealed that approximately 38 percent of the plants (21 PWRs and 20 BWRs) plan to movs heavy loads at power. Some of these plants indicated that they move analyzed heavy loads at power and unanalyzed heavy loads during plant shutdowns. These plants also indicated that heavy load movements over safety-related equipment are minimized to the extent practicable, and their procedures do not allow movements of heavy loads over fuel or over the reactor core in accordance with NUREG-0612.. Some PWR licensees (i.e., Callaway, Shearon Harris, and Calvstt Cliffs) indicated that tneir heavy load movements involve casks moved within a l
separate fuel building. ~ As indicated by the licensees, the moveraent of casks in PWRs that l
have a separate fuel building involves little or no cask travel over systems needed for safe shutdown functions. As a result, a dropped cask would not cause sigr lficant damage to l
safe shuidown equipment and, therefore, would have negligible effect on the licensees' l
ability to shut down the plant safely..
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. Approximately 39 parcent of the plants (28 PWRs and 15 BWRs) indicated that they move heavy loads at plant shutdowns, and about 23 percent of the plants (23 PWRs and 2 BWRs) did not clearly indicate the plant status when heavy loads are rnoved. A few of these licensees (e.g., Oyster Creek) that plan to move heavy loads during plant shutdowns also indicated that they plan to perform dry runs at power, before initially loading the cask.
The staff finds that although some licensees have committed to move only analyzed loads at power, they may not adequately consider the adverse safety consequences of a load drop during the movement of heavy loads. Some licensees' analyses consider methods that may be used to preclude a load drop (e.g., enhanecmonts to the load handling system, including upgrades to brakes, instrumentation, and controls, and the use of energy-absorbing structures throughout the load path). However, they rnay not consider the adequacy of their capabilities needed to mitigate or manage the adverse consequences of a load drop. Some examples of s'uch capabilities are the abilities to shut down 1; e plant safely, continue normal operation, maintain personnel access to various areas in the plant, and mitigate potential accidents that could expose individuals to releases.
The staff is also concemed that some licensees may not adequately address the potential consequences of a load drop during practice runs of cask movements while the reactor is at power. A drop of an empty cask during practice movements could result in similar adverse consequences to the operation of the plant as does the actual movement of a fully loaded spent fuel cask. Therefore, it is the staff's view that activities involving actual heavy load movements or practice runs of moving spent fuel dry storage casks are to be evalualad by the licensee for potential accidents and consequences.
In addition, the staff is concemed with BWR licensees that move heavy loads while the reactor is at power because, in general, the safety-related systems required for safe shutdowns are susceptible to damage from a dropped heavy load. These licensees should exhaust all options of establishing cafe load patha to minimize the risk of affecting safe shutdown equipment in the event a heaq load is dropped.
(2) Tvoes of Cranes Used in the responses to the bulletin, approximately 27 percent of the plants (6 PWRs and 23 BWRs) indicated that they use single-failure-proof cranes to lift heavy loads; 14 percent of the plants (12 PWRs and 3 BWRs) indicated thai they have upgraded the reliability of their load-handling system in accordance with NUREG-0612, Section 5.1.6 (see explanation below); and about 8 percent of the plants (5 PWRs and 4 BWRs) indicated that their crane is non-single-failure-proof. However, almost half the plants (49 PWRs and 7 BWRs) did not clearly indicate the typc of crane they use.
NUREG-0612, Sectica 5.1.6, " Single Failure Handling System," provides the altemative of upgrading an existing crane in lieu of complying with certain recommendations of NUREG-0554,
- Single Failure Proof Cranes for Nuclear Power Plants " to achieve improved
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) reliability in load-handling systems. Accordingly, several licensees have upgraded their I
overhead load-handling crane to single-failure-proof status, or they have improved I
reliability by increasing the factors of safety, or by providing redundancy in certain active components of the cranes. A few licenseed(i.e., Oyster Creek, Dresden, Yankee Rowe) have indicated that they are considering upgrading their cranes or installing new cranes to i
l achieve single failum-proof capsbility.
