ML21354A866
| ML21354A866 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Howard, K, ACRS | |
| References | |
| NRC-1750 | |
| Download: ML21354A866 (59) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Regulatory Policies and Practices Docket Number: (n/a)
Location: teleconference Date: Tuesday, November 16, 2021 Work Order No.: NRC-1750 Pages 1-46 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W., Suite 200 Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE 8 + + + + +
9 TUESDAY 10 NOVEMBER 16, 2021 11 + + + + +
12 The Subcommittee met via Video 13 Teleconference, at 2:00 p.m. EST, Ron Ballinger, 14 Chairman, presiding.
15 COMMITTEE MEMBERS:
16 MATTHEW W. SUNSERI, Member 17 RONALD G. BALLINGER, Member 18 VICKI BIER, Member 19 CHARLES H. BROWN, JR. Member 20 VESNA B. DIMITRIJEVIC, Member 21 GREG HALNON, Member 22 JOSE MARCH-LEUBA, Member 23 DAVID PETTI, Member 24 JOY L. REMPE, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 ACRS CONSULTANT:
2 STEVE SCHULTZ 3
4 DESIGNATED FEDERAL OFFICIAL:
5 HOWARD KENT 6
7 ALSO PRESENT:
8 STANLEY GARDOCKI, RES 9 STEVEN JONES, NRR 10 SCOTT MOORE, Executive Director, ACRS 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 P R O C E E D I N G S 2 2:00 p.m.
3 CHAIR SUNSERI: Good afternoon everyone.
4 It is 2 p.m. Eastern Time. The meeting will now come 5 to order.
6 My name is Matthew Sunseri, and I am the 7 subcommittee chair for the Regulatory Policies and 8 Practices Subcommittee meeting for today.
9 I'll just call down the roll here from 10 what I see, and then check that we have a quorum.
11 But anyway, I see Ron Ballinger, Vicki 12 Bier, Dennis Bley, Vesna Dimitrijevic, Greg Halnon, 13 Jose March-Leuba, Dave Petti, Joy Rempe, myself, and 14 our consultant is with us today also, Steve Schultz.
15 Did I miss any members?
16 (No audible response.)
17 CHAIR SUNSERI: Okay. The purpose of this 18 is a information briefing today, is for the NRC staff 19 to brief the subcommittee on Draft Guide 1381, which 20 will be Reg Guide 1.244, titled Control of Heavy Loads 21 at Nuclear Facilities.
22 Mr. Kent Howard, of the ACRS staff is our 23 designated fellow officer for this meeting.
24 During today's meeting, the subcommittee 25 will gather information and analyze relevant issues NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 and facts, and familiar proposed positions and actions 2 as appropriate.
3 However, at this subcommittee's 4 discretion, any matter will be considered for 5 presentation at the full committee, if necessary and 6 if members see fit.
7 However, I will note that as I mentioned, 8 this is an information briefing, and I'm not really 9 anticipating writing a letter at this time based on 10 the review that I've done, and the information that 11 we've seen from the staff already. But anyway, we'll 12 see what the committee feels at the end.
13 The ACRS was established by statute as 14 governed by the Federal Advisory Committee Act. The 15 committee only speaks through its published letter 16 reports.
17 Because this is a subcommittee meeting, 18 persons should consider any remarks by ACRS members as 19 their personal comments, and not committee positions.
20 We hold subcommittee meetings to gather 21 information and perform preparatory work that will 22 report our deliberations at full committee meetings, 23 if necessary.
24 The rules for participation in all ACRS 25 meetings including today's, were announced previously NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 in the Federal Register notice and included on our 2 website.
3 The ACRS section of the U.S. NRC public 4 website provides our charter, bylaws, agendas, letter 5 reports, and transcripts of all full and subcommittee 6 meetings, including presented material.
7 As stated on the website, members of the 8 public who desire to provide a written or oral input 9 to the subcommittee may do so, and should contact the 10 designated federal officer five days prior to the 11 meeting, as practical.
12 Today's meeting is open to the public 13 attendance, and there will be time set aside during 14 the meeting for comments from members of the public 15 attending, or listening.
16 Due to the Covid pandemic, today's meeting 17 is being held over Microsoft Teams for ACRS and NRC 18 attendees. There is also a call-in number allowing 19 participants of the public to connect to the Teams 20 session.
21 A transcript of the meeting is being kept.
22 Therefore, we request that meeting participants not on 23 the agenda identify themselves when they are asked to 24 speak, and speak with sufficient clarity and volume so 25 they can readily be heard.
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6 1 At this time, I ask attendees to put their 2 devices on mute to minimize disruptions, and only 3 unmute when speaking.
4 So, before we get into the meat of today, 5 I'll just call on the members. Members, any questions 6 about the agenda for today, or any comments you want 7 to make before we get started?
8 (No audible response.)
9 CHAIR SUNSERI: All right, we will now 10 proceed with the meeting, and I call on Mr. Steve 11 Jones, Acting Branch Chief of Containment and Plant 12 Systems Branch, the Division of Reactor Regulation, to 13 make any introductory remarks.
14 Mr. Jones, go ahead. You have the floor.
15 MR. JONES: Thank you, Chairman.
16 Good afternoon, my name is Steven Jones, 17 I'm currently serving as Acting Chief of the 18 Containment Plant Systems Branch in the Division of 19 Safety Systems, Office of Nuclear Reactor Regulation.
20 I'm here to brief the subcommittee on the 21 Draft Final Regulatory Guide 1.244, addressing control 22 of heavy loads at nuclear facilities.
23 This guide was previously issued as DG-24 1381 for public comment from, approximately from May 25 through July.
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7 1 The Reg Guide is intended to provide 2 guidance for the design, operation, maintenance, 3 inspection, and testing of material handling equipment 4 used at nuclear facilities under circumstances where 5 handling errors could threaten the satisfactory 6 accomplishment of essential safety functions.
7 The agenda for this meeting includes 8 discussion of the change in the guidance as a result 9 of the Reg Guide, a brief discussion of safety 10 significance, a resolution of public comments 11 received, and a brief discussion of our, of the 12 staff's conclusions.
13 I'm happy to address questions at any 14 point in the presentation. And in addition, there are 15 several staff members available to address areas 16 linked to control of heavy loads, that may be outside 17 the scope of the, of this Reg Guide.
