Text

Revised License Amendment Request (LAR) 2004-26, Use of the Fuel Building Cask Handling Crane for Dry Spent Fuel Cask Loading Operations Dated March 8, 2005
	ML052690225
Person / Time
Site:	River Bend
Issue date:	09/21/2005
From:	King R; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	+kBR1SISP20060503, RBG-46478
	Download: ML052690225 (118)
	v • d • e

Entergy Operations, Inc.

River Bend Station

__r 5485 U. S. Highway 61 N St. Francisville, LA 70775 v-r-;En e 4> Tel 2253366225 Fax 225 635 5068 rking~entergy.com Rick J. King Director, Nuclear Safety Assurance RBG-46478 September 21, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

River Bend Station Docket Nos. 50-458 and 72-49 License No. NPF-47 Revised License Amendment Request (LAR) 2004-26, "Use of the Fuel Building Cask Handling Crane for Dry Spent Fuel Cask Loading Operations"

References:

1. License Amendment Request (LAR) 2004-26, "Use of the Fuel Building Cask Handling Crane for Dry Spent Fuel Cask Loading Operations" Dated March 8, 2005

2. Entergy Operations letter to NRC, "Response to NRC Bulletin 96-02,

'Movement of Heavy Loads Over Spent Fuel, Fuel in the Reactor Core, or Over Safety Related Equipment,"' dated August 29, 1996

3. Supplement to License Amendment Request (LAR) 2004-26, "Use of the Fuel Building Cask Handling Crane for Dry Spent Fuel Cask Loading Operations" Dated April 19, 2005

4. Supplement to License Amendment Request (LAR) 2004-26, "Use of the Fuel Building Cask Handling Crane for Dry Spent Fuel Cask Loading Operations" Dated July 12, 2005.

5. NRC request for additional information dated August 19, 2005.

Dear Sir or Madam:

In Reference 1, Entergy Operations Incorporated (Entergy) requested an operating license amendment for River Bend Station (RBS). The proposed license amendment requested approval for the use of the Fuel Building Cask Handling Crane (FBCHC) for dry spent fuel cask handling operations. Specifically, consistent with the requirements of 10 CFR 50.59 and the guidance in NUREG-0612 and Bulletin 96-02, certain heavy load drop events had been postulated and analyzed, which Entergy has determined will require NRC review and approval prior to implementing dry storage cask operations at RBS. This submittal contains the following information:

Attachment 1 is a revision of the original Attachment 1 of Reference 1 and incorporates several corrections and clarifications to the original submittal.

AD 1

RBG-46478 Page 2 of 3 Attachment 2 contains the figures provided in the original submittal.

The proposed amendment includes new commitments. These new commitments are summarized in Attachment 3 to this letter and supersede the commitments provided in the original LAR.

Attachment 4 of this request responds to NRC Requests for Additional Information (RAI),

provides additional clarification and certain corrections of data.

Attachment 5 contains photographs of the crane rigging in response to the RAI.

Attachment 6 is the initial review of the NUREG-0612 AND NUREG-0554 Comparison Matrix for the RBS FBCHC submitted in Reference 3 with clarifications identified.

Changes have been marked with revision bars to assist in your review.

The proposed amendment was evaluated in accordance with 10 CFR 50.90(a)(1) using criteria in 10 CFR 50.92(c) and it was determined to involve no significant hazards considerations. The bases for these determinations are included in the attached submittal. The no significant hazards considerations are not affected by the responses to the RAI.

Entergy requests approval of the proposed amendment as soon a practicable but no later than November 1, 2005 to allow loading the three casks this year and maintain full core offload capability. Once approved, the amendment will be implemented prior to using the FBCHC for dry spent fuel cask operations.

If you have any questions or require additional information, please contact Mr. Bill Brice at 601-368-5076.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 21, 2005 Dincerely, Ri/ckJ.Kit Director, Nuclear Safety Assurance RJKIWBB

RBG-46478 Page 3 of 3 Attachments:

1. Analysis of RBS Spent Fuel Cask Handling in the Fuel Building

2. Figures

3. List of Regulatory Commitments

4. Responses to RAls for LAR 2004-26

5. Photographs of Redundant Rigging

6. NUREG-0612 AND NUREG-0554 Comparison Matrix for the RBS Fuel Building Cask Handling Crane cc: U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector P.O. Box 1050 St. Francisville, LA 70775 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam MS O-7D1 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission Attn: Mr. B. Vaidya MS O-7D1 Washington, DC 20555-0001 LA Dept. of Environmental Quality Office of Environmental Compliance Emergency and Radiological Services Div.

P. O. Box 4312 Baton Rouge, LA 70821-4312

Attachment I RBG-46478 Analysis of RBS Spent Fuel Cask Handling in the Fuel Building to RBG-46478 Page 1 of 32

1.0 DESCRIPTION

This letter is a revised request to amend Operating License NPF-47, for Energy Operations Incorporated's (Entergy's) River Bend Station (RBS) in support of dry spent fuel storage cask operations in the Fuel Building. As a result of a review recently performed, certain hypothetical heavy load drop events associated with dry spent fuel cask handling operations have been identified and evaluated. A preliminary evaluation of these drop events under 10 CFR 50.59 has resulted in a determination that a license amendment is required to implement the operating procedure changes associated with dry spent fuel storage cask operations at RBS.

This request has been revised to incorporate several corrections and clarifications to the original submittal. The request has also been revised to incorporate the responses to several Requests for Additional Information (RAI). Changes have been marked with revision bars to assist in your review.

2.0 PROPOSED CHANGE

S The proposed amendment will require changes to the RBS Updated Safety Analysis Report (USAR) to reflect the use of the non-single-failure-proof Fuel Building Cask Handling Crane (FBCHC)l for dry spent fuel cask component lifting and handling operations. Specifically, lifting and handling of the spent fuel canister, canister lid, and transfer cask is required. The existing discussion pertaining to a shipping cask drop will be augmented to discuss the spent fuel storage component drops. A new USAR subsection will be added to summarize the activities in support of dry spent fuel storage that take place in the RBS Fuel Building. The existing discussion related to the spent fuel shipping cask drop will be modified to add a new discussion of spent fuel storage cask component drops.

This proposed amendment does not involve any changes to the RBS operating license or technical specifications. Further, Entergy is not requesting NRC approval of an upgrade in designation of the FBCHC from non-single-failure-proof to single-failure-proof or from non-safety-related to safety-related. Rather, this submittal demonstrates that the FBCHC is adequately designed and is operated, inspected, tested, and maintained in a manner that makes it acceptable for use in spent fuel transfer cask lifting and handling activities. NRC approval of this proposed amendment is requested based on the fact that, despite the lack of single-failure-proof design, FBCHC load drop events remain highly unlikely and the consequences of certain hypothetical load drop events have been analyzed and found to be acceptable.

3.0 BACKGROUND

3.1 Fuel Building Cask Handling Crane Design and Licensing History The RBS FBCHC was designed, procured, and installed in the RBS Fuel Building in the late 1970s and early 1980s. It is a non-safety-related, commercial-grade crane originally designed and licensed to lift and handle a spent fuel shipping cask. The crane has been used from time to time since RBS commercial operation began in 1985 to move radwaste containers (e.g., high integrity containers) onto transportation vehicles for shipment to a disposal site. The FBCHC is

' The FBCHC is also referred to as the Spent Fuel Cask Trolley (SFCT) in the USAR and other design documents. The term FBCHC is used throughout this document for consistency.

to RBG-46478 Page 2 of 32 a bridge-and-trolley design that is not single-failure-proof as defined in NUREG-0612 (Reference 6.1) or NUREG-0554 (Reference 6.2). However, the crane does meet many of the criteria in these documents. Entergy will submit a matrix comparing the RBS FBCHC to NUREG-0554 and NUREG-0612 criteria to support the NRC review.

The FBCHC main hoist has a rated load of 125 tons and the auxiliary hoist has a rated load of 15 tons. The subject of this amendment request is only the main hoist because only the main hoist is used to lift the heavy loads associated with dry spent fuel cask loading operations.

A review of the FBCHC design, maintenance and operational history was conducted. This review concluded that with additional analysis, modifications and inspections, spent fuel casks can be handled with a load drop being a very unlikely event. Analysis was performed to demonstrate the crane can handle the rated load under the appropriate loading conditions including seismic. Inspections of welds, bolting, structural steel and concrete were performed to provide reasonable assurance that the crane and supporting structure are installed in accordance with the applicable design drawings and specifications. Aside from routine preventive maintenance activities and installing the redundant rigging discussed latter in this section, no additional modifications, test or inspections are required to support cask handling operations.

The main hoist is capable of lifting its rated load and moving it in a north-south direction between the spent fuel cask pool inside the Fuel Building to an adjacent area outside the Fuel Building designated for the cask transport vehicle to receive the cask (hereafter referred to as the "truck bay"). See existing USAR Figure 9.1-9 and Figure 1 in Attachment 2 to this submittal for details. The FBCHC is not capable of moving in the east-west direction.

The current licensing basis for the FBCHC permits the lifting and movement of a spent fuel shipping cask inside the Fuel Building. A hypothetical drop of a 125-ton shipping cask was analyzed as discussed in the RBS USAR in support of the proposed licensing basis because the FBCHC is not single-failure-proof. No significant damage to any safety-related structures, systems, or components (SSCs) was predicted by this analysis. However, the current licensing basis does not provide a bounding scenario for all of the lifting and handling evolutions required for the spent fuel storage cask system chosen for use at the RBS Independent Spent Fuel Storage Installation (ISFSI) under a 10 CFR 72 general license. The system chosen for use is the Holtec International HI-STORM 100 System, which includes the HI-TRAC 125D" transfer cask and the multi-purpose canister (MPC) that, together with necessary rigging, comprise the heaviest load lifted by the FBCHC during dry storage loading operations in the Fuel Building.

The HI-TRAC 125D"" transfer cask and the MPC must be lifted and moved several times during fuel loading operations in the Fuel Building. At various points in the operation, the empty transfer cask, the empty MPC, the MPC lid, the fuel-loaded MPC, and the loaded transfer cask must be lifted and handled by the FBCHC. Because the FBCHC is not single-failure-proof and will not be upgraded to single-failure-proof, certain drops of the transfer cask, MPC, and MPC lid must be postulated. The locations where drops are postulated and evaluated were chosen to comply with applicable Part 50 licensing requirements, NUREG-0612, and NRC Bulletin 96-02 (Reference 6.3). Licensing basis information for the dry storage cask system was also incorporated in this evaluation, as appropriate, from the HI-STORM 100 System" 10 CFR 72 Certificate of Compliance (CoC) (Reference 6.4) and associated Final Safety Analysis Report (FSAR) (Reference 6.5). A summary of the Fuel Building cask handling operational sequence to RBG-46478 Page 3 of 32 and postulated drops germane to this amendment request is provided in Appendix A to this attachment.

To mitigate the consequences of two of these postulated drops, engineered design features (i.e., impact limiters) will be employed in locations over which the transfer cask must be moved in the vertical direction. In most cases, for locations where the load is moved only in the horizontal direction, redundant crane rigging is employed to provide temporary single-failure-proof drop protection and preclude the need to postulate drops in these locations. More detail is provided on these design features in Section 4.7.2 of this attachment.

3.2 Fuel Building Loading Operations Summary The HI-STORM 100 System' will be used for dry cask storage of nuclear fuel at the RBS ISFSI.

The HI-STORM 100 System"' consists of a multi-purpose canister (MPC-68 ), which is capable of holding up to 68 BWR fuel assemblies; a transfer cask (HI-TRAC 125D"'), which contains the MPC during loading, unloading, and transfer operations; and a storage cask (HI-STORM 100Sm overpack), which provides shielding, heat removal capability, and structural protection for the MPC during storage operations at the ISFSI. The FBCHC is required to lift and handle the HI-TRAC transfer cask and MPC (both empty and loaded with spent nuclear fuel), and the MPC lid in support of dry storage cask loading. The combined maximum lifted weight, including rigging and lift yoke will not exceed 125 tons, which is the design rated (maximum critical) load of the FBCHC.

During each cask loading campaign, spent fuel assemblies are moved, one at a time, from the RBS spent fuel pool wet storage racks into the MPC, which is resting inside the HI-TRAC transfer cask in the cask pool on the lower shelf (Position 5 on USAR Figure 9.1-9). The cask pool will have been previously flooded with water to approximately the same elevation as the spent fuel pool and the gate separating the cask pool and spent fuel pool will have been opened. Once the desired number of fuel assemblies has been loaded into the MPC, the MPC lid is installed under water and the transfer cask is lifted by the FBCHC and placed on the cask pool upper shelf (Position 4 on USAR Figure 9.1-9) to allow changes in rigging equipment (see Figure 1 in Attachment 2 to this submittal). Then, the transfer cask is lifted out of the cask pool and moved northward to a dry cask washdown area (Position 3 on USAR Figure 9.1-9, hereafter referred to as the "cask pit").

