ML20268C235
| ML20268C235 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/24/2020 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Gaston R Entergy Nuclear Operations |
| Guzman R | |
| Shared Package | |
| ML20268C237 | List: |
| References | |
| EPID L-2020-LLA-0051 | |
| Download: ML20268C235 (4) | |
Text
{{#Wiki_filter:From: To: Cc:
Subject:
Date: Attachments: Guzman, Richard Gaston, Ronald William Mirzai, Mahvash; Schrage, John; Danna, James Indian Point Unit No. 3 - REQUEST FOR ADDITIONAL INFORMATION: LAR to Revise Licensing Basis for New Auxiliary Lifting Device [EPID L-2020-LLA-0051] Thursday, September 24, 2020 4:12:47 PM RAIs - IP3 HI-LIFT LAR (Plant Systems) NONREDACTED 9.24.20.pdf Mr. Gaston, On September 3, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff sent Entergy Nuclear Operations, Inc. (Entergy, the licensee) the subject Request for Additional Information (RAI) as DRAFT in an e-mail.The RAI pertains to the licensees March 24, 2020, license amendment request (ADAMS Accession No. ML20084U773) for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed license amendment would incorporate, into the IP3 Licensing Basis, the installation and use of a new single failure proof auxiliary lifting device (i.e., the Holtec International HI-LIFT) to handle a dry cask storage transfer cask in the IP3 Fuel Storage Building. On September 17, 2020, the NRC staff conducted a conference call with the licensee staff to clarify the request. Following the discussion, your staff indicated that Entergy will provide a response to this RAI within 45 days from the issuance of the RAI; accordingly, the NRC staff expects Entergys formal response by November 9, 2020. In the e-mail transmitting the draft RAI questions, the NRC staff also requested Entergys verification that the content of the draft questions was appropriate for public disclosure based on the March 6, 2020, affidavit withholding request from Holtec, the owner of the applicable information. On September 21, 2020, your staff provided a mark-up of the portions of the RAIs identified as proprietary information. The NRC staff has updated the RAI to provide a redacted and non-redacted version as it was determined to contain proprietary information pursuant to 10 CFR Section 2.390, Public inspections, exemptions, requests for withholding. The proprietary version of the RAI is provided as an attachment to the e-mail communication with proprietary information identified by text within double brackets. The non-proprietary version of the RAI is shown below with redacted information identified by blank space within double brackets. A publicly available version of this e-mail with the redacted RAI will be placed in the NRCs official recordkeeping system (ADAMS). Please contact me should you have any questions in regard to this request. Richard V. Guzman Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov
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REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE PLANT SYSTEMS REVIEW (SCPB) OF THE PROPOSED LICENSE AMENDMENT REQUEST TO REVISE THE LICENSING BASIS FOR INSTALLATION AND USE OF A NEW AUXILIARY LIFTING DEVICE INDIAN POINT NUCLEAR GENERATING STATION, UNIT NO. 3 DOCKET NO. 50-286 EPID L-2020-LLA-0051
Background
By letter dated March 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20084U773), Entergy Nuclear Operations, Inc., (Entergy, the licensee) submitted a license amendment request (LAR) for to revise the Indian Point Nuclear Generating Unit No. 3 (IP3) licensing basis for spent fuel cask handling. Specifically, the licensee requested approval to incorporate into the IP3 Licensing Basis the installation and use of a new single failure proof auxiliary lifting device (i.e., the Holtec International (Holtec) HI-LIFT) to handle a dry cask storage (DCS) transfer cask (i.e., the HI-TRAC) in the IP3 Fuel Storage Building (FSB). The change to the IP3 licensing would be documented in a revision to the IP3 Updated Final Safety Analysis Report (UFSAR). The existing IP3 40-ton FSB Crane does not have the capacity to lift a fully loaded HI-TRAC (i.e., containing a multi-purpose canister (MPC-32) with 32 spent fuel bundles). Building constraints limited the potential options for increasing the load capability of the existing crane. Since 2012, the licensee has conducted DCS loading by moving spent fuel from the IP3 FSB to the Indian Point Nuclear Generating Unit No. 2 (IP2) FSB using a wet transfer method, which requires multiple transfers to transfer 32 spent fuel bundles. The proposed licensing basis change would permit the direct loading of the HI-TRAC without wet fuel transfer from
IP3 to IP2 through use of the HI-LIFT as a single-failure-proof lifting device meeting the intent of guidance in American Society of Mechanical Engineers (ASME) NOG-1 2004 edition (ASME NOG-1), "Rules for Construction of Overhead and Gantry Cranes," NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," and NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants. Entergy described the HI-LIFT as a lifting device comprised of a U-shaped frame, strand jack hoisting device, hydraulic positioning cylinders, torque arms and stabilizing arm.