18 So, the intent of the issuance of Reg 19 Guide 1.244 was to adopt national consensus standards 20 where appropriate, to update guidance, and to expand 21 the scope to cover licensing under Parts 50, 52 and 72 22 of Title 10 of the Code of Federal Regulations.
23 Part 50 is the traditional licensing 24 approach for operating nuclear reactors, and certain 25 utilization facilities.
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8 1 Part 52 for the newer design reactors and 2 alternative licensing approach, and Part 72 covers the 3 licensing of independent spent fuel storage 4 installations.
5 These parts all include similar 6 requirements to provide appropriate protection from 7 the effects of equipment failures, and natural 8 phenomena, and thereby provide reasonable assurance 9 that essential safety functions would be accomplished.
10 These parts also include requirements to 11 describe normal operations, including maintenance and 12 testing of equipment important to safety.
13 First, I'll touch on the existing 14 guidelines.
15 Control of heavy load movement has been 16 part of the nuclear reactor licensing bases since the 17 1970s. And, through a generic letter issued in 1980, 18 the staff requested all licensees and applicants to 19 address conformance with the guidance in NUREG-0612.
20 NUREG-0612 invoked several secondary 21 standards governing design, operation, and maintenance 22 of heavy load handling equipment.
23 But only NUREG-0554, which was single 24 failure proof cranes for nuclear power plants, and 25 ANSI N14.6, which covered, or which addressed the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 1 design of special lifting devices for shipping 2 containers, applied to the design of important to 3 safety structure systems and components.
4 NUREG-0612 specifically provided 5 guidelines for safe handling of loads in areas where 6 the effects of a handling accident could threaten the 7 accomplishment of essential safety functions.
8 Particularly, this included areas around 9 the reactor vessel and spent fuel pool, where direct 10 damage to fuel, or damage that causes a loss of 11 cooling water from either the reactor vessel or spent 12 fuel pool, could result in a release of radioactive 13 material.
14 The NUREG-0612 guidelines also included 15 good industrial load handling practices as a defense 16 and def measure. Those included provisions from 17 typical industrial standards, such as ASME B30.2, 18 which covers the design and operation of overhead 19 crane -- and I'm sorry, and ASME B30.9 for slings.
20 For use of slings with heavy load handling equipment.
21 The NUREG-0554 guidelines provided 22 somewhat detailed guidance for the design of single 23 failure proof for what I'll term in this meeting, 24 enhanced reliability handling systems, for overhead 25 cranes that provide means to compensate for equipment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 1 failures, and withstand the effects of seismic events 2 while still being able to stop and hold the load.
3 The ANSI N14.6 standard provides design 4 testing and provisions for periodic demonstration of 5 continued compliance with those design measures for 6 permanent, special lifting devices that generally 7 provide a rigid connection between frequently handled 8 loads, and the crane load block.
9 Reg Guide 1.244 is proposed to endorse the 10 three ASME standards at ASME NML-1, Rules for the 11 Movement of Loads Using Overhead Handling Equipment in 12 Nuclear Facilities, provides the overall general 13 guidance for a heavy load handling program.
14 An appendix to NML-1 provides a comparison 15 of the guidelines in that standard with NUREG-0612.
16 It also uses a risk informed approach 17 considering qualitative risk insights related to the 18 type of lift, and the surroundings.
19 Its scope is somewhat broader than NUREG-20 0612. It covers for instance, operations in the yard 21 of nuclear power plants, or operations related to 22 interim, I'm sorry, to independent spent fuel storage 23 installations.
24 And, it has also been updated to reflect 25 operating experience insights that have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 accumulated since, since the 1980s related to control 2 of heavy loads, especially with respect to below the 3 hook activities, such as problems with the sling usage 4 and basket, or choker configurations, and which is 5 described in ASME B30.9.
6 And, it also relaxes requirements related 7 to special lifting devices, which have demonstrated 8 very good performance over the last 40 years as part 9 of an overall handling system for repeated handling of 10 very large loads, such as reactor vessel heads, vessel 11 internals, or independent spent fuel storage 12 installation transfer casks, and loaded fuel 13 canisters.
14 MEMBER BROWN: Can I ask a question?
15 MR. JONES: Sure.
16 MEMBER BROWN: This is Charlie Brown.
17 MR. JONES: Uh huh.
18 MEMBER BROWN: I guess I'd like to have you 19 explain a little bit, what do we mean by a qualitative 20 risk inform approach for lifting stuff?
21 I thought cranes, their cables, the 22 slings, all had load requirements and testing 23 requirements you know, to at least make sure their 24 strength and characteristics exceeded those needed for 25 any particular load.
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12 1 How do you make that qualitative?
2 MR. JONES: You're correct, that the 3 standard provides for specific requirements for the 4 handling system, the crane, and also any slings or 5 special lifting devices associated with that. And, as 6 well as the load lifting attachments.
7 However, the standard provides for, excuse 8 me, a graded assessment of the risk associated with 9 the, excuse me, with the load movement. Specifically, 10 there are the first element of any lift approach is to 11 classify the lift per NML-1.
12 And, that involves assessing the antenna'd 13 rigging applications, as well as what's surrounding 14 the lift path, and identifying any, any important to 15 safety structures or components.
16 This Reg Guide is intended to apply 17 predominantly to what's classified as nuclear safety 18 critical lifts. And, that's where the damage from a 19 postulated handling system failure could result in the 20 loss of a safety function.
21 In other words, for example, direct 22 mechanical damage to the fuel, which would, could 23 cause a release of gasseous fission products within 24 the fuel. Or, as I mentioned earlier, loss of water 25 from the spent fuel pool, or the reactor vessel.
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13 1 A change in configuration of the fuel that 2 could affect criticality. Or, away from the vessel or 3 the spent fuel pool, damage to redundant trains of 4 safety related equipment that perform the same 5 function.
6 For example, if cooling water, service 7 water, provides essential cooling via two pipelines 8 that are independent but they happen to be close 9 enough together that a single load drop can, could 10 damage or interrupt flow in both, then that would be 11 one of the areas subject to classification as that 12 nuclear safety critical lift.
13 Other circumstances would be considered 14 less risky and may be subject, for example, under the 15 maintenance rule or seismic two-over-one criteria, 16 that are also somewhat discussed in NML-1, but really 17 kind of outside the scope of the NRC's regulation of 18 heavy loads as a consideration in the safety analysis 19 specifically. That's more risk management and 20 maintenance associated.