In the cask pit, the MPC lid is seal welded and the canister is drained, dried and backfilled with helium in accordance with the 10 CFR 72 cask CoC and FSAR. The transfer cask containing the sealed MPC is decontaminated, lifted out of the cask pit, and moved by the FBCHC through the Fuel Building outer doors into the truck bay (Position 2 on USAR Figure 9.1-9) where it is placed on top of the empty storage overpack, which has previously been prepared to receive the transfer cask with a mating device. The FBCHC is disengaged from the transfer cask lifting trunnions and rigged to lift the MPC by its lift cleats. The MPC is lifted slightly to remove the weight from the transfer cask bottom (pool) lid. The pool lid is detached and lowered into the mating device, the mating device drawer is opened to provide a pathway through to the overpack, and the MPC is lowered into the overpack. After MPC transfer, the overpack lid is installed and the overpack is transported to the ISFSI using a cask crawler.

to RBG-46478 Page 4 of 32

4.0 TECHNICAL ANALYSIS

4.1 General Basis The River Bend Station FBCHC was designed and procured as a non-safety-related, non-single-failure-proof lifting system that would hold its suspended load in the event a safe shutdown earthquake occurred during load handling. This design and procurement process took place in the mid- to late-1970's and pre-dated the issuance of NUREG-0554, NUREG-0612, and associated NRC Generic Letters. The FBCHC design is in accordance with Crane Manufacturer's Association of America (CMAA) Standard 70 (1970); ANSI B30.2, "Overhead and Gantry Cranes" (1967); and Occupational Safety and Health Administration (OSHA) regulations (1973), as well as contemporaneous commercial structural, welding, and electrical design codes. The issues surrounding NUREG-0612 were addressed as part of the RBS license application review process, but the crane was not upgraded to single-failure-proof or safety-related.

A review of RBS historical records shows that, while the crane was not formally designated as safety-related with quality assurance controls under 10 CFR 50 Appendix B applied, there were appropriate inspections, tests, and documentation required by the procurement specification and performed at the time of construction to verify that the construction met the design requirements. As part of the RBS dry cask storage project, a comprehensive evaluation was undertaken by Entergy to review the original design and construction documents and compare them to what would be required of a safety-related design and installation today. From this review and the results of additional inspections and testing, it was concluded that the crane and superstructure were actually constructed in accordance with the design documents and are suitable for use in dry storage cask loading operations.

However, the crane does perform an important design function in lifting and handling the loaded transfer cask. Therefore, the classification of the FBCHC has been upgraded to "Quality Assurance Program Applicable" in the RBS configuration management and work control systems. With this upgrade in classification, all future modifications, inspections, testing, and maintenance of the FBCHC will be performed under the RBS 10 CFR 50 Appendix B Quality Assurance program (i.e., as if it was a safety-related component).

The outdoor portion of the FBCHC crane structure extends out from the Fuel Building doors in the north direction approximately 100 feet and is 27 feet wide, column line to column line (see Reference 6.6). There are a total of twelve vertical columns supporting the crane trolley. The structural members are carbon steel with cross-bracing for lateral stability. There are a number of bolted and welded joints that bear the dead load of the structure, including the crane bridge and trolley, and the live load of the suspended spent fuel transfer cask. Each element of the crane structure and certain key design criteria are addressed separately below.

to RBG-46478 Page 5 of 32 4.2 Crane Foundations Twelve reinforced concrete pedestals support the outdoor crane superstructure columns. All 12 of the crane columns are bolted to 5 ft. long by 3 ft. wide pedestals. The four southernmost pedestals are 3'-4Y2W high and rest atop a single 48 ft. long by 25 ft. wide by 31/2 ft thick footing.

Each of the center six pedestals rests atop individual 5ft. by 5 ft. by 21/2 ft. high footings. The two northernmost pedestals rest atop a single 34 ft. long by 16 ft. wide by 3% ft. thick footing.

The pedestals protrude approximately one foot above grade. Finish concrete is provided between the column rows to form the truck bay.

Entergy engineering performed a review to document the inspections and tests performed to demonstrate that there is reasonable assurance that the crane foundation, including the concrete pours, base plates and anchor bolts, was constructed in accordance with the design.

A ground-penetrating radar investigation of the crane foundation was also performed in May, 2004 during the ground excavation that was being performed in support of a modification to the truck bay concrete. The results of this investigation show that the crane pedestals and footings are in the locations and are of the dimensions specified on the design drawing. Evidence of reinforcing steel in the top mat of the foundation footings was also confirmed by the radar.

Additional excavation to expose more of the footings in an attempt to gain more information is not practical. The proximity of the footings to the RBS condensate storage tank (CST) precludes any significant additional excavation without the threat of undermining the CST foundation. No additional investigative work on the outdoor crane foundation is planned. No foundation modifications are required for the FBCHC to perform its design functions during dry spent fuel cask loading operations.

4.3 Crane Structural Steel An engineering review was also performed to document the inspections and tests performed and to demonstrate that there is reasonable assurance that the crane steel structure, including materials used and the bolted and welded connections that bear load or provide structural rigidity, was constructed in accordance with the design. All inspections conducted under this review were satisfactory in confirming the integrity of the crane structure.

As part of the operational review for dry storage cask loading activities, it was discovered that a header beam in the outdoor crane structure needed to be raised to provide adequate clearance for the overpack and cask crawler. Upon removal of the beam from its existing location, its root weld was observed to have a lack of fusion in a number of areas. As a result, the affected weld was repaired and the weld inspection scope was increased to include ultrasonic inspection of all critical (load bearing) welds of a similar type that support the crane rails and a sampling of other welds not in the load path but which contribute to the rigidity of the structure. No other occurrence of degraded welds was found.

4.4 Crane Inspections and Tests The FBCHC receives inspections on a daily basis when the crane is in use, with additional inspections and preventive maintenance on an 12-month frequency. These inspections are performed as a good practice to ensure the crane is in good working order prior to use.

Discrepancies that are encountered during the inspections are resolved as part of the inspection to RBG-46478 Page 6 of 32 or entered into either the maintenance work control system or the corrective action program for resolution.

The frequent inspection is a prior to use visual inspection that verifies that a fire extinguisher is available in the cab; that warning and caution signs are intact and legible; that the hoist rope wire is free of kinking, crushing, birdcaging, corrosion, unacceptable broken wires or outer wire wear; that the crane hook is free of bending or distortion and the hook latches are operable; that the brakes, hydraulic system, couplings, bearings and gear reducer are free of excessive wear, breakage, deformation and leakage; and that the footwalks, handrails bumpers and stops are free of excessive wear, breakage, deformation or interference of operation.

The periodic inspection is a more in-depth inspection than the frequent inspection and includes checking for loose parts on the bridge or trolley; for gearbox gear and teeth excessive wear; for gearbox lubricant chemistry and oil change, if necessary; for control cab damage or obstruction; for walkway, ladder, handrail and trap door damage; for support and crane structure rail anchorage, cracks in steel, or loose bolts; for wheel and bearing inspection and lubrication; for brake wear and adjustment, if necessary; for chain drive, sheave, wire rope and pillow block bearing inspections; for coupling grease; for drum groove wear and wire rope anchor inspection; for non destructive examination of the hooks; for verification that the bumpers are intact and securely bolted; and for motor and electrical equipment checks. An operational test is conducted following the inspections. These inspections are performed without a load on the hook(s).

Load testing of the entire travel range of outdoor portion of the FBCHC was performed in 2004 at 125% of the 125-ton rated load, which is consistent with the guidance in NUREG-0554. This test also included testing of the redundant rigging appurtenance design modification, which is relied upon to preclude having to postulate load drops during most lateral moves of the crane (see Section 4.7.2 and Appendix A to this attachment). Load testing of the indoor portion of the FBCHC was performed during initial construction. The crane procurement specification required a 125% rated load test, which was performed during plant pre-operational functional testing. Because the load-bearing components of the inside portion of the crane structure have not been modified since original installation, another 125% load test of the crane inside the Fuel Building in support of dry spent fuel cask loading operations is not required.

4.5 Crane Seismic Qualification The FBCHC was designed and procured as a seismically qualified structure. During the review of design documents for the RBS dry cask storage project it was discovered that the seismic analysis was performed with no load on the crane hook. This is contrary to the RBS USAR, which states that the crane is qualified to maintain the load during a design basis seismic event.

This issue was entered into the RBS corrective action system and a re-analysis was performed which concluded that, with the exception of two welds, the crane system is qualified to hold the maximum critical load during a design basis seismic event. The two affected welds - the main girt to the two end trucks - were recently upgraded under an RBS modification package.

Therefore, the crane is considered fully seismically qualified for dry storage cask loading operations.

to RBG-46478 Page 7 of 32 4.6 Tornado Wind and Missile Loads RBS currently has administrative controls in place that prohibit fuel handling and the Fuel Building outer doors from being opened if severe weather is imminent (Reference 6.7). If fuel handling is in progress when severe weather is detected, current procedures require fuel handling and radioactive material transport activities to cease except as required to move the material to a safe location. In addition, Entergy will evaluate meteorological conditions using information available from the National Oceanic and Atmospheric Administration (NOAA),

National Weather Service (NWS), or other appropriate source to confirm that weather conditions are not expected to be conducive to tornado development over the time period when cask handing in the outdoor crane structure is planned. Cask handling operations in the outdoor crane superstructure would not commence if atmospheric conditions exist that are conducive to tornado formation. Thus, no specific evaluation of tornado wind or missile loads on the crane superstructure while a cask is suspended above the truck bay has been performed.

If outdoor cask handling is underway and weather conditions unexpectedly deteriorate rapidly, sufficient time exists to move the suspended cask to a safe location in a controlled, deliberate manner. A "safe location" can mean anything from closing the outer doors and lowering the transfer cask onto the overpack or to the ground (where, in either case, it would then be in an analyzed condition), to returning the transfer cask to the Fuel Building and closing the outer doors. The actual actions taken would depend on the estimated time available before severe weather arrives. RBS's severe weather procedures will be reviewed and modified appropriately, as necessary, to address cask handling operations. RBS's cask loading operations procedures will contain a requirement to check meteorological conditions prior to opening the Fuel Building outer doors and commencing outdoor cask handling operations, and periodically thereafter during outdoor cask handling operations.

4.7 FBCHC Cask Handling and Postulated Drop Events 4.7.1 Cask Loading Operations and Related Design Features By design, the FBCHC cannot physically move a heavy load over irradiated fuel in the RBS spent fuel pool. The load path of the FBCHC main hoist is centered between, and parallel to, column lines FAA and FBA in the Fuel Building (see Reference 6.6). This keeps the loaded cask strictly above the cask pool, cask pit, and outdoor truck bay during cask loading operations. The step-by-step operational activities and hypothetical load drop events involving the FBCHC and the MPC/transfer cask are provided in Appendix A to this attachment based on the guidance of NUREG-0612. The following criteria govern cask handling operations as they pertain to the postulation of potential cask drop events (see Figure 1 in Attachment 2 to this submittal):

a) During applicable load movements, impact limiters are installed on the floor at elevation 70 ft. in the cask pool (known as the "lower shelf") and at elevation 98'-1" in the cask pit.

The impact limiters are made of a crushable material encased in sheet stainless steel (see Figure 2 in Attachment 2 to this submittal).

b) No impact limiters are used at elevation 93 ft. in the cask pool upper shelf or under the overpack in the truck bay beneath the outdoor cask handling crane structure.

to RBG-46478 Page 8 of 32 c) During certain horizontal cask movements between the cask pool and the outdoor truck bay, redundant rigging is engaged to the cask lift yoke, which provides temporary single-failure-proof protection against load drops and eliminates the need to postulate a load drop during these movements (Figure 3 in Attachment 2 to this submittal).

d) Cask drops must be postulated for locations where loads are suspended from the FBCHC and the redundant rigging is not engaged.

e) Drops of a loaded cask provide a bounding case for drops of an unloaded cask or empty MPC for a given location, provided other elements of the drop scenario (e.g., drop height or impact energy) are the same or bounded by the loaded cask drop.

f) Relevant elevations of the cask handling area horizontal surfaces and dimensions of cask components are:

i. Cask pool lower shelf elevation: 70 ft.

ii. Cask pool upper shelf elevation: 93 ft.

iii. Wall elevation between upper cask pool shelf and cask pit: 113 ft.

iv. Cask pit pedestal elevation: 98.08 ft.

v. Truck bay elevation: 94.42'.

vi. Impact limiter height: 26.25 in.

vii. Spent fuel pool water level elevation: 111.75 ft.

viii. HI-TRAC 125D pool lid thickness: 5.5 in.

ix. MPC baseplate thickness: 2.5 in.

x. MPC-68 basket height: 14.67 ft.

xi. HI-STORM overpack height without lid:

100S(243): 18.5 ft.,

100S Version B (218): 16.625 ft.

xii. HI-STORM baseplate thickness plus pedestal:

100S(243): 19.25 in.,

1OOS Version B: 8 in.

xiii. HI-STORM mating device height: 10.75 in.