Section 1.3, General Design Criteria, of the IP3 UFSAR states that the licensee conducted a study of the method of compliance with NRC regulations contained in 10 CFR Part 50, including the General Design Criteria (GDC) of Appendix A to 10 CFR Part 50, and that the results of the compliance study were updated to reflect changes made to the configuration since the study was completed. The study was conducted in accordance with the provisions of NRC Confirmatory Order of February 11, 1980, and were submitted to the NRC on August 11, 1980.
The Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete its review, as described in the request for additional information (RAI) shown below.
RAI-1 (SCPB-Plant Systems): Qualification of Components
Regulatory Basis:
In accordance with 10CFR Part50, Appendix A, GDC 1, Quality standards and records, specifies that structures, systems, and components (SSCs) important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. Where generally recognized codes and standards are used, they shall be identified and evaluated to determine their applicability. Section 10 of NUREG-0554, Single-Failure-Proof Cranes for Nuclear Power Plants, specifies quality measures addressing the design, fabrication, installation, testing, and operation be applied to crane handling systems for safe handling of critical loads.
Issue(s):
- a. The proposed insert for IP3 UFSAR Section 9.5.7 in Attachment 5 to the Enclosure to the LAR included the following:
The HI-LIFT is designed to meet the single-failure-proof criteria of NUREG-0554 [Single-Failure-Proof Cranes for Nuclear Power Plants, May 1979] and NUREG-0612 [Control of Heavy Loads at Nuclear Power Plants, July 1980] through compliance with ASME [American Society of Mechanical Engineers] NOG-1, 2004 [Rules for Construction for Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)].
Similar statements are included in other parts of the LAR, including Section 3.2, Heavy Loads Requirements, and Section 4.3, No Significant Hazards Consideration Analysis, of the Enclosure to the license amendment request. The words meet and compliance imply complete agreement with the referenced guidelines or standards. However, the proposed HI-LIFT is an entirely different technology from an overhead crane with a top-running trolley and multiple girders, and the amendment request included many exceptions or alternatives to criteria specified in the referenced guidelines and standards.
Request: Modify the amendment request to accurately reflect the degree to which the HI-LIFT assembly would conform to the referenced guidelines and standards considering the many specified exceptions and alternatives to the applicable criteria and given the differences in the design from an overhead crane with a top-running trolley and multiple girders. Describe at a high level how the intent of the referenced standards and NRC guidelines would be satisfied with respect to procedures, training, inspection, maintenance, testing for continued compliance, and design (i.e., quality assurance, structural reliability, capability to withstand a single component failure, and pre-operational testing scope), as supported by the detailed compliance matrices in to the amendment request.
- b. For Paragraph (( )) in Attachment 2 to the Enclosure to the LAR, the compliance evaluation included the following:
((
))
The above statement does not define whether the manufacturers quality assurance program conforms with NRC regulations or provide another basis for concluding strand jacks from the manufacturer provide reliability commensurate with the safety-significance of the proposed spent fuel cask handling operations, such as through commercial grade dedication, which may include analysis of operating experience with strand jacks made by the selected manufacturer (i.e., ASME NQA-1, Subpart 2-14, Method 4).
Request: Describe how the strand jack assembly would be qualified for the DCS lift application. Please address whether the strand jack manufacturer has a quality assurance program satisfying NRC regulations or commercial-grade dedication of the strand jack under the HOLTEC NQA-1 program will provide the qualification. If commercial grade dedication would be used, describe the critical characteristics of the strand jack and how each characteristic would be evaluated against the related acceptance criteria. Also address design conformance to an appropriate national consensus standard.
- c. The HI-LIFT utilizes hydraulic cylinders for positioning of the HI-LIFT frame and translation of the load. The NRC staff recognizes that ASME NOG-1 permits use of commercial hydraulic cylinders as part of the hoist system in paragraph 5540.
Request: Describe the hydraulic cylinder design conformance to an applicable national consensus standard.