21 Does that address your question?
22 MEMBER BROWN: Well, the initial, the items 23 you listed initially sounded like pretty specific 24 requirements. There was nothing evaluative about it.
25 They either had to be clear, you know, you put a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 1 checkmark by it or you don't.
2 MR. JONES: Well, I mean, I guess I wasn't 3 complete. There's several, I mean you can use lesser 4 quality cranes, or even a mobile crane, depending on 5 your assessment of the risk, and what you're around, 6 what is involved.
7 For example, a removal of an out-of-8 service component where, and in the yard, where you 9 know, even if the mobile crane toppled and were to 10 strike other things, there would be no challenge to 11 any safety function. Then that would have essentially 12 the lowest grade of control under NML-1 provisions.
13 That's considered a normal lift.
14 Then there's a classification as a special 15 lift where the, this would be more likely to involve 16 movement of one train, effecting one train of a safety 17 system, where the maintenance rule requirements may be 18 coming into play.
19 And, a third category is critical lift.
20 And, this could involve, I mean the standard is 21 actually intended to encompass things beyond nuclear 22 power plants, including aerospace activities where 23 very high value components might be handled by the 24 crane, and might be deemed critical lifts.
25 But a subset of that is nuclear safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 1 critical lifts, which meet the criteria described 2 earlier.
3 So, and that's the sense that there's a 4 qualitative risk informed approach within the standard 5 And, so the types of handling systems, the 6 qualification of the rigging components, and the 7 degree of extra measures provided to protect those 8 components from the effects of any load drop, all vary 9 based on that load classification.
10 MEMBER BIER: If I can chime in for a 11 minute, this is Vicki Bier.
12 I want to see if I'm understanding 13 correctly, and if so, maybe it will help answer 14 Charlie's question as well.
15 Charlie's comment was that the slings and 16 cranes, and whatever else, have very concrete 17 numerical criteria for strength, et cetera.
18 MR. JONES: Right.
19 MEMBER BIER: And, as I read it, the 20 qualitative risk informed approach applies to what's 21 under the cranes, not to the cranes.
22 And, my read of the word qualitative is 23 kind of you don't need to do a PRA to decide how 24 important this stuff is that's under the crane.
25 Is that a fair kind of shorthand summary?
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16 1 MR. JONES: Yes, but I'd like to qualify 2 that with there are differences in actually the types 3 of cranes that can be used under various 4 circumstances. And, also the degree of qualification.
5 Even if you use an overhead crane that, 6 you know, is similar to what might be considered you 7 know, single failure proof or enhanced reliability, or 8 enhanced safety crane.
9 NOG-1 actually has three types of cranes.
10 A type-3 is a standard industrial overhead crane.
11 Type-2 is seismically qualified to remain in place, 12 but not, not under load. So, addresses seismic two-13 over-one concerns, for example.
14 And, then the type-1 crane is, has 15 redundant features, such that if certain components 16 were to fail, or not operate as designed, the crane 17 would still be able to hold the load and prevent it 18 from dropping. Or cause damage to either the load 19 itself, or external components.
20 So, is that a little more clear?
21 And, then under the hook, you're correct.
22 There's differences.
23 ASME B30.9 has you know, a single standard 24 for a certain lift. But if you're employing it with 25 a nuclear safety critical load, then the guidelines NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 1 call for either having redundant load paths of 2 equivalent capability, or a single load path with 3 twice the design factors that would be applied to a 4 normal handling evolution.
5 MEMBER BROWN: What --
6 (Simultaneous speaking.)
7 MR. JONES: Can the --
8 MEMBER BROWN: Go ahead, I'm sorry.
9 MR. JONES: The same applies to special 10 lifting devices as well.
11 MEMBER BROWN: They still sound pretty 12 specific, quantifiables. I understand you used it for 13 a different type of crane, but you said of one of 14 lesser qualification. That one I don't quite 15 understand how --
16 MR. JONES: Well --
17 MEMBER BROWN: -- a lesser qualification, 18 what that means.
19 You don't have to have a double carriage 20 on the slings? Or you don't have to have the same 21 testing to ensure that that load capacity is really 22 what it is because it hasn't changed since the last, 23 or been damaged in some period of time since it was 24 last used?
25 I'm just still struggling. It sounds to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 1 me like it's pretty specific even now. That's where 2 I'm --
3 CHAIR SUNSERI: Charlie, this is Matt.
4 Maybe this helps. I'll try to simplify it quite a 5 bit.
6 MEMBER BROWN: No, I'm sorry to beat this 7 to death. I just wanted to have an understanding of 8 this area, that's all.
9 CHAIR SUNSERI: It's maybe to the point of 10 oversimplifying it here.
11 So, you know, the extreme, on one extreme 12 end is a highly nuclear safety consequential lift. If 13 it goes wrong, bad day, right? That's the highest end 14 of the spectrum.
15 And, so what he's saying is that he's got 16 this qualitative guidelines to assess when to apply 17 those standards, to have all the you know, nuclear 18 grade load dropping capability, no tipping, all that 19 stuff.
20 On the other end of the spectrum is what 21 I'll call a commercial lift. You could be lifting a 22 container in Walmart's parking lot and use that kind 23 of crane for that.
24 So, you know, the qualitative assessment 25 is there to help decide which crane is appropriate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 based on the nuclear safety risks.
2 Did I say that simplified enough, Steve?
3 Is that close?
4 MR. JONES: Yes, that's very close.
5 I mean this standard's not meant to be, I 6 mean it is meant to cover a very large spectrum. And, 7 at the bottom end, you're basically just complying 8 with OSHA requirements for what would be done at any 9 industrial site using a crane to lift things, 10 components around people.
11 MEMBER BROWN: Okay.
12 MR. JONES: Does that help, Charlie?
13 MEMBER BROWN: Yes, I mean yes.
14 I understand the desire not to hammer 15 everything with the nuclear set of standards.
16 Obviously, that makes sense no matter what. I just 17 was trying to get a handle on what, what changes when 18 you do that, okay?
19 And, you've kind of captured the bottom, 20 the bottom feeder in when you're in the parking lot of 21 Walmart and want to lift up a shipping container.
22 MR. JONES: Right.
23 MEMBER BROWN: That certainly clarifies it.
24 Okay, thanks. I won't beat this one to 25 death anymore.
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20 1 CHAIR SUNSERI: No, that's a good question.