4.7.2 Redundant Crane Rigging 4.7.2.1 Operational Description and Design Criteria The FBCHC has been modified to add upper "lift links," which are redundant, load-bearing structural connections to the crane main girt. These upper lift links include pins, around which fixed-length slings are looped. Lower lift links are attached to the bottom of the slings and connect to the lift yoke to create redundant rigging that is capable of holding the full 125-ton rated load of the crane in the event of a failure of the main hoist's ability to hold the load for any reason (Figure 3 in Attachment 2 to this submittal). The upper crane links are considered a crane modification and are designed with safety factors of three and five to yield and ultimate stress allowables, respectively. The slings are designed in accordance with ASME B30.9,

'Slings." The lower crane links and lift yoke are designed as special lifting devices in accordance with the guidance in ANSI N14.6 (Reference 6.8). The RBS cask lift yoke is designed as shown in Figure 3 in Attachment 2 to this submittal to mate with the lower lift links as described below. The upper crane link modification has been successfully installed and load to RBG-46478 Page 9 of 32 tested at 125% of the rated load. The lower crane links were also shop tested at 150% of the rated load in accordance with ANSI N14.6.

Referring to Figures 1 and 3 in Attachment 2 to this submittal, the redundant crane rigging is engaged whenever a loaded cask is moved horizontally at its maximum suspended elevation.

That is, when the bottom of the transfer cask is at about elevation 114'-0".

The redundant crane rigging is engaged for the following specific horizontal moves of a loaded transfer cask, for either a cask loading or cask unloading evolution:

Between the cask pool and the cask pit-The move is between a position above the impact limiter at the cask pool lower shelf and a position above the impact limiter on the pedestal in the cask pit.

Between the cask pit and the MPC transfer stack up-The move is between a position above the impact limiter on the pedestal in the cask pit and a position above the spiral wound gasket on the mating device mounted on a HI-STORM overpack cask.

During these lifts, the main hook is attached to the cask lift yoke and the lift yoke is attached to the lifting trunnions of the transfer cask with ANSI N14.6-designed lift links. The cask is lifted vertically with the main hoist until the crane block and lift yoke are high enough that the lower lift links of the redundant rigging fit inside the lift yoke and the engagement mechanisms of both lower links are aligned with the holes in the lift yoke. Air actuators are used to engage the lower lift links with the lift yoke, providing a redundant load path through the slings and upper lift links into the crane support structure. Successful engagement of the redundant rigging is visually confirmed. After initial engagement with the lift yoke, the slings have some slack in them. To eliminate the slack, and therefore, minimize the dynamic loading in the event of a sudden load transfer, the load is lowered slightly to make the slings taut without placing any significant load on them. We will ensure that cask loading procedures include visual confirmation that redundant rigging is properly engaged and slack is removed from redundant rigging slings prior to horizontal movement whenever a loaded cask is moved horizontally at its maximum suspended elevation.

After successful engagement of the redundant rigging, vertical movement of the load is not necessary and horizontal movement of the cask may proceed. When the cask reaches a point where vertical movement is again required, the redundant rigging is disengaged and the main hoist may be operated normally to lower and raise the load. The redundant rigging may be engaged and disengaged as many times as necessary during cask handling operations with the FBCHC. Load drops are not postulated during times when the redundant rigging is engaged.

4.7.2.2 Load Transfer during Postulated Failure Scenarios As described above, operating administrative controls are used to ensure the slings in the redundant load path have a minimal amount of slack without carrying any significant portion of the load. The absence of significant load in the redundant load path under normal conditions eliminates having to evaluate some, or the entire load being suddenly shifted to the primary load path if a failure of the redundant load path is postulated.

to RBG-46478 Page 10 of 32 In a postulated failure scenario where the load is suddenly shifted from the primary load path (the crane hook) to the redundant rigging, a dynamic load is applied to the slings and other members of the redundant load path. The magnitude of that dynamic load has been calculated to verify that the load is within the capacity of the redundant rigging system (Reference 6.9). The dynamic analysis code used is VisualNastran, a commercial dynamic simulation code that has been used by Holtec International in other dynamic analysis work reviewed and approved by the NRC. The acceptance criterion for this analysis is that, due to the shift of the load from the primary load path to the redundant load path, the design limits of all components must not be violated by the expected increase in stress or load level.

Key assumptions used in this analysis are:

1. The crane trolley is assumed to be positioned over a support when the event occurs.

This is conservative because no structural dampening from the crane girders is available to reduce the dynamic amplification.

2. The redundant lift links are assumed to behave as non-linear elastic members. The crane hoist primary load is modeled as a rope element; no compression is permitted in the crane main load path member. These are realistic assumptions.

3. When the event occurs, the load is transmitted instantaneously to the redundant load path. This is conservative.

4. The crane ascent or descent speed is constant throughout the computer simulation. This is realistic and makes the solution independent of the speed.

5. The redundant load path slings are assumed to have no slack. This is realistic and control by operating procedures.

6. The redundant load path links are unloaded when the load transfer occurs. This is conservative because any initial tensile loading in the redundant links would serve to reduce the dynamic amplification.

7. The damping available in the redundant load path system is the same as the structural damping in steel from a safe-shutdown seismic event. This is conservative because the sling material and built-up woven construction increases internal friction and produces higher damping values.

Key input data used in this analysis are:

1. A spring constant for the redundant link system is calculated using data from the sling manufacturer to develop a non-linear load-stretch relation, K = 2x105 Mbf/in.

2. Redundant link damping = 7 percent.

3. Weight of lifted load = 250,000 lbs.

4. Weight of load block = 5,000 lbs.

5. Weight of trolley = 55,000 lbs.

to RBG-46478 Page 11 of 32 The results of the analysis indicate that the peak dynamic load in the redundant load support system due to a sudden shift of the 125-ton load from the primary load path to the redundant load path is 492 kips or, stated differently, a dynamic amplifier of 1.97. Other load cases executed to determine the sensitivity of the results to higher damping (arbitrarily chosen to be 21%) and starting with some load in the redundant load path (28 kips and 127 kips) show that the 7% damping and zero load in the redundant load path provide a bounding set of results.

The crane girders, secondary load-bearing members, the trolley, and the crane hook and attachments are all qualified for a load of 596 kips based on the seismic analysis of the FBCHC.

Because the supports for the redundant load support system transmit load to the trolley main girt directly, safety factors for the main girt were re-computed for the 492-kip maximum load calculated for the sudden load transfer event plus the girt self weight. The safety factor based on 90% of yield for the girt material and assuming a pin-ended connection for the main girt is 1.162. The safety factor for the weld group (defined as allowable load per unit length divided by the calculated load per unit length) assuming a one-inch weld and fixed-end connections at the ends of the main girt is 1.07.

The redundant load support system components have a safety factor of 1.06 for the normal 125-ton load condition (over and above the minimum requirements of 3.0 on yield and 5.0 on ultimate for members in tension or combined shear). The safety factor is for a bending stress in the top pin of the lift yoke load latch assembly. Under the peak dynamic load induced in the redundant load path by the load transfer event, the bending stress in the pin is 42.7 ksi, which is well below the yield strength of 95 ksi for the SA 193-B7 material.

The two slings in the redundant load support system are rated for a combined load of 300,000 lbs with a safety factor of 5.0 for a total sling capacity of 1,500 kips. For the peak dynamic load of 492 kips in the load transfer event, the safety factor is slightly more than 3.0.

In summary, all load-bearing members of the redundant load support system are qualified to support the dynamic load resulting from a hypothetical loss of the primary load support system during cask handling operations with the redundant rigging engaged.

4.7.3 MPC Lid Drop The drop of the MPC lid during installation into the canister after fuel loading in the cask pool is addressed as a unique event. Due to its weight (10,000 Ibs), the MPC lid is a heavy load as defined in NUREG-0612. The combined weight of the lid and rigging apparatus is approximately 15,600 lbs. The 125-ton rated load of the FBCHC is nearly 16 times the weight of the lifted load. Therefore, all crane safety factors calculated based on the rated load are 16 times higher for lid-only lifts, making a lid drop event extremely unlikely.

The slings and special lifting devices used to lift the MPC lid exceed all applicable NUREG-0612, Section 5.1.6 design guidance to preclude having to postulate a load drop due to a failure in a load-bearing component in the load path below the crane hook. However, as discussed above, the crane design does not meet all NUREG-0612 and NUREG-0554 guidance to be considered single-failure-proof (e.g., it does not have dual rope reeving). Absent a single-failure-proof crane design, a drop of the MPC lid needs to be evaluated.

to RBG-46478 Page 12 of 32 Section 5.1.4 of NUREG-0612 specifically addresses handling heavy loads over irradiated fuel inside the reactor building of a BWR. While the MPC lid handling activity at RBS does not occur in the Reactor Building (it takes place in the Fuel Building), this guidance is deemed to be applicable because the lid is suspended over irradiated fuel in the canister located in the cask pool. The NUREG-0612 guidance recommends several alternative approaches for addressing heavy load handling over irradiated fuel, including:

Upgrade the crane to single-failure-proof status in accordance with Section 5.1.6 of the guidance (which includes NUREG-0612, Appendix C for existing cranes), or

Analyze the drop of the load in accordance with Appendix A of the guidance to ensure the acceptance criteria of NUREG-0612, Section 5.1 are met.

Entergy has chosen to evaluate the consequences of an MPC lid drop into the loaded spent fuel canister. A discussion of that evaluation is provided in Section 4.7.4 below.

4.7.4 MPC Lid Drop Evaluation As discussed previously, the MPC lid and associated rigging weigh approximately 15,600 lbs and will be handled by the FBCHC, which has a rated load of 250,000 lbs, making the safety factors for the lid lift 16 times higher than those for the rated load. An NRC safety evaluation report for Zion Nuclear Power Station (Reference 6.10) provides a licensing precedent for considering a crane single failure proof based on high safety factors for the load being lifted. In the case described in the Zion SER, the crane is to be used to lift spent fuel racks, some of which would contain spent fuel assemblies during the lift. However, the racks would only be lifted six inches above the pool floor and would not be carried over irradiated fuel. Despite the high safety factor for the MPC lid lift with the FBCHC and this licensing precedent, Entergy determined that it would be prudent to evaluate the consequences of an MPC lid drop onto the loaded MPC in the cask pool as a conservative licensing approach.

4.7.4.1 Lid Drop into the MPC After the spent fuel is loaded into the MPC, the MPC lid is installed using the FBCHC. The rigging, attached to four symmetrically located lift points in the lid, ensures that the lid is held in the horizontal position during lowering so that it will fit into the MPC, which has a very close shell-to-lid dimensional clearance. Because there is approximately 20 feet of water above the MPC during lid installation, if a failure of a crane mechanical component (rather than a wire rope) results in an uncontrolled lowering of the lid, the lid will initially remain horizontal.

If the lid is dropped from a significant height, the column of water below the falling lid will eventually cause the lid to drift laterally and not physically be able to enter the open MPC.

Therefore, the first analysis of this event assumes the lid is three feet above the MPC and perfectly positioned for insertion when the failure occurs, allowing the lid to drop straight down into the MPC fuel cavity in the horizontal orientation. In this scenario, the lid will accelerate as it falls and impart an impact load on the four lift lugs welded to the inside of the MPC shell. (The lift lugs are designed to support the dead weight of the lid until the lid is welded to the canister shell.) The lift lugs are designed with very large safety factors to preclude failure and dropping of the lid onto the top of the fuel basket. The analysis evaluates the ability of the lift lugs to withstand the impact load of the lid drop using manual structural mechanics computational techniques (Reference 6.11).

to RBG-46478 Page 13 of 32 The acceptance criterion for this analysis is no damage to the spent fuel assemblies in the MPC.

Key assumptions used in this analysis are:

1. The lid remains horizontal during the drop through the water and enters the MPC without obstruction. This is conservative for the 3 ft. drop height assumed because the lid would actually likely drift laterally to some extent and be prevented from entering the MPC without impacting the MPC shell or transfer cask upper flange.

2. The lid is considered as a rigid mass. This is realistic for this application.

3. The MPC shell is assumed to be instantaneously expanded out by the increase in internal pressure caused by the "piston" effect to the diameter where it contacts the transfer cask inner shell. This is conservative because it provides the largest drop cross-sectional area and a smaller resisting force is applied to the dropped lid.

4. Fluid drag is considered in computing the lid velocity during the free fall. This is realistic.

5. The water is considered approximately incompressible in that the change in density is assumed to be proportional to the lid velocity. The proportionality constant affords a simple way to account for the expected reduction in the water velocity escaping through the lid-to-shell gap as the water density increases. This is a simplifying assumption.

Key input data used in the analysis are:

1. Drop height above MPC = 3 ft.

2. Distance from top of MPC to top of lift lugs = 9.5 inches

3. MPC lid weight = 10,000 lbs.

4. MPC lid diameter = 67.25 in.

5. MPC shell inner diameter = 67.75 in.

6. Other cask component dimensions and material properties are taken from the Hl-STORM 100 FSAR.

The results of the analysis show that the lift lugs will withstand the impact force and prevent the lid from coming into contact with the fuel basket or fuel.