- d. For Paragraph (( )) in Attachment 2 to the Enclosure to the LAR, the compliance evaluation included the following statement:
((
))
The NRC staff concluded that these valves perform an essential function to prevent uncontrolled movement of the cylinders in the event of a hydraulic line break.The LAR did not provide sufficient information on the qualification of these valves on the swing cylinders for the essential function of locking the hydraulic cylinders on loss of hydraulic pressure.
Request: Describe the qualification of the counterbalance valves on the swing cylinders.
RAI-2 (SCPB-Plant Systems): Strand Jack Support Configuration
Regulatory Basis:
10 CFR Part 50, Appendix A, GDC 4, Environmental and Dynamic Effects Design Bases, specifies appropriate protection for SSCs important to safety against dynamic effects, including the effects of missiles that may result from equipment failures. Section 4.2, Drum Support of NUREG-0554 states that Proper support of the rope drums is necessary to ensure that they would be prevented from falling.
Issue: The strand jack essentially functions as the rope drum and reeving system in a wire rope crane hoist. For Section (( )) in Attachment 2 to the Enclosure to the LAR, the compliance evaluation included the following:
((
))
Request: Provide a drawing of the strand jack mounting details and an explanation of how the strand jack mounting would be analyzed to ensure it would meet ASME NOG-1 stress criteria and NUREG-0554 criteria for restraint.
RAI-3 (SCPB-Plant Systems): Strand Jack Failure Modes and Effects
Regulatory Basis:
10 CFR Part 50, Appendix A, GDC 4, Environmental and Dynamic Effects Design Bases, specifies appropriate protection for SSCs important to safety against dynamic effects, including the effects of missiles that may result from equipment failures. Section 4.9, Hoist Braking System of NUREG-0554 states that Mechanical holding brakes in the hoisting system (raising and lowering) that are automatically activated when electric power is off or mechanically tripped by overspeed devices or overload devices in the hoisting system will help ensure that a critical load will be safely held or controlled in case of failure in the individual load-bearing parts of the hoisting machinery.
Issue: For Section (( )) in Attachment 2 to the Enclosure to the LAR, the compliance evaluation included the following:
((
))
Request: With consideration of single failures in the strand jack hydraulic system or its control system that could actuate the hydraulic wedge lock release, explain the basis for the statement that no more than one strand could be disengaged by a single mechanical or hydraulic failure. Also describe how that design feature to prevent disengagement of wedges is verified (e.g., design condition or test) and provide supporting diagrams or test descriptions for the relevant design features.
RAI-4 (SCPB-Plant Systems): Testing and Maintenance
Regulatory Basis:
In accordance with 10 CFR 50.34(b)(6)(iv), the final safety analysis report shall include a description of plans for conduct of normal operations, including maintenance, surveillance, and periodic testing of structures, systems, and components. Section 5.1.1, General of NUREG-0612, Item (6) states that The crane should be inspected, tested, and maintained in accordance with Chapter 2-2 of ANSI.B30.2-1976 [Overhead and Gantry Cranes].
Issue: For Section (( )) in Attachment 2 to the Enclosure to the license amendment request, the compliance evaluation included the following:
((
))
Request: Describe an inspection, testing, and maintenance program that encompasses the important components of the proposed HI-LIFT design and discuss consistency of the program with appropriate national consensus standards that include important HI-LIFT component types within the scope of the standard.
RAI-5 (SCPB-Plant Systems): Material Compatibility
Regulatory Basis:
In accordance with 10 CFR 50.34(b)(6)(iv), the final safety analysis report shall include a description of plans for conduct of normal operations, including maintenance, surveillance, and periodic testing of structures, systems, and components. Paragraph 1145(b), Chemical of NOG-1, states that, if a cranes load block and wire rope would be immersed in a pool, Requirements for the materials and lubricants of the load block and wire rope shall also be specified to insure compatibility with the pool chemistry.
Issue: For Paragraph (( )) in Attachment 2 to the Enclosure to the license amendment request, the compliance evaluation included the following:
((
))
Lubricants and chemicals, such as boric acid crystals, could adversely affect the grip of the strand jack wedge locks, in addition to potentially adversely affecting the materials of construction.
Request: Explain the configuration of the strand attachment to the load block and specify the materials to be used in the strands, the strand attachment to the load block, and the load block. Explain how environmental compatibility will be ensured during operation of the strand jack to prevent adverse effects.
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