2 Go ahead, Steve. Continue on.
3 MR. JONES: All right, I'll move on to the 4 next two standards.
5 ASME NOG-1, the Reg Guide is endorsing the 6 2020 version of this standard. By the way, going 7 back, ASME NML-1 was new for 2019, so that's the 8 reason that this Reg Guide is essentially being 9 produced. Or being considered for issuance at this 10 time, because that's what allowed us to replace the 11 old technical guidance in NUREG-0612.
12 And, then so this standard addresses 13 specifically, a specific type of overhead crane that 14 uses a wire rope hoist and redundant girders that 15 carry a trolley, you know, over a fixed span usually 16 within a building, without the walls of the building 17 structure supporting the crane.
18 But it could also be a gantry, or semi-19 gantry crane where the crane itself runs on tracks at 20 ground level on one or both sides.
21 The main factor here is to address the new 22 technologies that have been incorporated into these 23 types of overhead cranes, especially related to the 24 drive systems and the brakes, or the means of slowing 25 the load during lowering evolutions.
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21 1 There used to be a commonly, a mechanical 2 load brake, and they would just use a DC-type of motor 3 for the hoist.
4 Now, there's a variable frequency, AC 5 motor drives, that can literally do what they call 6 float the load, where it adjusts the field strength of 7 the motor to just hold the load in position without 8 engaging any brakes.
9 And, it also can use electrical components 10 to basically dissipate the heat of lowering the energy 11 from lowering the load, through a resister bank, and 12 use that as a controlled braking means during 13 lowering, which were not really addressed in NUREG-14 0554.
15 In addition, it provides a great deal more 16 detail with regard to the design of the single failure 17 proof, or enhanced safety cranes.
18 All the recent cranes, or I'm sorry, 19 design certifications involving for example AP1000, 20 have cited this standard, an earlier version of this 21 standard, for those cranes.
22 And, then the final standard is ASME BTH-1 23 2017. It's designed for both as it says here, design 24 of below the hook lifting devices.
25 And, specifically, we're looking at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 chapters 1 through 3, which address static mechanical 2 devices that directly support the load.
3 There are some provisions in that standard 4 for example, with magnetic hoists, or magnetic devices 5 and other features that might be used in other lifting 6 applications.
7 So, our intent here is to only accept 8 mechanical lifting devices that directly connect to 9 the loads.
10 The provisions of ANSE N14.6 that direct 11 with continued compliance, are covered in NML-1 as far 12 as you know, periodically verifying that the special 13 lifting device, which is really just typically a steel 14 structure, that the welds are not developing cracks, 15 that the dimensions of the lifting device are not 16 changing.
17 That's encompassed in NML-1 now, instead 18 of in use of ANSI N14.6, which was no longer, which 19 has been withdrawn and was really no longer getting 20 support for upgrades.
21 The effect of this new guidelines is to 22 really recognize that as I mentioned before, the 23 changes in technology and the lessons learned from 24 decades of operating experience under the previous 25 guidelines.
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23 1 One of the big factors, or big changes, is 2 to administratively restrict sling usage to either 3 straight connections between specially designed 4 attachment points, or use of basket configurations 5 only around large diameter round objects, for nuclear 6 safety critical lifts, that highest, or most 7 concerning category of lifts.
8 That's really based on operating 9 experience that was, did not involve nuclear safety 10 critical lifts, but where objects were supported by 11 slings wrapped around the object.
12 And, a corner of that component was able 13 to cut through the sling material when the corner 14 protection devices that were placed by riggers, moved 15 out of position.
16 So, that really isn't meeting the intent 17 of an enhanced safety lift. So, we're trying to start 18 from the basic design where that protection against 19 cutting is inherent in the rigging design.
20 And, then beyond that, having additional 21 safety factors either provided through a redundant 22 rigging, or enhanced safety factors in the single 23 rigging path.
24 We've also recognized like, as I mentioned 25 before, the very good performance of special lifting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 1 devices, and reduced the design margins incorporated 2 in those, and the periodic testing of special lifting 3 devices.
4 This reflects mostly a transition to a 5 different means of verifying the integrity of the 6 structure.
7 And as I mentioned, the design standard 8 with ASME BTH-1 is intended really for again, 9 everything from lifting a component in the Walmart 10 parking lot, to use that example, to a nuclear safety 11 critical lift where there might be significant other 12 safety concerns.
13 And, what changes is the design factors, 14 and the quality applied to the design and initial 15 testing of those devices.
16 But it moves away from the ANSI N14.6 17 guidelines where you could be designing things with a 18 factor of safety of 10 on an ultimate, or a 6 on the 19 yield, which really probably wasn't providing a lot of 20 extra safety necessarily. It's more just ensuring 21 it's well constructed and that the.
22 And, also recognizing the intent of ANSI 23 N14.6 was for applications to shipping containers, 24 which would be moved from side-to-side, and used on an 25 almost daily basis where, and be stored externally NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 1 when most of the, the special lifting devices that are 2 subject to this Reg Guide would be stationary at a 3 single site, and stored in inside structures.
4 Either inside an auxiliary building, or 5 reactor building containment structure for periodic 6 use during refueling, or interim, or independent spent 7 fuel storage installation operations.
8 It also provides for standardization of 9 programs and training. In the fleet now, many lifts 10 are conducted by contracted personnel during refueling 11 outages. So, it helps to have a very standard 12 training and qualification program. This standard 13 helps provide that.
14 It also adds to the scope of required 15 training in that it covers the rating personnel in the 16 training program, as well as the crane operator, to 17 help reduce the risk of below the hook errors.
18 In addition, I've added a section that 19 kind of goes beyond the new, beyond these three 20 standards to address guidance for special conditions 21 where really clear, stand alone consensus standards do 22 not exist.
23 And, this involves areas like large 24 component replacements, such as steam generator 25 replacement activities. Areas where space or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 1 structural limitations preclude use of a standard 2 overhead crane with a wire rope hoist, and redundant 3 girders, such as an aug-1 crane.
4 And, a lot of activities involving 5 independent spent fuel storage installations that 6 occur outside nuclear power plant structures, but 7 still pose a risk as to the fuel stored inside the 8 canisters.
9 In other words, for certain applications 10 where the potential drop height exceeds that analyzed 11 for the whatever the canister and overpack design is, 12 for that particular storage cask system.
13 This however, does not apply to Part 71, 14 you know, transportation casks, which are evaluated 15 separately for impact, and transportation accidents.