4.7.4.2 MPC Lid Drop onto the Transfer Cask Top Flange A second MPC lid drop event was analyzed where the dropped lid lands on the transfer cask top flange, pivots, and falls into the MPC. This analysis (Reference 6.12) was performed using the LS-DYNA computer code, which has been used in previous NRC-reviewed and approved dynamic analysis work performed by the cask vendor. The acceptance criterion for this analysis is no unacceptable fuel damage and that the deformation of the fuel basket in the MPC, if any, to RBG-46478 Page 14 of 32 must not extend to the top of the active fuel region, where the fixed neutron poison panels are located. This second criterion is chosen to ensure the licensing basis criticality analysis is preserved.

Key assumptions used in this analysis are:

1. The lid is dropped from the surface of the cask pool through the water to the upper flange of the transfer cask. This is a realistic assumption because the lid will only be carried high enough to avoid making contact with the cask pool prior to being lowered into the MPC. See Figure 1 in Attachment 2 to this submittal.

2. The MPC and the transfer cask structural components behave as bilinear elastic-plastic materials characterized by five material parameters (i.e., Young's modulus, yield strength, ultimate strength, failure strain, and Poisson's ratio). This is a reasonable assumption based on good engineering practice.

3. Material damping and water resistance during the impact are neglected. This is conservative since both damping and resistance will be non-zero.

4. The lid impacts the transfer cask flange at a 2-inch offset between the radial centers of the MPC/transfer cask and the lid such that the lid does not fall directly into the MPC in a horizontal orientation and a minimal amount of energy is dissipated in the first impact with the transfer cask prior to the lid falling into the MPC.

Key input data used in this analysis are:

1. Weight of MPC lid = 10,000 lb.

2. Thickness of MPC lid = 9.5 in.

3. Distance between top of the fuel basket and top of the active fuel region = 14.625 in.

4. Lid drop height = 319.25 in.

5. Other cask component dimensions and material properties are taken from the Hl-STORM 100 FSAR.

The analysis shows that the lid hits the transfer cask top flange with a velocity of 212.6 in/sec.

The impact does not cause any damage to the transfer cask because the maximum stress (10,300 psi) is well below the material yield stress. The subsequent impact between the MPC lid and the MPC shell does result in local plastic deformation; the maximum plastic strain (0.3123) is below the failure strain limit of the material (0.38). The fuel basket is also locally damaged with plastic deformation in four fuel cells, extending down two inches from the top of the basket.

This damage is well above the active fuel region and the neutron absorber panels remain undamaged. Conservatively, up to four fuel assemblies could experience some damage, but major relocation of fuel material would not be expected.

to RBG-46478 Page 15 of 32 4.7.4.3 Radiological Evaluation The potential radiological consequences of an MPC lid drop onto irradiated fuel in the canister and subsequent damage to the fuel were compared to the existing RBS fuel handling accident analysis described in USAR Section 15.7.4 and with the data in Tables 2.1-1 and 2.1-2 of NUREG-0612. While the MPC lid drop has the potential to damage more fuel assemblies than the drop of a single fuel assembly (see Section 4.7.4.2), the fuel in the spent fuel storage canister will have decayed at least three years in order to be authorized for dry storage in the HI-STORM 100 System 2 . The decay time for the fuel considered in the fuel handling accident is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . A significant amount of decay of the radionuclides available for release will have taken place between 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and three years. No significant iodine will be available for release after three years3 and the key noble gas elements that contribute to the whole body dose, xenon and krypton, will have decayed to very low levels.

Table 2.1-1 of NUREG-0612 shows that, for 90 days of decay and no credit for halogen filtration, the calculated thyroid doses from damage to a single BWR fuel assembly at the Exclusion Area Boundary (EAB) and Low Population Zone (LPZ) are 40 millirem and zero, respectively. The whole body doses at the EAB and LPZ are zero. No doses for the control room are estimated. Also from Table 2.1-1 of NUREG-0612, the number of fuel assemblies that would need to be damaged at 90-days decay to produce doses that are 25% of the 10 CFR 100 dose limits is 1,900. Based on the lid drop analysis described in Section 4.7.4.2 above, at most there may be four fuel assemblies damaged. A conservative evaluation has been performed, as described below, that bounds all four assemblies being damaged.

The generic NUREG-0612 analysis assumes a thermal power level of 3,000 Mwt and X/Q values for the EAB and LPZ of 1.Ox10-3 sec/M 3 and 1.0x1 04 sec/M 3 , respectively, as shown in Table 2.1-2 of that document. The power level used in the River Bend Station fuel handling accident is 3,100 Mwt and the X/Q values are: 8.58x10 4 sec/M 3 (EAB), 1.13x104 sec/M 3 (LPZ, 0-8 hour maximum), and 1.62x103 sec/M 3 (control room, 0-20 minute maximum). Other differences include peaking factor (1.2 in NUREG-0612 and 2.0 in the RBS fuel handling accident) and halogen decontamination factor (100 in NUREG-0612 and 200 in the RBS fuel handling accident).

To determine whether the RBS fuel handling accident radiological consequences provide a bounding case for an MPC lid drop into the canister, the number of fuel assemblies in the canister required to be damaged to reach 25% of the 10 CFR 100 dose limits4 and the GDC 19 control room dose limits was estimated using the NUREG-0612 value (1,900) and the ratios of the differences in the generic NUREG-0612 and site-specific RBS fuel handling accident analysis inputs to see if the number of assemblies remains above four. The difference in dose due to the difference in halogen decontamination factor is ignored due to the three-year decay time. This is conservative because the RBS site-specific analysis uses a higher 2The limit inAmendment 1 (the current version) of the HI-STORM 100 CoC Isfive years minimum cooling time. This limit has tentatively been approved to be decreased to three years InHoltec HIl-STORM 100 CoC Amendment 2. which is currently being prepared for rulemaking. Therefore, three years Isused as a bounding value in this evaluation.

3 1-131 has a half-life of approximately eight days. All other isotopes of iodine except 1-129 have half lives of 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months or less. The half-life of 1-129 is 1.6x10 years but it emits a very low-energy gamma photon (0.04 MeV), making it an insignificant dose contributor for short duration exposures.

4 The RBS licensing basis for offsite dose is the alternate source term limits specified in 10 CFR 50.67. The dose limits in 10 CFR 50.67 are equivalent to the GDC 19 control room limits and 25% of the 10 CFR 100 off-site limits.

to RBG-46478 Page 16 of 32 decontamination factor and would, therefore, reduce the dose. The difference in dose due to the lower source term produced by the longer decay time is not evaluated because it is not a linear relationship. This is conservative because the longer decay time would yield even lower doses.

Power Level: 3,000 / 3,100 = 0.968 X/Q: 1.0x103 sec/m 3 / 1.62x103 sec/M 3 = 0.617 Peaking Factor: 1.2 / 2.0 = 0.600 N = Minimum number of RBS fuel assemblies required to reach 25% of Part 100 dose limits in a fuel handling accident:

N = (0.968)(0.617)(0.600) x 1,900 = 680 assemblies This means that, assuming 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months decay time, at least 170 (680/4) times the number of fuel assemblies that could possibly be damaged in a lid drop event at RBS would need to be damaged to reach 25% of the 10 CFR 100 and GDC 19 dose limits (equivalent to the 10 CFR 50.67 dose limits) considering River Bend site-specific licensing basis inputs instead of the NUREG-0612 generic inputs. Accounting for the three years of minimum decay time required by the HI-STORM 100 CoC and the fact that the peak X/Q value for all dose locations and all times was used in the evaluation above, the number of fuel assemblies required to approach the Part 100 dose limits would actually be significantly higher. Therefore, the existing fuel handling analysis in USAR Section 15.7.4 (which assumed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months decay time and more realistic, time-dependent X/Q values) provides a limiting case accident event that bounds the potential consequences from fuel damage due to an MPC lid drop.

4.7.4.4 Criticality Evaluation Both of the analyses performed for the MPC lid drop and described in Section 4.7.4.1 and 4.7.4.2 confirm that no damage to the fuel basket occurs to the extent that the neutron absorber panels would be prevented from performing their criticality safety function. In addition, there would be no significant relocation of fuel material to create a critical geometry. Therefore the existing generic cask vendor licensing basis criticality analysis remains applicable and bounding and no additional analysis is necessary.

4.7.5 Storage Cask Component Load Drop Summary 4.7.5.1 Drops Inside the Fuel Building Referring to Appendix A to this attachment, the unique and/or bounding load drops inside the Fuel Building that are required to be evaluated and analyzed, as appropriate, due to a lack of single-failure-proof crane design features (by operational step) are:

to RBG-46478 Page 17 of 32

1. Step 4: 4.5 ft. empty MPC vertical drop5 onto the cask pit north wall (see note at end of Section 4.7.6).l

2. Step 26(a): <1 ft. loaded transfer cask drop onto cask pool upper shelf corner with cask top-to-side wall impact (no impact limiter). This evaluation bounds those drops specified in Steps 4 and 31(a).

3. Step 26(b): <1 ft. loaded transfer cask vertical drop onto cask pool upper shelf (no impact limiter). This evaluation bounds the drop specified in Step 30.

4. Step 32: 42.5 ft loaded transfer cask vertical drop onto cask pool lower shelf (with impact limiter). This evaluation bounds those drops specified in Steps 25 and 31.

5. Step 35: 17.5 ft. loaded transfer cask vertical drop into cask pit (with impact limiter). This evaluation bounds the drop specified in Step 40.

4.7.5.2 Drops Outside the Fuel Building When the cask moves from inside the Fuel Building to outdoors, the applicability of NUREG-0612 and the requirement to postulate load drops become less clear. As previously discussed, the focus of the guidance in NUREG-0612 is to ensure protection of operating plant equipment in general and safe shutdown equipment in particular, as well as irradiated fuel in the reactor and spent fuel pool. There is no safe shutdown equipment located under the outdoor crane truck bay. However, because the FBCHC is not single-failure-proof, a drop of the loaded transfer cask onto the top of the overpack and mating device is postulated in the truck bay when the redundant rigging is not engaged. For any drop in the truck bay, the concern is protection of the MPC, the transfer cask, and the contained spent fuel. Therefore, the dry storage system 10 CFR 72 licensing basis documents (FSAR and CoC) were consulted to determine the appropriate acceptance criteria for the drop evaluations.

The HI-STORM 100 CoC includes requirements for the design of a Cask Transfer Facility (CTF), which is used for cask lifting and handling using lift devices not governed by 10 CFR 50.

This set of requirements was considered the most appropriate to use as a basis for determining the acceptance criteria for evaluating drops in the truck bay due to functional similarities between the CTF and the FBCHC outdoor crane structure. Section 3.5.2.1.4 of Appendix B to the HI-STORM 100 CoC states that 'The CTF shall be designed, constructed, and evaluated to ensure that if the MPC is dropped [into the overpack] during inter-cask transfer operations, its confinement boundary would not be breached. This requirement applies to either stationary or mobile lift devices [emphasis added]." That is, notwithstanding the design features required of the device used to lower the MPC into the overpack (i.e., the CTF or a mobile crane), a drop of the MPC during transfer operations must be postulated, with maintenance of confinement boundary integrity as the acceptance criterion for the evaluation.

Based on the above assessment of truck bay operations, the following two additional drops (drops 6 and 7) require evaluation:

5 Drop distances, where cited, are approximate and are measured from the bottom of the dropped load to the top of the target (i.e.,

the cask pool or cask pit floor, the impact limiter, the top of the HI-STORM mating device, or the top of the overpack pedestal). See the detailed analysis section for actual drop distances evaluated.

to RBG-46478 Page 18 of 32

6. Step 43: <1 ft. loaded transfer cask vertical drop onto HI-STORM mating device.

7. Step 44: 18.5 ft. to 19.5 ft. loaded MPC vertical drop into HI-STORM overpack (no impact limiter)

It is appropriate, based on the CoC requirements for a CTF, to establish the acceptance criterion for Drop Number 7 as maintaining of confinement boundary integrity.

4.7.6 Transfer Cask Drop Evaluations A description of the evaluation of each of the transfer cask drops is provided in the subsections below, along with the results of each evaluation. In general, the impact velocity of the dropped cask was calculated using an equation of motion that takes into account all applicable fluid effects, as applicable (e.g., cask pool water), and the height of the drop. The derivation of this equation of motion is based on Reference 6.13 and is described in Reference 6.14. After calculating the impact velocity, a dynamic simulation computer code, such as VisualNastran (VN) or LSDYNA, was used to simulate the dynamic impact and resultant effects on the cask and/or building structure. The results from the dynamic simulation establish the peak g-force on the cask/fuel, the extent of crush of the impact limiter (as applicable), and the maximum deformation in the floor slab or wall. The VisualNastran and LSDYNA computer codes have been used in prior dynamic simulation work by Holtec International and reviewed by the NRC, as described in Sections 3.4 and 3.6 of the HI-STORM 100 System' FSAR.

The general acceptance criteria for each drop analysis are (as applicable) 6:

Maintain deceleration of the cask to < 60 g's to protect the fuel inside the cask and to ensure the MPC design basis deceleration limit is not exceeded. It should be noted that the design basis g-load deceleration limit for the HI-STORM 100 System"" is 45 g's.

