NL-05-093, Reply to Supplemental RAI Regarding Fuel Storage Building Single-Failure-Proof Gantry Crane

Reply to Supplemental RAI Regarding Fuel Storage Building Single-Failure-Proof Gantry Crane

ML052140477
Person / Time
Site:	Indian Point
Issue date:	07/22/2005
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-05-093, TAC MC5036
Download: ML052140477 (9)

Text

Entergy Nuclear Northeast

_A _ Indian Point Energy Center EnMPMWt450 Broadway, GSB R0. Box 249 Ent Buchanan, NY 10511-0249 Tel 9147346700 Fred Dacimo Site Vice President Administration July 22, 2005 Re: Indian Point Unit No. 2 Docket No. 50-247 NL-05-093 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station O-Pl-17 Washington, DC 20555-0001

Subject:

Reply to Supplemental RAI regarding Fuel Storage Building Single-Failure-Proof Gantry Crane

References:

1. NRC Letter dated June 6, 2005, Supplemental Request for Additional Information regarding Amendment Application for Fuel Storage Building Gantry Crane (TAC No. MC5036)

2. Entergy letter dated April 12, 2005, Reply to RAI regarding Amendment Application for Fuel Storage Building Gantry Crane (ML051150099)

3. NRC letter dated February 25, 2005, Request for Additional Information regarding Amendment Application for Fuel Storage Building Crane (ML050470515)

4. Entergy letter dated November 1, 2004, License Amendment Request (LAR) - Fuel Storage Building Single-Failure-Proof Gantry Crane (ML043140282)

Dear Sir/Madam:

Entergy Nuclear Operations Inc. is providing a response to the NRC request for additional information (RAI) in reference I regarding the proposed license amendment request for new Fuel Storage Building Single-Failure-Proof Gantry Crane for Indian Point Unit 2. The responses for the questions are provided in Attachment 1.

There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Patric W. Conroy, Manager, Licensing, at 914-734-6668.

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NL-05-093 Docket No.50-247 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on 1/C22 /o 11J Fred R. Dacimo Site Vice President Indian Point Energy Center

Attachment:

cc: See page 3

NL-05-093 Docket No. 50-247 Page 3 of 3 cc: Mr. Samuel J. Collins Regional Administrator - Region I Mr. John Boska, Senior Project Manager Project Directorate 1-1 Senior Resident Inspector U.S. Nuclear Regulatory Commission Indian Point Unit 2 Mayor, Village of Buchanan Mr. Paul Eddy State of NY Public Service Commission Mr. Peter R. Smith, President NYSERDA

NL-05-093 Docket No. 50-247 Attachment 1 Page 1 of 6 ATTACHMENT 1 TO NL-05-093 REPLY TO NRC SUPPLEMENTAL REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT REQUEST FOR NEW FUEL STORAGE BUILDING GANTRY CRANE AT INDIAN POINT 2 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 2 DOCKET 50-247

NL-05-093 Docket No. 50-247 Attachment I Page 2 of 6 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 2 DOCKET 50-247 Request for supplemental additional information from NRC letter dated June 6.2005 (TAC ML 5036)

Ouestion 1:

In its April 12 letter, Entergy stated in its response to RAI Question 2 that some of the protection provided by the programmable logic controller (PLC) system is as follows:

• Movement of the trolley north towards the fuel pool is only permitted if the following conditions are satisfied:

o Turnbuckles are attached to the crane tie down points.

o Cantilever arms are extended and locked in place.

o Main transfer hoist is at operating elevation that allows HI-TRAC to clear south wall of spent fuel pit.

Describe, in sufficient detail, the logic that will prevent the occurrence of the following scenarios, and whether these protection schemes can be overridden by the operators:

(a) Movement of the trolley north towards the pool when the arms have not yet been extended and pinned in place; (b) Movement of the trolley when the main transfer hoist is at an operating elevation that does not allow the HI-TRAC to clear the south wall of the spent fuel pit; and (c) Movement of the trolley towards the pool when the turnbuckles have not been attached to the crane tie down points.

Ouestion 1 Response:

There are multiple safety interlocks that prevent improper north motion of the trolley toward the fuel pool. The following interlocks described below need to be satisfied in order to allow trolley motion north towards the fuel pool. These design features in conjunction with detailed procedures and task specific training will ensure the movement of the trolley will occur at the appropriate times in the procedure when the interlocks are satisfied.

a. Scenario - movement of the trolley north towards the pool when the arms have not yet been extended and pinned in place.

NL-05-093 Docket No. 50-247 Attachment I Page 3 of 6 Protection system - The cantilever arms need to be extended and all pins locked in place.

There are limit switches that verify the east, west and end-tie girder actuators are fully extended (cantilever arms extended). Also there are limit switches that verify the east, west and end-tie upper and lower locking pins are locked in place. Finally a redundant mechanical limit switch is actuated when the end-tie girder is fully closed. This end-tie fully closed limit switch can only actuate when the east, west and end-tie girders are completely closed. These hard-wired interlocks will prevent trolley motion if not satisfied. An operator input at the girder pendant activates the PLC sequencing of the Girder Mechanization System. The PLC is an independent system that does not control trolley movement or any interlocking of the trolley.