16 Okay, I did want to address the safety 17 significance. Because of generally good standard 18 regulation and design of overhead handling systems, 19 these provide fairly reliable performance.
20 What we've seen in the nuclear industry is 21 less than what I call one uncontrolled motion, or you 22 know, major drop of a load per 10,000 lifts.
23 So, in other words, it's something on the 24 order of one even -5 per year, or I'm sorry per lift, 25 chance of a major load drop based on the operating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 1 experience.
2 And, this comes from generic issue 186 3 related to again, control of heavy loads and the 4 supporting NUREG-1774, which was discussed with the 5 ACRS committee back in several years ago, 2011, I 6 believe.
7 Let's see. So, these, the standard heavy 8 load handling equipment is suitable when a safety 9 function would not be challenged by handling system 10 failure. And there are plenty of those operations in 11 the nuclear power plant facility, and we're not 12 intending to regulate that.
13 But, that is included within the scope of 14 NML-1. And, it provides general controls for standard 15 and special lifts that would fall under that category.
16 And, I should note again, may be covered 17 by the maintenance rule, or you know, as a risk 18 management action for certain conditions.
19 Or, there may be a seismic two-over-one 20 concern with certain cranes that are only used during 21 shut down periods that need to be parked in a location 22 where a seismic event would not cause them to impact 23 other safety related equipment.
24 The enhanced safety handling systems, 25 which is really our focus, reduced the frequency of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 uncontrolled motion or load drops by well, the staff 2 expects another one to two orders of magnitude.
3 The two orders of magnitude would be 4 associated with those lifts using special lifting 5 devices, which provide the greatest assurance of you 6 know, control of the heavy load.
7 And, the enhanced safety handling systems 8 covered by NOG-1 and BTH-1 then, would be suitable for 9 nuclear safety critical lifts when using cranes 10 designed to that NOG-1, type-1 criteria, and have 11 appropriate lifting devices per NML-1 underneath the 12 hook.
13 Next thing I wanted to touch on was the 14 public comments received. As I mentioned in the 15 introduction, the availability of Draft Guide 1381, 16 was published in the Federal Register on May 4, 2021.
17 And, the comment period was extended to end of July 5, 18 2021.
19 The Nuclear Energy Institute provided 24 20 comments. Eleven were related to clarification of 21 individual items. I'll touch on those in the next 22 slide.
23 Five related to the licensing basis change 24 control processes that might be applied with this, and 25 I guess really to look at how to simplify NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 1 incorporation of these new endorsed standards in 2 their, in the licensing basis under 10 CFR 50.59, or 3 10 CFR 72.48.
4 Four related to endorsement of additional 5 standards. These are generally secondary standards 6 that are already mentioned in NML-1.
7 And, the staff you know, deliberately 8 selected the three standards that are called out for 9 endorsement because they're related to the design, 10 fabrication, and initial testing, and qualification of 11 permanent structures, or control of the overall 12 handling system program.
13 And, therefore, the other standards are 14 considered secondary references that are really just 15 invoked by NML-1.
16 And, in some cases modified by what's 17 stated in NML-1 as far as their applicability to a 18 particular classification of load handling.
19 And, then four additional comments were 20 related to enhancing the flexibility of operations 21 through credit for administrative controls, or 22 alternative design elements such as for example, 23 doubling the safety factor of some portion of, or some 24 component in the crane.
25 And, the staff generally did not accept NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 1 those, or agree with those comments.
2 Two individuals provided additional 3 comments that overlapped with NEI comments. These 4 were both related really to below the hook items, and 5 particularly the restrictions on the usage of slings 6 with nuclear safety critical lifts.
7 Okay, the staff did make some changes to 8 the Draft Guide as a result of these comments. The 9 staff clarified the relationship between ANSI N14.6 10 and ASME BTH-1, to identify the you know, that they 11 both cover the design and fabrication of special 12 lifting devices.
13 But BTH-1 does not provide for that 14 demonstration of continuing compliance. That really 15 comes from NML-1, and the secondary standards that it 16 invokes.
17 The staff also clarified that specifically 18 controlled ranges of motion, which is where the crane 19 is limited by interlocks, or just its physical design, 20 or temporary mechanical stops to limit the range of 21 motion of the carried load, such that it would not 22 interfere with essential safety functions if the load 23 were to drop.
24 And, those guidelines covering enhanced 25 safety handling systems, which would involve a NOG-1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 crane, or some other crane, where the staff 2 specifically accepted its design as providing for 3 enhanced safety might be used with, or I'm sorry, I 4 need to step back.
5 The enhanced safety handling systems that 6 invoke a NOG-1, type-1 crane, and that also use either 7 the special lifting device, device per BTH-1, and NML-8 1 considering the, you know, the nuclear safety 9 critical lift classification.
10 Those two approaches would be considered 11 complete, or may be classified as complete, acceptable 12 methods of evaluation as it relates to 50.59, or 13 72.48, the licensing basis change control processes.
14 The staff also explained the basis for the 15 sling restrictions during critical lifts to address 16 multiple comments there.
17 The staff slightly modified the regulatory 18 guidance related to assignment and qualification of 19 cranes used for nuclear safety critical lifts with 20 controlled ranges of motion.
21 In that case, you know, we're using a 22 crane with a more standard design, but it's and again, 23 restricted in its range of operation to preclude it 24 from operating in a way that can threaten loads under 25 the, or under or near the crane.
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32 1 So, those cranes should be seismically 2 qualified, in other words, to prevent toppling during 3 any motion where they're credited in protecting you 4 know, the range of motion is credited in protecting 5 equipment important to safety, or providing for an 6 essential safety function.
7 Provided the limited clarification for the 8 alternative designs of cranes. In other words, these 9 cranes that do not, or could not be designed using 10 ASME NOG-1, type-1 crane design standard because of 11 either physical constraints of where it's located, or 12 that it's used for a temporary large component 13 replacement, or used outside of buildings for in 14 support of an independent spent fuel storage 15 installation.
16 So, there's alternate design criteria 17 where hydraulic gantry cranes, or other crane designs 18 that don't have an enhanced safety standard developed.
19 The intent there is to provide guidance 20 for applications to come in for license, or for review 21 of that as a safety analysis report change addressing 22 specific handling conditions and cranes, where 23 enhanced safety is credited as the means of protecting 24 essential safety functions.