However, it has been demonstrated that the fuel assembly deceleration limit for a vertical drop is 64.8 g's (HI-STORM FSAR Section 3.5). The MPC is designed for 60 g's based on the HI-STAR 100 storage FSAR (Docket 72-1008). Therefore, 60 g's is chosen as the fuel assembly and MPC acceptance criterion for these evaluations to provide an additional margin of safety.

Ensure primary stress levels in the HI-TRAC 125DTmtransfer cask structure remain with ASME Code Level D limits,

Ensure that any cask-to-pool wall impact does not cause a collapse of the pool wall.

The general assumptions used in the analyses are (as applicable):

The cask and contents are modeled as rigid bodies with known geometry and weight.

This is conservative because all energy loss associated with cask structural deformation is neglected, which imparts maximum energy into the drop target.

6The Fuel Building floor is already qualified for a 125-ton shipping cask drop under the current RBS licensing basis and is, therefore, not re-analyzed.

to RBG-46478 Page 19 of 32

At the interface between the dropped cask and the target (impact limiter or the floor slab), a contact force-crush relationship is specified. This represents the force-crush relationship of the impact limiter or the force-deformation behavior of the floor slab if no impact limiter is present. This is a realistic assumption that permits actual impact limiter test data to be used to represent impact limiter performance.

If the cask is dropped through water, buoyancy effects, fluid virtual mass, and fluid hydrodynamic mass are included in the simulation after the cask breaks the surface of the water. This is a realistic assumption. The effect of "squeezing out" the fluid between the cask and the impact surface are neglected in calculating impact velocity.

This is conservative because this effect, if included, would decrease the impact velocity.

The energy lost by splashing of the cask as it enters the water is neglected. This is conservative because that energy is assumed to remain with the dropped cask.

During the post-impact phase, all effects of the surrounding fluid (e.g., drag, added mass) are ignored. This is conservative because these effects tend to decelerate the cask as it falls.

For those drops occurring before the MPC lid is welded to the MPC shell, the MPC lid is treated as a separate body in order to determine the potential for separation of the lid from the MPC shell. The mass assigned to the MPC lid in the computer model represents the combined mass of the lid, the lift yoke, crane hook, and a portion of the hoist chain, which were assumed to have separated from the crane in the hypothetical failure that caused the load drop.

Appropriate cask component dimensions and masses, lift yoke and rigging component masses, and characteristics of the building structure were taken from the applicable design documents (e.g., drawings) and the HI-STORM 100 System FSAR. The design of the impact limiters was confirmed based on the analyses, which included the necessary crush strength for the devices, and manufacturer's data for the foam installed inside the impact limiters' steel housing.

Other assumptions and inputs unique to a particular drop analysis are included in the discussion of that particular analysis.

Note: Drops of heavy loads, discussed herein, that do not contain fuel or pass over fuel are bounded by drop analysis in accordance with the existing 10 CFR 50 license, and are included for information only.

4.7.6.1 Drop I - Empty MPC Drop onto the Cask Pit North Wall The effects of this drop on the adjacent floor slab at elevation 93'-0" are bounded by the current licensing basis analysis of an RBS shipping cask drop described in River Bend USAR Section 9.1.4.3. The drop of an empty MPC-68 (approximately 39,000 Ibs) from 4.5 feet above the doorway opening results in significantly less kinetic energy when impacting the floor slab than the 125-ton analyzed drop of the'shipping cask from 0.5 feet above the door opening. No significant damage to safety-related SSCs was predicted by the shipping cask drop analysis.

Therefore, the empty MPC drop will not damage any safety-related SSCs. Because the MPC to RBG-46478 Page 20 of 32 does not contain spent fuel during this postulated drop, there is no need to evaluate damage to the cask's contents.

4.7.6.2 Drop 2 - Loaded Transfer Cask Drop onto Cask Pool Upper Shelf Corner with Cask Top-to-Side Wall Impact After the spent fuel and MPC lid are installed under water, the transfer cask containing the loaded MPC is lifted to an elevation just high enough to clear the elevation of the cask pool upper shelf. The cask is then moved horizontally toward a position over the upper shelf. The movement of the transfer cask to and from the cask pool lower shelf from and to the upper shelf, respectively, are the only horizontal movements of the transfer cask performed without the crane redundant rigging installed (see Section 4.7.2). This is because a lift yoke extension is used to place the cask on the cask pool lower shelf to avoid contaminating the crane block due to immersion in the pool water (see Figure 1 in Attachment 2 to this submittal).

The redundant rigging cannot be installed with the lift yoke extension in use. The lift yoke extension is installed and removed when the cask is on the cask pool upper shelf. Therefore, a drop of the loaded transfer cask is postulated when it is located over the edge of the cask pool upper shelf before the whole cask clears the corner of the shelf, as a bounding analysis. The cask is postulated to drop onto the shelf corner and pivot to the south, toward the lower shelf area, impacting the cask pool south wall. This drop analysis (Reference 6.15) evaluates the structural integrity of the cask pool south wall, including the steel liner.

Two drop orientations were analyzed to determine the worst case impact on the cask pool south wall. The first case assumes the impact of the outer edge of the transfer cask pool lid on the corner of the upper shelf with the resulting rotation of the cask about that point and impact with the wall. The second case assumes the central portion of the cask pool lid impacts the corner of the upper shelf and rotates toward the pool wall. Two drop heights, 1.37 inches and 4 inches, were evaluated for each drop scenario in order to determine sensitivity and identify a bounding case for further evaluation of the pool wall structural integrity. The limiting case (producing the peak force on the cask pool wall) is the 4-inch drop with impact at the edge of the cask pool lid.

This limiting drop case was then re-analyzed to include the non-linear behavior and ductility of the concrete wall to more precisely evaluate the effect of the impact on the cask pool wall.

The results of the limiting case analysis are:

Peak Vertical Force on Upper Shelf: 13,220 kips Peak Horizontal Local Impact Force on Pool Wall: 1,071 kips Peak Force in Wall Spring: 939 kips Vertical Cask Speed at Impact with Upper Shelf: 51.36 inches/sec HI-TRAC Angular Velocity at Impact with Pool Wall: 53.53 degrees/sec The ductility ratio of the pool wall is calculated to be 5.48. The maximum permitted ductility ratio for a concrete plate supported is 30 (Table 4-4 in Reference 6.16). Therefore, the cask pool wall will not collapse as a result of a hypothetical cask drop onto the upper shelf and rotation impact into the wall.

to RBG-46478 Page 21 of 32 4.7.6.3 Drop 3 - Loaded Transfer Cask Vertical Drop onto Cask Pool Upper Shelf A second hypothetical drop of the loaded transfer cask during horizontal movement without the redundant rigging engaged was analyzed (Reference 6.17) for when the cask clears the corner of the cask pool upper shelf. This is a vertical drop of the transfer cask onto the upper shelf from an arbitrarily chosen bounding carry height. This height limit, or less will be incorporated as an operating limit in the cask loading procedures. The dynamic analysis computer code LS-DYNA was used for this simulation.

The acceptance criteria for the analysis are as follows:

No stress levels in the MPC may exceed the allowable limits established in the cask system FSAR for load handling accidents, and the fuel deceleration (Reference 6.5) shall not exceed 64.8 g's.

The reduction in cask shielding, if any, shall be limited such that the dose emitted by the cask is less than any analyzed loss-of-shielding event in the cask FSAR.

The MPC and transfer cask must not deform to the extent that prevents retrievability of the MPC and the fuel assemblies.

The deformation of the fuel basket in the MPC, if any, must not lead to the loss of fuel cladding integrity such that reactivity of the system is increased compared to normal conditions.

The deformation of the MPC, if any, shall not produce an internal helium flow configuration that stifles heat rejection.

Key assumptions used in this analysis are:

1. The transfer cask structural components behave as bilinear elastic-plastic materials characterized by five material parameters (i.e., Young's modulus, yield strength, ultimate strength, failure strain, and Poisson's ratio). This is a reasonable assumption based on good engineering practice.

2. Material damping is neglected. This is conservative because the energy absorption associated with damping is ignored.

3. The load block, crane wire rope, and cask lift yoke, weighing a total of approximately 10,000 Ibs, are resting atop the transfer cask during the drop event. This is conservative because it increases the total mass of the dropped cask.

4. The drop height is approximately 3.5 inches. This was assumed as a reasonable carry height necessary to ensure clearance over the upper shelf corner.

5. The dropped transfer cask remains stable after impacting the target. VisualNastran simulations demonstrate that a dropped transfer cask will not tip over under the conservatively postulated worst scenario.

Attachment I to RBG-46478 Page 22 of 32 The analysis was performed assuming a drop through air. This is conservative because the cask would actually be falling through water, which would create drag resistance on the cask body. A drop through water would result in a lower impact velocity of the cask and less severe consequences compared to a drop through air.

The results of the dynamic simulation show that the cask velocity upon impact with the target after a fall of approximately 3.5-inch freefall is 55.01 in/sec. The maximum deceleration of the MPC is 45 g's, which is below the fuel acceptance limit of 64.8 g's. Therefore, the drop would not cause fuel cladding damage or fuel relocation resulting in an unanalyzed criticality configuration.

The MPC enclosure experiences a maximum Von Mises stress at the MPC lid-to-shell weld above the material yield stress of 20,050 psi, but well below the failure stress of the material.

Other than at the lid-to-shell weld, the MPC enclosure vessel does not experience any plastic deformation. The maximum Von Mises stress on the transfer cask inner shell is less than the material yield stress of 33,150 psi. Therefore, there is no deformation of the transfer cask inner shell. Results indicate that the MPC and transfer cask will retain their structural configurations sufficiently to permit retrieval of the MPC after the drop.

Because of the relatively low yield stress of the pure lead shielding material, some slumping will occur due to the drop. This slump is predicted by the computer simulation to be less than 0.5 inch. While this may allow a small amount of local radiation streaming, but does not have an offsite does consequence. Therefore, it is an acceptable consequence for an accident event.

4.7.6.4 Drop 4 - Loaded Transfer Cask Vertical Drop onto Cask Pool Lower Shelf In this event, the loaded transfer cask is assumed to drop vertically 42'-6" onto the cask pool lower shelf with the impact limiter installed on the floor at elevation 70 ft. The first portion of the drop is through air and the remaining portion of the drop is through water (normal pool water elevation is assumed to be 111 '-9"; water bubble was taken to be 2' 4" below normal water level). The top of the impact limiter is at elevation 72'-21/4". In order to determine sensitivity, different impact limiter resistances were evaluated: 80%, 100%, 120%, and 140%. The 80-120% range covers the manufacturer's standard tolerance range for the foam material and the 140% resistance addresses the scenario where a larger impact area contributes to increased resistance. The analysis yielded the following results:

MAXIMUM CASK IMPACT LIMITER MAXIMUM CRUSH CASE DECELERATION CRUSH STRAIN (g's) (inches) (%)

100% Resistance* 48.0 12.84 55.24 80% Resistance 53.54 14.61 62.9 120% Resistance* 45.9 11.46 49.30 140% Resistance* 48.5 10.30 44.32

Table values based on normal pool water elevation All cask deceleration values are less than 60 g's. Therefore, no fuel damage is predicted and all MPC stresses remain below allowable values established in the HI-STAR 100 SystemT FSAR.

to RBG-46478 Page 23 of 32 The MPC lid shows no tendency to separate from the MPC shell. Therefore, no lid restraint system is required.

The following limiting Von-Mises Stresses were calculated for the transfer cask for a bounding deceleration value of 61.3 g's:

LOCATION VON-MISES STRESS (ksi)

Inner Shell 10.3 Water Jacket End Plate 11.4 Outer Shell 9.22 Water Jacket Bottom Ring 22.1 As interpolated from the data in Table 3.1.12 of the HI-STORM 100 System FSAR, the allowable primary membrane stress intensity and primary membrane plus bending stress intensity at 3500F and are 39.75 ksi and 59.65 ksi, respectively. Von Mises stresses are closely related to stress intensity at a point. Therefore, the Level D stress allowables are met for all values of deceleration calculated for this drop event.

4.7.6.5 Drop 6 - Loaded Transfer Cask Vertical Drop into Cask Pit This drop is postulated to occur while the loaded transfer cask is suspended 19'-9" above the cask pit floor. The cask pit is dry and has a 26.25 inch thick impact limiter located on the pedestal at elevation 98'-1". A cask drop height of 17.5 ft. through air onto the impact limiter was analyzed. The analysis was performed considering the pedestal elevation at 95' resulting in additional conservatism in the results. Like drop No. 4, cask deceleration and impact limiter performance are analyzed, except that the 80% resistance case was not run. The results are as follows:

MAXIMUM CASK IMPACT LIMITER MAXIMUM CASE DECELERATION CRUSH CRUSH STRAIN (g's) (inches) (%)

100% 32.4 9.67 41.61 Resistance 120% 34.2 8.45 36.34 Resistance 140stnc 42.2 7.10 30.56 All cask deceleration values are less than 60 g's. Therefore, no fuel damage is predicted and all MPC stresses remain below allowable values established in the HI-STAR 100 System' h FSAR.