1 Licensee inforrr.ation regarding the types of overhead cranes used at the plants indicates that many plants have either single-failure-proof cranes in accordance with NUREG-0554,
" Single-Failure-Proof Cranes for Nuclear Power Plunts," or cranes upgraded in accordance l
with guidelines in NUREG-0612 (Section 5.1.6, and Appendix C," Modification of Existing Cranes)." Although several plLnts were not clear about the type of crane they possess, l
none of the plants indicated that they have cranes and lifting systems that were inadequately designed, ;nstalled, and testod.
The staff concludes that many licensees prev.iously performed adequate evaluations of their crane decign for lifting heavy loads and the evaluations were accepted by the staff.
j However, the staff is concerned thet some facilities could have weaknesses in their load-i handling operations. These weaknesses may include insufficient training of personnel l
involved in the lifting and rigging procedures, procedures lacking in requirements for evaluating loads and ensuring that the design !!mitations of the hoisting system are not i
exceeded, insufficient inspection and preventive maintenance of cranes and !ifting devices, j
and inadequate review of load:ng capacities. The staff s view is that the potential exists for any of these weaknesses to result in a single failure involving heavy loads being dropped and causing adverse consequences. As a result, future staff reviews will be focused on licensees' evaluations of thel cranes and liftlag devices, and related methods and l
procedunas used for complying with the requirements of NUREG-0612.
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(3) Ey,1tluahon.cf Licensina Basis for Handlina Heavy Loads Review of the responses to the bulletin indicated that all of the licensees lyslieve that their heavy load-handling operations are in accordance with the licensing basis of the facility, j
Approximately 24 percent of the plants (10 BWRs and 16 PWRs) did not address the i
licensing basis in their responses. The staff is concemed that some plants that believe their bad-handlinD operation is within the p' nt's licensing basis may, in fact, be outside x
the licensing basis. For example, the staffs iaviews of Oyster Creek's (OC's) load-handhng operat;ons detennined that OC would have operated beyond i:s licensing basis.
This is because OC was planning to move loads that exceeded the size 0f the loads previously evaluated in the FSAR. Approximately 10 percent of the licensees indicated that they wi!! review and modify their licensing basis as neede1. As indicated in the l
submittals, licensees' reviews of the licensing basis resulted in one or more of the i
following:
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' identification and analysis of new heavy loes beyond the loads previously addressed
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in the licensing basis,
. commitments to only move heavy loads tnat were previously analyzed, determinations that heavy load-handling operations deviated from previous e
cotamitments and the licensing bases, and determinations that change the TSs are needed.
Licensees' reviews of their plans and capabilities to handle and control heavy loads have resulted in some licensoes undertaking licensing actions to implement their load-handling operations. The following are examples of planned licensing actions noted in the responses to NRCB 9642:
1 License.R EJAODed Licensina Actions Brunswick License amendment request to make the FSAR consistent with actual plant operations (completed).
Fitzpatrick Changes to the TSs to allow the movement of spent fuel dry storage casks at power (schedule TBD).
l Nine Mile Point Design change involving reracking of the spent fuel pool (schedule TBD).
North Anna Various license amendments regarding heavy load-handling issues (schedule TBD).
Oyster Creek TS changes to remove the weight restriction for lifting the dry storage canister (DSC) shield plugs over fuel in the DSC (completed).
Watts Bar Design change for reracking of the spent fuel pool (currently under review).
The staff's revie# of the information submitted indicates that some licensees'loed-handling operations may have been implemented inconsistently with the licensing basis of the facility. Some plants either have inadvertently deviated from their load-handling procedures, implemented procedures that are inconsistent with the licensing basis, or misinterpreted the design features of their load-handling system. The staff also believes that since the issuancs of NUREG 0612, many changes have evolved in licensees' plans to handle heavy leads, As a result, several licensees have identified changes in their load-handling operations that were not previously addreraed in their licensing basis. Ther sfore, on an "as needed" basis, the staff will continue to perform audits and inspections in order to evaluate licensees' movement of heavy loads.