25 And, then again, clarification of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 sling restrictions for nuclear safety critical lifts.
2 So, in conclusion, the staff is endorsing 3 three industry standards related to either the overall 4 handling system program, or specific design of nuclear 5 overhead cranes, a specific type of overhead crane, 6 and the special lifting devices that may be used with 7 those cranes.
8 The staff expects the revised guidance to 9 provide safety and efficiency benefits over the 10 existing guidance provided in technical, NRC staff 11 technical reports developed in the late '70s and early 12 '80s.
13 And, the staff does expect substantial 14 adoption of NML-1, Control of Heavy Loads programmatic 15 guidance through provisions of the licensing basis 16 change control regulations 50.59 and 72.48.
17 With that, I'm open to address any 18 questions the members may have.
19 CHAIR SUNSERI: Thank you, Steve. I 20 appreciate the presentation.
21 So members, any questions for staff?
22 MEMBER HALNON: Yes, Steve, this is Greg 23 Halnon.
24 The little technical questions but you 25 know, 0612 is kind of weaved pretty extensively in our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 1 licensing basis throughout the plants, and procedures, 2 inspection procedures and everything else that we use 3 as the NRC inspectors as well.
4 I know that 0612 is like 40 years old but 5 why not just update 0612? I mean, is this is it an 6 expensive change? I mean, when you put the two next 7 to each other, is there going to be a huge change in 8 licensing basis and back fit discussions, and those 9 types of things?
10 MR. JONES: No. There is an appendix in 11 NML-1 addressing compliance, or conformance with the 12 NUREG-0612 guidelines.
13 And, for the nuclear safety critical list, 14 which is really where this applies, they're 15 essentially identical.
16 I guess there's certain things are still 17 going to require license amendments because we can't 18 really address, for example, a load drop analysis 19 where that's credited under certain conditions where 20 you know, you're not crediting the crane or the 21 lifting devices just to prevent a load handling drop.
22 And, it is in an area where it could affect an 23 essential safety function.
24 So, when you're looking at what's the 25 result if you postulate a load dropping, that requires NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 1 really a license amendment.
2 And, these special or non-standard crane 3 designs where when a NOG-1, type-1 crane can't be 4 used, that's another example where we still expect to 5 see license amendments. And, that really doesn't 6 change because NUREG-0612 is not used.
7 However, I did want to clarify. Because 8 of the commission's back fed and forward fed policies, 9 the you know, NUREG-0612 and NUREG-0554 can still be 10 used, and could still be cited for example, in new 11 applications, if desired.
12 But our intent is to you know, address the 13 operating experience change, the technology changes 14 that have occurred over the years.
15 And, also, we're also trying to meet the 16 Commission and I guess the, really the government's 17 policy to endorse national consensus standards 18 wherever appropriate.
19 MEMBER HALNON: Okay, so it's a voluntary 20 thing --
21 (Simultaneous speaking.)
22 MR. JONES: Yes.
23 MEMBER HALNON: -- that takes that out of 24 the way.
25 What about I assume that there's NRC staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 1 on these committees that develop these, and will be on 2 them to cover any potential changes down the road?
3 MR. JONES: Yes.
4 MEMBER HALNON: Okay. Last question is for 5 decommissioned plants.
6 Do these have applicability there as well 7 when they're moving the hive of the waste and whatnot?
8 MR. JONES: Yes. We have approved license 9 amendments where certain plants needed to be 10 reconfigured, or used specialized, you know, lifting 11 arrangements to support defueling of spent fuel pools.
12 Especially some of the very you know, the 13 older plants where they weren't designed for 100 ton 14 interim storage, or I'm sorry, I keep using interim, 15 but independent spent fuel storage installation 16 storage cask systems.
17 Or multi-purpose systems. Sorry.
18 MEMBER HALNON: So, we should see even the 19 plants that are shut down, adopt at least the 20 applicable portions of these newer standards that are 21 coming out?
22 MR. JONES: Well, and they may. I'm not 23 certain on you know, that. There may be such a limited 24 period where they expect to still be handling fuel.
25 Once the fuel is out of, or is removed to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 1 dry storage, they may not have any need to maintain 2 this, the particular part of the heavy loads handling 3 program that deals with nuclear safety critical lifts.
4 MEMBER HALNON: Okay, yes, I got you.
5 MR. JONES: They might not (inaudible) 6 valuable.
7 MEMBER HALNON: Yes, all right, thanks.
8 CHAIR SUNSERI: Vicki, go ahead with your 9 question.
10 MEMBER BIER: Sorry, I guess I'm on mute.
11 Okay.
12 I just wanted to know how this policy 13 would play out in the day-to-day life of say, a 14 resident inspector or somebody.
15 Are they going to notice compliance or 16 problems kind of only at the moment when there is a 17 lift like this, which may be very infrequent, or is 18 there some other method by which they would be 19 reviewing the policies and procedures on site?
20 You know, how would we know if there is a 21 problem before something gets dropped?
22 MR. JONES: The primary areas where this is 23 inspected involve the, the refueling inspection module 24 for operating reactors, and the independent spent fuel 25 storage installation start up inspections, or dry run NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 1 inspections, where the staff would be specifically 2 looking at handling system design and operation, and 3 their procedures covering inspection and testing of 4 the components during operation. And, also the 5 procedures on how they handle that.
6 So, with respect to inspection, that's 7 where Part 72 would invoke it. For Part 50, this 8 routinely applies to the reactor vessel head 9 movements, the reactor vessel internal lifts, and I 10 guess some other lifts may be invoked.
11 For example, I guess I'm thinking Watts 12 Bar Unit 2 is replacing steam generators in the near 13 future. And, so that process, they're invoking really 14 a load drop analysis type of process.
15 But that's one example where I'm certain 16 the resident inspectors would be following that 17 activity because they have, that's one example where 18 the load crosses.
19 Although the reactor is defueled, there's 20 no safety functions within containment itself where 21 the, the steam generators would be moved.
22 The load path does go over areas where for 23 example, there's two service water lines supporting 24 the operating unit. And, both trains of service water 25 supporting the operating unit. So, that would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 1 Watts Bar Unit 1.
2 So, that those are examples I guess, where 3 this would come up in inspection space.
4 I think this does a better job of maybe 5 highlighting for example, the ANO scatter drop event 6 in 2013 involved a temporary large component 7 replacement activity.