The MPC lid shows no tendency to separate from the MPC shell. Therefore, no lid restraint system is required. Because the deceleration values are all less than 61.3 g's, the conclusions drawn under Drop 4 for transfer cask structural integrity are applicable and bounding for this drop.

to RBG-46478 Page 24 of 32 4.7.6.6 Drop 6 - Loaded Transfer Cask Vertical Drop onto HI-STORM Mating Device Once the loaded transfer cask is moved horizontally by the FBCHC into the truck bay through the Fuel Building doors and positioned directly over the overpack with the mating device installed, the redundant rigging is removed in preparation for lowering the transfer cask onto the mating device. A cask drop is postulated at this point and analyzed. The analysis (Reference 6.17) assumes a free vertical drop from a height of eight and one half inches. This height was assumed as a reasonable bounding value for the carry height necessary to ensure clearance over the mating device. This height limit, or less, will be incorporated as an operating limit in the cask loading procedures. The details of this analysis are described in Section 4.7.6.3.

In this scenario, the pool lid, which protrudes approximately 5.5 inches below the transfer cask bottom flange, would not experience an impact because it would fit into the open drawer of the mating device. The impact location, therefore, is the transfer cask bottom flange. This drop simulation results in the same deceleration loads on the MPC and fuel as that previously discussed in Section 4.7.6.3. However, unique to this drop scenario, the structural integrity of the transfer cask bottom flange and pool lid are evaluated to ensure that the MPC does not break through the pool lid and drop into (or through) the mating device drawer. This drop scenario also credits a flexible, spiral wound gasket mounted on the top of the mating device for limiting fuel deceleration to the limits described in Section 4.7.6.3.

The analysis results show that the 2-inch thick bottom flange has a safety factor of 1.51 against shear failure when the limiting deceleration of 64.8 g's is assumed. This result bounds the pool lid as well because the pool lid is 5.5 inches thick. Moreover, even if the pool lid bolts were to fail by tension, the disconnected pool lid would stay in the mating device due to the vertical support provided by the overpack.

to RBG-46478 Page 25 of 32 4.7.6.7 Drop 7 - Loaded MPC Vertical Drop into HI-STORM Overpack After the transfer cask pool lid has been unbolted and removed by the mating device, a path to transfer the MPC into the overpack exists. A drop of the MPC into the overpack has been analyzed for this scenario. The acceptance criterion for this event is no breach of the MPC enclosure vessel, as justified in Section 4.7.5.2. The drop analysis (Reference 6.18) is performed using the LS-DYNA dynamic simulation computer program.

Key assumptions used in the analysis are:

1. The stainless steel used to manufacture the MPC is a bilinear, elasto-plastic material with a failure strain of 0.38 in/in.

2. The contents of the MPC (fuel basket and fuel) are modeled as a rigid mass with no energy dissipation capability.

3. The MPC lid-to-shell weld is explicitly modeled with full recognition of the discontinuity stresses that are expected to develop at the weld location. The material behavior of the weld joint is conservatively assumed to be the same as the MPC shell material.

4. The impact target is modeled as an infinite half-space of steel using the bounding overpack baseplate material properties. This conservatively bounds the actual target, which is one of two overpack designs resting atop the cask staging pad. The cask staging pad is a 36-inch (maximum) thick concrete pad (compressive strength < 4,200 psi at 28 days) founded upon a subgrade with a soil effective modulus of elasticity no greater than 28,000 psi. The HI-STORM 1OOS and HI-STORM 1OOS Version B overpack pedestals are constructed using a combination of steel and/or concrete as shown on the drawings in the HI-STORM 100 System FSAR.

5. Yield and ultimate stresses for the target are taken at room temperature.

Key input data used in the analysis are:

1. The loaded MPC weighs 90,000 lbs. This is a conservative, bounding value from Reference 6.5.

2. The MPC drop height is 25 feet. This is conservative because the height of the taller overpack design plus the mating device is just under 20 feet.

3. The impact velocity of the MPC is (2gh)1 2 = 481.5 in/sec.

The result of the dynamic simulation show that the maximum Von Mises stress in the MPC shell is 44,515 psi, indicating that the shell is plastically deformed. However, the calculated stress is well below the ultimate stress of the material (64,000 psi). The maximum plastic strain is less than 21.25%, which is below the failure strain of 38%. The MPC shell is deformed most at the bottom because of impact-induced local bending. Therefore, the uno breach" acceptance criterion is met and this hypothetical drop has acceptable consequences.

to RBG-46478 Page 26 of 32 4.8 SummarV The FBCHC is adequately designed and has been appropriately maintained, inspected and tested to provide reasonable assurance that the cask handling loads can be safely handled with a load drop being a very unlikely event. We will ensure cask loading procedures restrict loaded transfer cask lift height over cask pool lower shelf, cask pool upper shelf, cask washdown area, and mating device to values less than or equal to the values used in the drop analyses.

Evaluations of hypothetical drop events during spent fuel storage cask component lifting and handling resulted in no unacceptable consequences for the plant, the MPC, the transfer cask, the cask contents, and the public.

5.0 REGULATORY ANALYSIS

The hypothetical load drops associated with using the FBCHC for dry spent fuel cask handling require the use of an impact limiter in certain locations to ensure the consequences of the drop are acceptable. As such, they create a malfunction of an SCC with a different result than previously evaluated in the USAR. Furthermore, the cask drop onto the cask pool upper shelf resulting in a secondary impact against the pool wall is an accident of a different type than previously evaluated in the USAR. Thus, a 10 CFR 50.59 evaluation for the procedure changes needed to implement dry spent fuel storage at RBS would result in the need for a license amendment. In addition, Entergy's response to NRC Bulletin 96-02 for River Bend Station includes a statement that a license amendment request would be submitted if an activity creates a potential load drop accident not previously evaluated in the FSAR. While its consequences are clearly bounded by a previously evaluated accident, the drop of an MPC lid has not previously been evaluated in the FSAR. For these reasons, NRC approval of this amendment request is requested to support implementation of dry storage cask loading activities inside the Part 50 facility at RBS.

5.1 Applicable Regulatory Requirements/Criteria The USAR and plant procedure changes required to implement dry spent fuel storage at RBS have been evaluated to determine whether applicable requirements and regulations continue to be met.

Entergy has determined that the proposed amendment does not require any exemptions or relief from regulatory requirements and do not affect conformance with any 10 CFR 50, Appendix A General Design Criterion (GDC) differently than described in the USAR.

NRC regulatory guidance applicable to this proposed amendment includes NUREG-0612,

'Control of Heavy Loads at Nuclear Power Plants" (Reference 6.1); associated Generic Letters80-113, 81-07, 83-42, and 85-11; NUREG-0554, 'Single Failure Proof Cranes" (Reference 6.2);

and ANSI N14.6, "American National Standard for Radioactive Material - Lifting Devices for Shipping Containers Weighing 10,000 lbs (4500 kg) or More" (Reference 6.8). NUREG-0612 and its associated generic letters required Part 50 licensees and holders of construction permits to demonstrate to the NRC how the criteria in NUREG-0612 are met for the handling of heavy loads. NUREG-0612 was issued in July 1980 and GL 80-113 was issued in December 1980 as part of the resolution of Generic Technical Activity A-36, "Control of Heavy Loads near Spent Fuel."

to RBG-46478 Page 27 of 32 Appendix I to the River Bend Station Supplemental Safety Evaluation Report (Reference 6.19) provides NRC's approval of River Bend's response to NUREG-0612 and the associated generic letters. At that time, the River Bend licensing basis for spent fuel cask handling addressed only a generic, 125-ton shipping cask. The presumption was that the shipping cask would be certified under 10 CFR 71 and, as such, would be qualified to withstand a 9 meter (30 ft.) drop without radioactive release or damage to the fuel. Therefore, no analysis of the consequences of a shipping cask drop on the cask or cask contents was performed as part of Part 50 licensing for RBS.

The Part 50 licensing basis includes qualification of the RBS Fuel Building for handling a 125-ton shipping cask in the area of the cask pool, cask pit, and outdoor crane structure. This licensing basis remains bounding for the handling of the 125-ton spent fuel transfer cask (HI-TRAC 125D ) as it relates to drop effects on the Part 50 structure. However, the HI-TRAC 125D" transfer cask is not a 10 CFR 71-certified transport package. Therefore, because the FBCHC is not going to be upgraded to single-failure-proof, the spent fuel storage canister (MPC-68), the fuel inside, and the transfer cask require evaluation for certain hypothetical drops postulated based on the guidance in NUREG-0612.

NRC Bulletin 96-02 (Reference 6.3) was issued in April 1996 in response to a heavy load handling issue that arose in the industry pertaining to spent fuel cask handling. This Bulletin reiterated to licensees NRC's expectations regarding heavy load control established in NUREG-0612. Bulletin 96-02 states, in part: "For licensees planning to perform activities involving the handling of heavy loads over spent fuel, fuel in the reactor core, or safety-related equipment while the reactor is at power... and that involve a potential load drop accident that has not been previously evaluated in the FSAR, submit a license amendment request in advance..." RBS responded to Bulletin 96-02 in August 1996 (Reference 6.20) and the NRC approved that response in May 1998 (Reference 6.21).

Section 5.5 of Appendix A to the HI-STORM 100 System" Certificate of Compliance (CoC) states: "For lifting of the loaded TRANSFER CASK or OVERPACK using devices which are integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply."

Because the FBCHC is integral to the RBS Fuel Building, this amendment request is governed by the regulations in 10 CFR 50, consistent with that CoC provision. However, the acceptance criteria for verifying the integrity of the spent fuel, the spent fuel transfer cask, and the multi-purpose canister are drawn from the 10 CFR 72 cask licensing basis documents. The cask system being used at RBS under a Part 72 general license is certified under 10 CFR 72, Subpart L. The CoC and FSAR for the HI-STORM 100 System" provide the design criteria for verifying protection of the cask components and fuel, which have been previously approved by the NRC. Absent applicable acceptance criteria in 10 CFR 50 for these components and fuel, the acceptance criteria developed under 10 CFR 72 during cask licensing were chosen for use in evaluating the consequences of postulated load drops related to cask handling in the Fuel Building and the adjacent outdoor crane structure.

5.2 No Significant Hazards Consideration The proposed amendment will revise the Updated Safety Analysis Report pertaining to spent fuel management, ISFSI operations, heavy load handling, and associated drop event analyses.

The proposed amendment will add an overview of dry storage cask loading operations and a discussion of the transfer cask, MPC, and MPC lid drop events to augment the existing USAR to RBG-46478 Page 28 of 32 discussion of the shipping cask drop event. The changes to the USAR will be made after approval of this amendment request.

This proposed amendment has been evaluated in accordance with 10 CFR 50.92(c). The amendment shall be deemed to involve a no significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment introduces no new mode of plant operations and does not affect Structures, Systems, and Components (SSCs) associated with power production, accident mitigation, or safe plant shutdown. The SSCs affected by this proposed amendment are the Fuel Building Cask Handling Crane (FBCHC), the spent fuel storage canister, the spent fuel transfer cask, and the spent fuel inside the storage canister. A hypothetical 30 ft. drop of a loaded spent fuel shipping cask from the FBCHC is part of the River Bend Station (RBS) current licensing basis. With the proposed spent fuel transfer cask design and procedural changes implemented, the FCHC will be used to lift and handle a fuel-loaded spent fuel transfer cask of the same maximum weight and approximately the same dimensions as previously evaluated in the RBS USAR. The proposed amendment involves the use of redundant crane rigging during most lateral moves with a loaded spent fuel transfer cask, which provides temporary single-failure proof design features to provide protection against an uncontrolled lowering of the load or load drop. In those cases where the spent fuel transfer cask is not supported with redundant rigging, certain hypothetical, non-mechanistic load drops have been postulated and evaluated, with due consideration of the use of impact limiters in some locations.

With this amendment, the probability of a loaded spent fuel transfer cask drop is actually less likely than previously evaluated because the capacity of the spent fuel multi-purpose canister (68 fuel assemblies) is larger than the capacity of the shipping cask described in the current licensing basis (18 fuel assemblies), which means that fewer casks will be required to be loaded, lifted, and handled for a given population of spent fuel assemblies. The consequences of the hypothetical spent fuel transfer cask load drops on plant SSCs are bounded by those previously evaluated for a shipping cask.

That is, there is no significant damage to the Fuel Building structure or any SSCs used for safe plant shutdown. New analyses of hypothetical drops of a loaded transfer cask or canister confirm that there is no release of radioactive material from the storage canister and no unacceptable damage to the fuel, MPC, or transfer cask.

The hypothetical drop of a spent fuel canister lid into an open, fuel-filled canister in the spent fuel pool during fuel loading has also been evaluated. Again, this hypothetical accident is no more likely to occur than previously considered due to the higher capacity of the spent fuel transfer cask over the spent fuel shipping cask (i.e., fewer casks will need to be loaded for a given number of fuel assemblies). The radiological consequences of this event due to the potential damage of spent fuel assemblies in the canister onto which the lid could be dropped have been evaluated. While more total fuel to RBG-46478 Page 29 of 32 assemblies could potentially be damaged from a spent fuel canister lid drop compared to that assumed for the fuel handling accident described in the RBS current licensing basis, the significantly longer decay time of the spent fuel assemblies in the canister results in a much smaller source term, such that the existing fuel handling accident described in USAR Section 15.7.4 provides a bounding evaluation for the radiological consequences MPC lid drop. There is no rearrangement of the fuel or deformation of the fuel basket in the canister such that a critical geometry is created as a result of an MPC lid drop.