Note - If the cantilever arms are not extended and all pins are not locked in place, the trolley should always be pinned in the seismically restrained position. Locking of the trolley shall only be manually performed by trained personnel following written administrative procedure.

b. Scenario - Movement of the trolley when the main transfer hoist is at an operating elevation that does not allow the HI-TRAC to clear the south wall of the spent fuel pit.

Protection System - The main hoist and canister hoist must be raised to their respective geared upper limit positions before the trolley is allowed to move north or south over the pool wall. These hard-wired interlocks prevent the trolley motion if not satisfied. If these interlocks are not satisfied, a primary cantilever limit switch will stop the trolley

NL-05-093 Docket No. 50-247 Attachment I Page 4 of 6 motion prior to movement onto the cantilever. If the trolley moves beyond the primary cantilever switch, a secondary cantilever limit switch will remove 480v AC power to the trolley motor controller and brake. Removal of power to the brake control sets the brakes.

c. Scenario - Movement of the trolley towards the pool when the turnbuckles have not been attached to the crane tie down points.

Protection system - Four (4) turnbuckles are attached on the south truck tie down points.

See picture below. Two (2) similar turnbuckles are attached on the north truck tie down points. When all six (6) turnbuckles are mechanically secure, six (6) individual tie down proximity switches are actuated. These hard-wired interlocks prevent trolley motion if not satisfied. If these interlocks are not satisfied, a primary cantilever limit switch will stop trolley motion prior to movement onto the cantilever. If the trolley moves beyond the primary cantilever switch, a secondary cantilever limit switch will remove 480v AC power to the trolley motor controller and brake. Removal of power to the brake control sets the brakes.

NL-05-093 Docket No. 50-247 Attachment 1 Page 5 of 6 Note - The "Pool" position must be selected by the operator on the Cask Handling Key switch to allow trolley movement onto the cantilever. The key will be removed and administratively protected when the switch is in the "Normal" position. The operators cannot override any interlocking logic as there are no bypass switches that are available to allow trolley movement north towards the fuel pool if conditions described in scenarios a through c (above) are not met.

Ouestion 2:

Describe how training will address operation of the crane and interlocks to provide some measure of defense-in-depth against the events described above.

Ouestion 2 Resnonse:

The procedure for the set-up and operation of the new gantry crane and crane operator training were commitments submitted in the original License Amendment Request submitted November 1,2004.

w - -

NL-05-093 Docket No. 50-247 Attachment I Page 6 of 6 Previous Commitments:

Gantry crane operatingproceduresutilizedfor cask and cask component lifts will be prepared to include: identificationof requiredequipment; inspections andacceptance criteriarequired before loadmovement; the steps andpropersequence to be followed in handling the load; defining the safe loadpath;and otherprecautions. A specific cask loadingandhandling procedure will provide additionaldetailsfor controlledmovement duringcask handling operations.

Craneoperatorsreceive trainingthat includes the provisions of Chapter2-3 ofANSI B30.2.0 -

1976. In addition, completion of a crane-specificon-the-job-trainingqualificationcardis required Training of personnel is based on the procedures to be used for Dry Cask Storage. The development of the gantry crane procedure will have all the requirements for setting up the crane for the specific evolution. The interlocks discussed in this letter as well as other design features of the crane is be part of the procedure. The specific actions or evolutions will be discussed in training class and followed with On the Job Training (OJT). Upon completion of the training the crane operators will need to complete a qualification card that ensures proficiency in crane operations.

The following identified procedural requirements shall describe how training will provide assurances that the operators of the crane and its controls system will avoid events listed in question 1.

• The Cask Handling Key Switch will always be removed and administratively protected with the switch in the "Normal" position except when the operation over the pool is required. Only trained personnel would be allowed use of the key with the authorization of the program manager. Switching to the "Pool" position is just one interlock which must be satisfied to allow movement of the trolley onto the cantilever.

• After the cantilever arms are completely extended and all the locking pins are locked in place, power from the Girder Mechanization System will be shut off by switching the disconnect switch on the Girder Mechanization Panel to the "off' position This removes power to the PLC, all girder actuators and girder locking pin solenoids. The pressurized air system shall also be disconnected from the Girder Mechanization System piping.

These steps will prevent inadvertent operation of any portion of the Girder Mechanization system during crane operations.

• The trolley locking pin (seismic restraint) will always be installed except when the cantilever arms are closed and locked in place and the crane turnbuckles are in place securing the crane. This locking pin will mechanically prevent any movement of the trolley.

• Moving the trolley over the pool wall must also be visually monitored carefully at all times.

The above protection system with trained and qualified operators will assure proper and safe crane operation.