8 And, this Reg Guide kind of highlights 9 that that needs to be assessed very carefully to 10 determine whether or not there's a you know, a nuclear 11 safety lift, nuclear critical safety lift involved 12 with that type of replacement activity.
13 And, what types of reviews might be 14 involved with getting approval for that, if necessary.
15 Or maybe conducting the 50, the evaluation whether 16 it's under the maintenance rule or 50.59 to address 17 that situation.
18 CHAIR SUNSERI: Thank you.
19 Vesna has a question. Vesna, you have the 20 floor.
21 MEMBER DIMITRIJEVIC: Thank you. I don't 22 maybe have a question. I just want to make some 23 observation because the AP1000 and you know, advance 24 reactors were mentioned, but what we saw in the new 25 scale review is actually that the risk, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 1 (inaudible) risk is actually dominated by load drop.
2 So, we have a very specific situation when 3 you move the module not only if you drop it, you will 4 damage one (inaudible) but it can (inaudible) to core 5 damage.
6 Also, is not really happening in the shut 7 down, is happening in shut down for the module which 8 is moving for the (inaudible), but is moving in 9 vicinity of operating module, so the load drop can 10 actually damage operating modules.
11 So, in the looking in this is one of the 12 you know, the multi-module designs. An advance 13 reactor, maybe we will need same type-1 plus category 14 for those load drops in the situation like that.
15 So, I just want to make that comment.
16 CHAIR SUNSERI: Thank you. Any response 17 from staff on that or?
18 MR. JONES: Yes. Are staff available to 19 address specifically I think the new scale design?
20 If anyone wishes to come forward.
21 Otherwise, I guess what I'd say is that's really what 22 I intended to address with the safety significance.
23 We expect that you know, the frequency of 24 a load handling problem, especially with a crane 25 designed with you know, to be a NOG-1, type-1 crane, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 1 with a special lifting device conforming with NML-1 2 being used in that process, would have a you know, a 3 probability of failure in the vicinity of 10 to -7 or 4 lower.
5 MEMBER DIMITRIJEVIC: Well, you know, but 6 the risk of these advanced reactors is often in the 7 like, never mind, like 10 to -8 , 10 to -9 categories.
8 MR. JONES: Right.
9 MEMBER DIMITRIJEVIC: So, even 10 to -7 is 10 a very high contributor.
11 But as I remember from the review on the 12 new scale, the risk for their load drop was dominated 13 by operator errors of commissions when they do 14 something not proceduralized, or with instrumentation 15 errors.
16 So, I'm not sure this, the frequency of 17 load drops what they're based on, but this is what was 18 the situation there, so.
19 CHAIR SUNSERI: So, when we look at things 20 like that, we need to consider other than just the 21 cranes themselves, all the other infrastructure around 22 it.
23 Good observation, Vesna.
24 Any other members?
25 (No audible response.)
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42 1 CHAIR SUNSERI: Okay, well thank you for 2 the presentation.
3 I guess I'll now open the floor to anybody 4 listening in to the conversation today, if you would 5 care to make a comment, or provide a remark, this is 6 for the general public.
7 Any members of the general public wishing 8 to make a statement, you can unmute yourself using *6, 9 make your statement, state your name and make your 10 statements and I'll open the floor.
11 (No audible response.)
12 CHAIR SUNSERI: Okay, so we'll close that 13 up and I'll give the same courtesy to any of the staff 14 members, or other participants listening in through 15 the Teams channel, if you'd like to make any comments 16 or statements.
17 (No audible response.)
18 CHAIR SUNSERI: All right, appearing none, 19 or me wrapping this up here then shortly.
20 Let me just say I appreciate the staff 21 coming over here. When I initially reviewed these 22 documents way back a long time ago I felt like it was, 23 you know, the staff was heading in the right direction 24 consolidating, taking industry experience and applying 25 it to the systems.
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43 1 Anyway, we asked them to come, and then 2 based on our pretty much extensive conversations 3 during new scale, I knew there was a sensitivity to 4 heavy loads, and I know that a lot of this is not 5 directly applicable, but that may be applicable in 6 some applications.
7 So, I thought it would be useful for the 8 committee members that were interested to hear where 9 the heavy loads program was going, what options would 10 be available, so that as Vesna points out, in the 11 future when we review other advance reactor designs, 12 we'll have a general familiarity with this new 13 standard, if you will, in how it built on the old 14 link.
15 So, at this point, I really as I said, 16 invited them in here as an information briefing. They 17 have not requested a letter from us, and I don't think 18 we need to have a letter, that's my opinion. But I'll 19 just open it up to the members.
20 Does anybody feel otherwise, that we 21 should have a letter?
22 MEMBER HALNON: Matt, this is Greg. Do we 23 have access to these standards? I didn't get a chance 24 to go through all of our documents, but are these 25 standards available to us for our future review on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 the, heavy loads in the nuclear reactors?
2 CHAIR SUNSERI: Yes, yes, we can get the 3 stuff.
4 MEMBER HALNON: Can put these in our ACRS 5 shared folders?
6 CHAIR SUNSERI: Working through our --
7 MEMBER HALNON: Okay.
8 CHAIR SUNSERI: -- our staff members can 9 obtain them for us.
10 MEMBER BLEY: Hey, Greg?
11 MEMBER HALNON: Yes?
12 MEMBER BLEY: This isn't related to today's 13 talk, but we can have somebody on the staff show you 14 how, but we can get to almost any standards and many 15 journals, too, if you need them.
16 MEMBER HALNON: I signed up for that 17 online, Dennis. I was able to get some stuff on 18 there.
19 But it's always, for me it's always a crap 20 shoot if I'm spelling NML right. Nevertheless, I 21 understand.
22 But back to your original question, Matt.
23 I'm not, unless the staff feels they need some 24 confirmation from the committee, I don't think a 25 letter would be necessary.
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45 1 MR. GARDOCKI: This is Stan Gardocki, can 2 you hear me?
3 CHAIR SUNSERI: Yes.
4 MR. GARDOCKI: Stan Gardocki, I work in Reg 5 Guide branch, and we interface face you were asked on 6 the Reg Guides before were published.
7 We just need a confirmation from the ACRS 8 that there is no comments in regards to this Reg Guide 9 before we publish it here in the next couple of weeks.
10 If you can put it in the meeting summary 11 notes or something like that, then we can have 12 confirmation that there's no, ACRS did not have any 13 comments on the Reg Guides.