The likelihood of a spent fuel canister lid drop due to the failure of a crane component due to overload is very unlikely because the rated load of the crane (250,000 Ibs) is approximately 16 times the weight of components lifted to install the canister lid.

2. Will operation of the facility in accordance with this proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment introduces no new mode of plant operations and does not affect SSCs associated with power production, accident mitigation, or safe plant shutdown. The SSCs affected by this proposed amendment are the non-single-failure-proof FBCHC, the spent fuel canister, the spent fuel transfer cask, and the spent fuel inside the canister. The design function of the FBCHC is not changed. The proposed amendment does not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators. The proposed amendment creates a new initiator of two accidents previously evaluated and caused by the non-mechanistic single failure of a component in the FBCHC load path.

The current licensing basis accidents for which new initiators are created by this amendment are the spent fuel shipping cask drop and the fuel handling accident. The RBS current licensing basis includes evaluations of the consequences of a spent fuel shipping cask drop and the consequences of the drop of a spent fuel assembly into the reactor core shortly after shutdown and reactor head removal. The new initiators include the drop of a spent fuel transfer cask of the same maximum weight and approximately the same dimensions as the shipping cask, and the drop of a spent fuel canister lid into an open, fuel filled canister in the spent fuel pool. Both of these new initiators create hypothetical accidents that are comparable in consequences to those previously evaluated. For the drop of a spent fuel transfer cask, the consequences are bounded by the current licensing basis analysis of the spent fuel shipping cask drop. That is, there is no significant damage to the Fuel Building structure or any SSCs used for safe plant shutdown, and there is no release of radioactive material. New analyses of the drop of a loaded transfer cask confirm that there is no release of radioactive material from the storage canister and no unacceptable damage to the fuel, MPC, or transfer cask.

For the drop of the spent fuel canister lid, the significantly longer decay time of the spent fuel assemblies in the canister compared to a spent fuel assembly in a recently shutdown reactor results in doses to the public that are less than the previously analyzed fuel handling accident. There is no rearrangement of the fuel in the canister such that a critical geometry is created as a result of an MPC lid drop.

Attachment I to RBG46478 Page 30 of 32

3. Will operation of the facility in accordance with this proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment introduces no new mode of plant operations and does not affect SSCs associated with power production, accident mitigation, or safe plant shutdown. The SSCs affected by this proposed amendment are the non-single-failure-proof FBCHC, the spent fuel storage canister, the spent fuel transfer cask, and the spent fuel inside the canister. Therefore, this amendment does not affect the reactor or fuel during power operations, the reactor coolant pressure boundary, or primary or secondary containment. All activities associated with this amendment occur in the Fuel Building or in the adjacent outdoor truck bay area. The design function of the FBCHC is not changed. The proposed changes to plant operating procedures needed to implement dry spent fuel storage at RBS do not exceed or alter a design basis or safety limit associated with plant operation, accident mitigation, or safe shutdown. The FBCHC is used to lift and handle the spent fuel canister lid over spent fuel in the canister while in the spent fuel pool, and to lift and handle the spent fuel transfer cask, both when it is empty and after it is loaded with spent fuel in the spent fuel pool.

This proposed amendment results in a net safety benefit because a larger capacity cask is being used to move spent fuel out of the spent fuel pool that was previously evaluated (68 fuel assemblies versus 18 fuel assemblies), while maintaining the same maximum analyzed cask weight described in the USAR. This yields fewer casks to be loaded, fewer heavy load lifts, and, as a result, fewer opportunities for events such as load drops. Because the maximum weight of the loaded spent fuel transfer cask is the same as that assumed for the shipping cask and for which the FBCHC was designed, all design safety margins for use of the FBCHC remain unchanged. The rated capacity of the FBCHC is approximately 16 times that of components lifted to place the spent fuel canister lid, yielding significant safety margins for that particular lift.

Based on the above review, it is concluded that: (1)the proposed amendment does not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed amendment; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Impact Statement.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

to RBG-46478 Page 31 of 32

6.0 REFERENCES

6.1 NUREG-0612, 'Control of Heavy Loads at Nuclear Power Plants," USNRC, July 1980.

6.2 NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants," USNRC, May 1979.

6.3 USNRC Bulletin 96-02, "Movement of Heavy loads Over Spent Fuel, Over Fuel in the Reactor Core, or over Safety-Related Equipment," April 1996.

6.4 HI-STORM 100 10 CFR 72 Certificate of Compliance 72-1014, Amendment 1.

6.5 HI-STORM 100 System Final Safety Analysis Report, Revision 2.

6.6 Drawing EC-62-AM, "Foundation Plan & Details, Cask Handling Area, Fuel Building,"

Revision 2.

6.7 "Severe Weather Operation," RBS Abnormal Procedure AOP-0029, Rev. 14B.

6.8 ANSI N14.6, "American National Standards for Radioactive Material Lifting Devices for Shipping Containers Weighing 10,000 Ibs (4500 kg) or More," 1993.

6.9 Holtec International Report No. HI-2043304, "Dynamic Analysis of Redundant Link System Subsequent to Loss of Primary Load Path in Cask Pit Crane," Revision 0.

6.10 U.S. NRC Safety Evaluation Report Related to License Amendments 142 and 139 for 10 CFR 50 Operating Licenses DPR-39 and DPR-48, respectively, Dockets 50-295 and 50-305, Zion Nuclear Power Station, Commonwealth Edison Company, February 23, 1993.

6.11 Holtec International Report No. HI-2043275, "Analysis of MPC Lid Drop during Cask Loading at River Bend," Revision 0.

6.12 Holtec International Report No. HI-2043312, "Analysis of a Postulated MPC Lid Drop Event over the HI-TRAC Transfer Cask Top Flange," Revision 0.

6.13 "The Effect of Liquids on the Dynamic Motion of Immersed Solids," R.J. Fritz, ASME Journal of Engineering for Industry, February 1972.

6.14 Holtec Position Paper DS-246, "Seismic Analysis of Submerged Bodies," Revision 1.

6.15 Holtec International Report No. HI-2022956, "HI-TRAC Impact Limiter Qualification at River Bend," Revision 1.

6.16 "Design of Structures for Missile Impact," Topical Report BC-TOP-9A, Bechtel Power Corporation, Revision 2.

6.17 Holtec International Report No. HI-2043278, "Evaluation of Postulated HI-TRAC 125D Transfer Cask Drop Accidents at the River Bend Station," Revision 2.

to RBG-46478 Page 32 of 32 6.18 Holtec International Report No. HI-2043276, 'Analysis of a Postulated MPC Drop Accident during MPC Transfer Operation," Revision 0.

6.19 Supplemental Safety Evaluation Report for River Bend Station, EG&G Idaho for USNRC, Appendix I, January 1985.

6.20 Entergy Operations' Response to NRC Bulletin 96-02 for River Bend Station, dated August 29, 1996.

6.21 USNRC letter to Mr. John R. McGaha, Jr., dated May 13, 1998, 'Completion of Licensing Action for NRC Bulletin 96-02, "Movement of Heavy Loads over Fuel in the Reactor Core, or over Safety-Related Equipment, dated April 11, 1996, for River Bend Station, Unit 1."

Appendix A to Attachment 1 to RGB-46478 I Cask Handling Operational Sequence

Appendix A to Attachment 1 to RBG-46478 Page 1 of 2 Cask Handling Operational Sequence Refer to Figure 1 in Attachment 2 to this submittal for cask locations and Section 4.7 of this attachment for component dimensions and elevations. A transfer cask bottom elevation of approximately I 14'is assumed to permit engagement of redundant rigging with the lift yoke.

"IL" means an impact limiter is in place to protect the dropped component and the target, and "no IL" means no impact limiter. "PD" means postulated drop(s) for loads that are not bounded by drop analysis in accordance with the existing 10 CFR 50 license as discussed in Section 4.7.6

. Drop distances, where cited, are approximate. See the detailed analysis section for the actual drop distances evaluated.

This sequence is provided as information only and is intended to reflect a typical transfer.

Variance from this sequence may be required as conditions dictate.

1. Empty multi-purpose canister (MPC) located outdoors

2. Open Fuel Building door (no fuel movement permitted inside)

3. Lift MPC to point where bottom of MPC is approx. 117.5 ft. elevation

4. Move MPC laterally through Fuel Building door to point above cask pit (Impact Limiter (IL) and empty transfer cask (HI-TRAC), previously installed in cask pit. 4.5 ft empty MPC vertical drop onto cask pit north wall-no IL

5. Lower MPC into HI-TRAC transfer cask and close Fuel Building door.

6. Engage Lift Yoke to HI-TRAC transfer cask

7. Lift empty HI-TRAC / MPC to point where bottom of HI-TRAC is approx. I 14'-7" ft.

elevation

8. Move empty HI-TRAC / MPC laterally to point above upper shelf in cask pool

9. Lower HI-TRAC / MPC onto cask pool upper shelf, approx. 93'-0"

10. Disengage lift yoke from HI-TRAC transfer cask

11. Attach lift yoke extension and attach lift yoke

12. Engage lift yoke to empty HI-TRAC transfer cask

13. Lift empty HI-TRAC / MPC to approx. 93'-3" elevation (3 inches above cask pool upper shelf)

14. Move empty HI-TRAC / MPC laterally to a point above cask pool lower shelf PD-- < 1 ft empty HI-TRAC MPC drop onto corner of cask pool upper shelf-no IL

15. Lower empty HI-TRAC / MPC onto lower shelf on impact limiter

16. Detach and stow lift yoke and lift yoke extension

17. Open Cask Pool Gate

18. Load fuel into MPC

19. Close Cask Pool Gate

20. Rig MPC lid with drain tube installed

21. Move MPC lid into place above loaded HI-TRAC / MPC PD - 27 ft. drop of MPC lid onto MPC basket with fuel loaded

22. Lower MPC lid, install in loaded MPC, and disengage lid rigging

23. Attach lift yoke extension and lift yoke

24. Engage lift yoke with extension to HI-TRAC transfer cask

Appendix A to Attachment 1 to RBG-46478 Page 2 of 2

25. Lift loaded HI-TRAC / MPC to approx 93'-3" ft. elevation (3" above cask pool upper shelf)

PD-- 22 ft. loaded cask vertical drop on to cask pool lower shelf- IL

26. Move loaded HI-TRAC / MPC laterally to point above cask pool upper shelf PD - (a): < 1 ft. loaded cask drop onto corner of cask pool upper shelf-no IL, and (b): <

1 ft. loaded cask vertical drop onto cask pool upper shelf- no IL

27. Lower loaded HI-TRAC / MPC onto cask pool upper shelf

28. Disengage lift yoke and extension

29. Engage lift yoke without extension to HI-TRAC transfer cask

30. Lift loaded HI-TRAC / MPC to approx. 93'-3" elevation (3" above cask pool upper shelf)

PD -- < 1 ft. loaded cask drop onto cask pool with upper shelf- no IL

31. Move loaded HI-TRAC / MPC laterally to a point above cask pool lower shelf PD - (a): < 1 ft. loaded cask drop onto corner of cask pool upper shelf (no IL) and (b): 22 ft. loaded cask vertical drop onto cask pool lower shelf- IL

32. Raise loaded HI-TRAC / MPC to approx. 114'-1" elevation.

PD - 42.5 ft. loaded cask vertical drop onto cask pool lower shelf- IL

33. Engage redundant rigging

34. Move cask laterally at approx. 113'-1 1" elevation to point above cask pit

35. Raise loaded HI-TRAC / MPC to approx I 14'-1" and disengage redundant rigging PD - 17.5 ft. loaded cask vertical drop into cask pit - IL

36. Lower loaded HI-TRAC / MPC into cask pit on IL

37. Disengage lift yoke from HI-TRAC transfer cask

38. Finish MPC preparation and install HI-TRAC top lid

39. Engage lift yoke to HI-TRAC transfer cask

40. Lift loaded HI-TRAC / MPC to approx 114'-1"elevation PD - 17.5 ft loaded cask vertical drop into cask pit - IL

41. Engage redundant rigging

42. Move loaded HI-TRAC / MPC laterally at approx. I 13'-1 " elevation outdoors to point above empty HI-STORM with mating device installed

43. Raise loaded HI-TRAC / MPC to approx 1 4'-1" elevation and disengage redundant rigging PD -- < 1 ft loaded HI-TRAC / MPC vertical drop onto mating device - drop height varies with overpack model used and whether an overpack spacer ring or cribbing for the IOOS Version B overpack is used - Spiral wound gasket limits impact

44. Remove HI-TRAC pool lid PD -- 18.5 to 19.5 ft. loaded MPC drop into empty overpack - drop height varies with overpack model used and whether an overpack spacer ring or cribbing for the 1OOS Version B overpack is used.