7 (4) Plans for Movinq30ent Fuel Drv Storage Casks Approximately 17 percent of the plants (10 i'WRt and 9 BWRs) indicated that they plan to store spent fuel tiry storage casks. Most of these plants plan to move casks within 2 years frcm the date of the bulletin; The remainder of the licensees either did not address the issue or have not yet begun planning for the storage of spent fuel.
(5) LpadDtpo and Consequence Analysis Performed Approximately 33 percent of the plants indicated that they have perfont ed load drop and consequenz analyses in support of their planb to mcVe neavy loads. Tne remaining plar,ts did not show that any analysis exists. In the futLre, the staff will review the load drop and consequence analyses on an as-needed plant-specific basis The Eleff has found that s2veral licensees hcve done load drop and consequence analyses though Generic '.ettor 85-11 canceled Phase 11 of NUREG-0612, and dismissed the need for licensecs to perform these analyses. The results of the analyses have led some licensees to modify their load-handling operations, including upgrading the crane and Escociated componsnts of the lifting system, and modifying tha lo'ad paths.
GElualon Tne staff finds that NRC Bulletin 96-02 achloved its obbetWe of getting licensees to evaluate their load-nandling u,tivities to ensure that they are performed safely and in the best interest of -
protecting the health and safety of the public. The bulletin vias very effective in getting licensees to review their plans and capabilifea, licensing bases, and regulatory guidelines for carrying out activitice involving the movement of heavy loads. Although the licensees' rer;ponses to the bulletin contained varicus levels of detail regarding load handling operations at their plants, sufficient information was available to enable the staff to reach the conclusions noted below.
Although several licenses; have increased the reliability of their load-handling systems, the staff will continue to review loud hanGling opere4ons, on an as-needed bssis, to ensure that licensees adequately address their ability to preclude load drop accidents. As determbed through eadier NRC reviews, licensees have reliable lifting systems as reauired by NUREG-0612. However, licensees nesd to continue to address other activities surrounding tne crane operation that could belp to minimize weaknesses in their load-haud!!ng operations that may contribute to load drop accidents Such wesknesses could include ir. sufficient training of personnel involved in applying the lifting and rigging proceduren, procedures lacking in requirements for evaluating loads and for ensuring that the design limitations of the load-lifting system are not exceeded, insufficient inspection and prevenUvo maintenance of cranes and
. lifting devices, and inadequate twview of loading capacities.
Also, the staff finds that because some licensees plan to move heavy loads at power, they may rieed to assess their capabilities to both mitigate and manage the adverse consequences of a
8-heavy load drop. Ucensees should consider, among other things, possibie plant shutdowns during the movement of heavy loads, limiting personnel exposure from required entry into j
contaminated plant areas following an accident, and Im:evering from the adverse conditions I
caused by ca accident, Accordingly, the staff is prdicularly interested in future evaluations of 1
load drops and consequences associated with the loao-handling operations of the licensees.
The staff also finds that several licerisees have determined, after reviewing their licensing basis, j
that their load-handling operations may b:: inconsistent with their licensing basis. Consequently,-
several licensees have undertaken actions to correct or resolve this condition, including
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reviawing the FSAR, TS requiremerds, and procedures govamir'0 the condud of aperations
. !nvolving tha mover"ent of he:avy loada. The stan will pursue enforcement actions for matters involving a noncompliance with sagulatory requirernents as appropriate.
I On the basis of the preceding discussion, the sta+f will continue to review issues regardin(: the 1
handling of heavy loads on a plant specific basis as needed. Generic issues regarding ttA s'ablect will be addrers3d through an ongoing Task Action Plan (TAP) for Heavy Loads. Any additional infortration required for the completion of the TAP will be obtelned on a plant-specific basis.
Principal Contributor. Brian E. Thomas F
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