14 CHAIR SUNSERI: Can that confirmation come 15 the first week of December, or you need it earlier 16 than that?
17 MR. GARDOCKI: No, that's fine.
18 CHAIR SUNSERI: Okay. So, we normally do 19 that in our Planning & Procedures discussion in full 20 committee meetings, and will do that this time.
21 MR. GARDOCKI: Great. Yes, we normally get 22 the letter, and that letter we used as the 23 acknowledgment to go forward in the process, that ACRS 24 didn't have any comments on a procedure in the Reg 25 Guide.
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46 1 CHAIR SUNSERI: Yes, so we'll follow that 2 process seems.
3 MR. GARDOCKI: Thanks.
4 MEMBER MARCH-LEUBA: This is Jose, and I 5 know I'm playing a broken record but we have example 6 today of two Reg Guides with members benefit from a 7 memo type procedure where we do this P&P in a more 8 formal way.
9 And, I know I keep pushing it, and you 10 guys keep voting no but I, we need to do something 11 that is simple, unpainful, and that satisfies 12 everybody.
13 I'll leave it at that.
14 CHAIR SUNSERI: Thank you. Anyone else?
15 (No audible response.)
16 CHAIR SUNSERI: Okay, well thank you to the 17 staff for the presentation today. Thank you to the 18 members for your attention, and at this time we are 19 adjourned.
20 Have a good day.
21 (Whereupon, the above-entitled matter went 22 off the record at 3:09 p.m.)
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Draft Regulatory Guide 1.244 Control of Heavy Loads at Nuclear Facilities Steven Jones, Acting Chief Containment and Plant Systems Branch, NRR Presentation to the Advisory Committee on Reactor Safety, Subcommittee on Regulatory Policies and Practices November 16, 2021
Agenda
- 1. Introduction
- 2. Existing Guidance
- 3. Proposed New Guidance
- 4. Safety Significance
- 5. Response to Public Comments
- 6. Conclusion
Introduction
- Purpose of RG 1.244:
- Endorse appropriate consensus standards for control of heavy loads
- Update guidance contained in current technical reports
- Expand applicability to include lifting devices used for major component replacement and spent fuel storage
- These consensus standards provide updated guidance for heavy load handling programs, including:
- methods to assure safety functions are accomplished considering equipment failures and effects of natural phenomena
- standards for operation, maintenance, and testing of handling systems, especially enhanced reliability systems
Existing NRC Guidance
- NUREG-0612, Control of Heavy Loads at Nuclear Power Plants
- Provides criteria for protection of safety functions
- Specifies good practices for the handling of heavy loads
- NUREG-0554, Single Failure-Proof Cranes for Nuclear Power Plants
- Provides criteria for crane design, fabrication, and testing
- Specifies features to control load following component failures, natural phenomena, and operator errors
- ANSI N14.6, Radioactive MaterialsSpecial Lifting Devices for Shipping Containers Weighing 10 000 Pounds (4500 kg) or More for Nuclear Materials
- Provides criteria for lifting device design and testing
- Specifies inspection and testing to verify continued compliance
Proposed Endorsed Standards
- American Society of Mechanical Engineers (ASME) Standard NML-1-2019, Rules for the Movement of Loads Using Overhead Handling Equipment in Nuclear Facilities
- Replacement for NUREG-0612
- Qualitative risk-informed approach
- Scope expanded for wider use at nuclear facilities
- Updated to reflect operating experience
- Restrictions on use of slings
- Simplified testing for special lifting devices
Proposed Endorsed Standards (cont.)
- ASME Std. NOG-1-2020, Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)
- Replacement for NUREG-0554
- Reflects current technologies
- ASME Std. BTH-1-2017, Design of Below-the-Hook Lifting Devices, Chapters 1-3 (mechanical devices)
- Provides criteria for the design and fabrication of special lifting devices and load lifting attachments
- NML-1 and BTH-1 combined address scope of ANSI N14.6
Effect of New Guidance
- The staff expects endorsement of these three industry consensus standards to provide safety and efficiency benefits.
- Incorporates lessons from several decades of operating experience
- Administratively restricts sling usage to straight connections to specially designed attachment points or basket configurations around large diameter rounded objects for safety-significant lifts
- Reduces design margin and burden of testing special lifting devices based on high reliability
- Wire rope cranes take advantage of new designs to eliminate risk from two-blocking and provide controlled lowering systems
- Standardization of programs and training
- Many lifts conducted by contracted personnel during refueling outages
- Adds riggers to scope of training included in program to reduce risk of below-the-hook errors
- Flexible guidance included for special conditions
- Large component replacement (e.g., Steam Generator Replacement)
- Space/structural limitations preclude NOG-1 crane
- Outside nuclear power plant structures (e.g., ISFSI Operations)
Safety Significance
- Standard nuclear overhead handling systems provide reliable performance
- Less than one uncontrolled motion per 10,000 lifts based on operating experience
- Suitable when safety function would not be challenged by handling system failure
- NML-1 provides acceptable controls for standard and special lifts
- Enhanced safety handling systems
- Reduce frequency of uncontrolled motion by 1 to 2 orders of magnitude
- Suitable for NML-1 Nuclear Safety Critical Lifts when using crane designed to NOG-1, Type I criteria and appropriate lifting devices
Public Comment
- Availability of Draft Guide 1381 for public comment published in Federal Register on May 4, 2021
- Public comment period ended on July 5, 2021
- Nuclear Energy Institute provided 24 comments:
- 11 related to clarification of specific items
- 5 related to licensing basis change control process
- 4 related to endorsement of additional standards
- 4 related to enhance flexibility through credit for administrative controls or alternative design elements
- Two individuals provided additional comments that overlapped with NEI comments.
Changes to Draft Guide
- Background
- ANSI-N14.6 and ASME BTH-1 relationship
- Clarified that controlled ranges of motion and enhanced safety handling systems constitute complete acceptable methods of evaluation
- Explained basis for sling restrictions during critical lifts
- Regulatory guidance
- Seismic qualification of cranes used for nuclear safety critical lifts with controlled range of motion
- Clarified criteria for alternative crane designs for critical lifts
- Clarification of sling restrictions for critical lifts
Conclusion
- The staff is endorsing three industry standards
- The staff expects the revised guidance to provide safety and efficiency benefits
- The staff expects substantial adoption of NML-1 control of heavy loads program guidance through the provisions of licensing basis change control regulations