45. Download MPC into HI-STORM

46. Remove empty HI-TRAC and mating device

47. Install overpack lid and transport loaded overpack / MPC to ISFSI RBG-46478 Figures

I__

IT

__ ___ _LL. I -- -F Z '

/l MAXUP POSITI~)r,

-LIFT YOKE F'JELEL~r.EXTENSION FUEL ELD TRUCK SAY / '.

- TRANSFER CASK YOKE TPANSPOPTER ~(MAPC NOT SHOWN4)/-ITYK

/o =

TPAkNSPO°TE - ' f a5Ur a 'z LINK MATING DEvICE OPF/-AjIPOLMPC LID EL. 113L-9 /4 -13'-0 EL S PI-STOEM OVER- ..

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UPRSHELF

- . _aK ,

EL.. 93.0 4 *.1... ___ ___ ___ EL. 23S CASK PIT PEDESTAL4 IMPACT LLTRlTER 26 1/4 THICK (TYPICAL)

Entergy Operations, Inc.

FIGURE 1 ELEVATION OF R8S FUEL BUILDING AND TRUCK BAY FO2 SPENT FUEL STORAGE CASK LOADING

Entergy Operations, Inc.

FIGURE 2 SECTION VIE'A DRY & WET IMPACT LIMITER ASSEMBLY J.

UPPER CRANE LINKS (WELDED TO CASK CRANE MAIN LOAD GIRDER)

".7

Z: Entergy Operations, Inc.

FIGURE 3 REDUNDANT CRANE RIGGING AND LIFT YOKE ASSEMBLY

Attachment 3 RBG-46478 List of Regulatory Commitments

Attachment 3 RBG46478 Page 1 of 2 List of Regulatory Commitments This table identifies actions discussed in this letterfor which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

TYPE SCHEDULED COMMITMENT (Check One) COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)

Continuing inspection is in accordance with the RBS Preventative Maintenance Program for slings Prior to first and special lifting devices. This will be X cask loading accomplished on a frequency in accordance with campaign ASME B30.9 and ANSI N14.6.

All critical lifts of the MPC, MPC Lid, HI-TRAC, HI- Prior to first TRAC Top and Pool Lids, containing nuclear fuel X cask loading or over nuclear fuel, will be made using the Main campaign

Hook, Ensure appropriately designed impact limiters are Prior to first installed on the cask pool lower shelf and cask X cask loading washdown area prior to cask lifts in these areas campaign Ensure cask loading procedures match cask Prior to first loading evolutions described in this LAR X cask loading campaign RBS will retest and qualify the crane for use in temperatures below 700 F as warranted to support Prior to use in cask loading plans. The results from successful X temperatures retesting will be incorporated into site procedures below 70mF in the form of revised minimum temperature limitations.

Ensure cask loading procedures include instructions to check for severe weather prior to commencing outdoor cask handling operations. Prior to first Evaluation and modify, as necessary, severe X cask loading weather procedures to address cask handling campaign operations per this LAR, particularly operations when the loaded cask is suspended from the outdoor cask handling crane superstructure We will ensure that cask loading procedures include visual confirmation that redundant rigging is properly engaged and slack is removed from Prior to first redundant rigging slings prior to horizontal X cask loading movement whenever a loaded cask is moved campaign horizontally at its maximum suspended elevation.

Attachment 3 RBG-46478 Page 2 of 2 We will ensure cask loading procedures restrict loaded transfer cask lift height over cask pool Prior to first lower shelf, cask pool upper shelf, cask washdown X cask loading area, and mating device to values less than or campaign equal to the values used in the drop analyses.

Provide appropriate personnel training to reflect Prior to first operating procedures and limits per this LAR X cask loading campaign Personnel performing the engagement of redundant rigging will be trained to perform this evolution. Prior to first X cask loading These visual verifications will be documented in campaign the controlling procedure(s).

New Dry Fuel Storage (DFS) Procedures, which control activities involving FBCHC operation, that will be written include:

1. DFS-0002, Dry Fuel Cask Loading

2. DFS-0003, Dry Cask Transport and Prior to first Storage X cask loading

3. DFS-0004, MPC Unload Procedure campaign

4. DFS-0005, DFS Rigging Plan

5. DFS-0100, FB 113-04 Door (this is the door opening to the outside Cask Crane Structure)

The trained Person In Charge (PIC), with responsibility for the lift, and the trained Cask Crane Operator, with responsibility for crane operation, will establish the crane hoist and travel speeds for loaded cask lifts within the following procedural constraints:

Use Crane uinching speed" at 0.5 fpm Prior to first where appropriate. "inching speed may be X cask loading used, at the flagman's (as the PlC's campaign designee) discretion or at the PlC's discretion, for lift phases where precise load positioning is appropriate.

Do not cycle the cask crane by "jogging" or Uplugging". The PIC and the crane operator have been trained to use the crane's "inching speed" and not use "jogging" or "plugging" of the crane.

Attachment 4 RBG-46478 Responses to RAls for LAR 2004-26

- to RBG-46478 1 of 21 Responses to RAls for LAR 2004-26 RAI from Plant Systems Group

1. The Fuel Building Cask Handling Crane (FBCHC) is described in Section 3.1 of the license amendment request, dated March 8, 2005, as a "non-safety-related, commercial grade crane, " and "a bridge-and-trolley design that is not single-failure-proof." NUREG-0612 section 5.1.4 states that to provide assurance that the evaluation criteria of Section 5.1 are met one of two options should be met in addition to satisfying the guidelines of section 5.1.1. Please indicate which of the two options apply to the use of the FBCHC during Dry Spent Fuel Cask Loading Operations, and discuss in detail how the requirements set forth in the option chosen are met.

Response

As part of cask loading operations at RBS, only one heavy load is ever suspended above irradiated fuel in the canister in the cask pool - the MPC lid. LAR Attachment 1, Section 4.7.3 provides the reasoning for choosing NUREG-0612 Section 5.1.4, "Reactor Building -

BWR," as the applicable section for evaluating the MPC lid handling activity.

Section 5.1.4 of NUREG-0612 offers two options to provide assurance that the evaluation criteria of Section 5.1 are met. Option 2, which requires evaluation of the effects of heavy load drops, was chosen for use in the LAR, as discussed in LAR Attachment 1, Section 4.7.3. Drop evaluations performed in accordance with Option 2 of Section 5.1.4 are*

required to be performed using the evaluation criteria of NUREG-0612, Section 5.1 and the guidance in NUREG-0612, Appendix A.

LAR Attachment 1, Sections 4.7.4 through 4.7.6 provide detailed discussions of the hypothetical drops of the MPC lid into the fuel-loaded canister and drops the loaded HI-TRAC transfer cask in several different locations in the Fuel Building. The guidance of NUREG-0612, Appendix A was considered, as applicable, in each of the drop analyses as detailed in the LAR. The specific comparison of the results of the drop analyses against the criteria in NUREG-0612 Section 5.1 is provided below.

NUREG-0612, Section 5.1, Criterion I Releases of radioactive material that may result from damage to spent fuel based on calculations involving accidental dropping of a postulated heavy load produce doses that are well within 10 CFR Part 100 limits of 300 rem thyroid, 25 rem whole body (analyses should show that doses are equal to or less than X of Part 100 limits).

LAR Attachment 1, Section 4.7.4.3 describes how the design basis fuel handling accident described in RBS USAR Section 15.7.4 bounds the potential dose from a drop of the MPC lid into the fuel-loaded MPC, based on a acceptance criterion of 25% of the Part 100 dose limits. Based on the potential damage of up to four fuel assemblies due to an MPC lid drop, a factor of safety of 170 is calculated.

to RBG-46478 2 of 21 LAR Attachment 1, Section 4.7.6 describes the results of the various postulated drops of the fuel-loaded transfer cask. In every case, no radiological consequences result, either from plant structures, systems, and components, or from the material inside the transfer cask.

Therefore, this criterion is met.

NUREG-0612, Section 5.1, Criterion II Damage to fuel and fuel storage racks based on calculations involving accidental dropping of a postulated heavy load does not result in a configuration of the fuel such that keff is larger than 0.95.

As described in LAR Attachment A, Sections 4.7.4 and 4.7.6, neither the MPC lid drop nor the various transfer cask drops result in damage to the fuel assemblies such that re-configuration of the fuel into an unanalyzed geometry and potential criticality are a concern.

The fuel remains in an analyzed geometry in all cases, with keff less than 0.95 as described in Chapter 6 of the HI-STORM 100 FSAR.

Therefore, this criterion is met.

NUREG-0612, Section 5.1, Criterion IlIl Damage to the reactor vessel or the spent fuel pool based on calculations of damage following an accidental dropping of a postulated heavy load is limited so as not to result in water leakage that could uncover the fuel (makeup water provided to overcome leakage should be from a borated source of adequate concentration if the water lost is being borated).

The drops evaluated in the scope of the LAR occur in the Fuel Building cask pool after fuel loading into the MPC has been completed. The cask pool does not contain spent fuel racks and is not connected to the spent fuel pool once the MPC is loaded and the gate between the cask pool and spent fuel pool is installed. Lifts of heavy loads during cask loading operations do not occur in the vicinity of the reactor vessel.

Therefore, this criterion is met.

NUREG-0612, Section 5.1. Criterion IV Damage to equipment in redundant or dual safe shutdown paths, based on calculations assuming the accidental dropping of a postulated heavy load, will be limited so as not to result in loss of required safe shutdown functions.

Heavy load lifts required for cask loading operations occur only in the cask pool and outdoor crane structure areas. The only safety-related equipment over which heavy loads are suspended is cables and piping located in a pipe tunnel beneath the cask pit. The RBS current licensing basis (described in USAR Section 9.1.4.3) includes an evaluation of the dropping of a bounding heavy load into the cask pit. No damage to the safety-related cable or piping in the pipe tunnel occurs as a result of this drop.

to RBG-46478 3 of 21 Therefore, this criterion is met.

2. In Section 4.0 of attachment I of the LAR it is stated that the classification of the FBCHC is being upgraded to 'Quality Assurance Program Applicable" in the RBS configuration management control systems. Please identify the difference in the requirements for equipment that is designated safety-related as opposed to "Quality Assurance Program Applicable."

Response

There is no difference in QA requirements between Quality Assurance Program Applicable (QAPA) and Safety Related designations for changes to the FBCHC including recent seismic analysis and required modifications. The use of the QAPA designation in lieu of Safety Related is appropriate because the crane and outside supporting structure were purchased/fabricated/constructed as non-safety related. The FBCHC is currently designated as QAPA, and will be treated as safety related in all respects.

3. In section 4.4 of attachment 1 of the LAR submittal it is stated that the load test performed included testing of the redundant rigging appurtenance design modification, which is relied upon to preclude having to postulate load drops during lateral moves of the crane.

Describe how testing of the redundant rigging appurtenance was performed to verify the load carrying capability of the redundant crane links, and discuss in detail the inspection that will be performed, and criteria to be met to assure proper application of the redundant rigging prior to its use.

Response

The upper crane links were load tested to the same intensity (125% of the rated load) and under the same conditions as the crane. Following the load test, NDE surface examination was performed on welds made under the modification that installed the links, as well as parts of the link plates below the tops of the pins and the pins themselves.

The redundant link components were shop tested in accordance with the Holtec purchase specification. Requirements for shop testing and re-certifications are consistent with ANSI N14.6. Slings were shop tested at the sling fabrication/test facility in accordance with ASME B30.9.

Continuing inspection is in accordance with the RBS Preventative Maintenance Program for slings and special lifting devices. This will be accomplished on a frequency in accordance with ASME B30.9 and ANSI N14.6.

The redundant link slings are inspected for damage and wear prior to use.

4. In section 4.4 of attachment 1 of the LAR submittal it is stated that load testing of the indoor portion of the FBCHC were performed during initial construction, and because the load-bearing components of the inside portion of the crane structure have not been modified since original installation, another 125% load test is not required. Inthe NUREG-0612 and NUREG-0554 comparison matrix provided by the applicant it is stated that the actual indoor test lift was

- - . to RBG-46478 4 of 21 performed in September 1983, and the FBCHC outdoor test lift was performed at a minimum temperature of 74.5 0F. The applicant then states, in the notes, that cask loading procedures will require an ambient temperature > 70 OF.

a) In NUREG-0554, Section 2.4 it is stated that in regards to the cold proof testing that 'If the desired minimum operating temperature cannot be achieved during the test, the minimum operating temperature should be that of the test until the crane is retested at a lower temperature." Please provide the basis for selection of the minimum ambient temperature of 70 OF to be used in the procedures.

Response

The use of a minimum operating temperature of 700F is based on the discussion of NUREG-0554 requirements given in Appendix C of NUREG-0612. The section titled "Implementation of NUREG-0554 for Operating Plants"on page C-2, lists alternatives that may be applied when upgrading an existing crane (in lieu of complying with certain recommendations of the NUREG-0554). Item (2) states that the upgrade requirement for coldproof testing was omitted because the minimum ambient temperatures in operating plants was 70 0F, which is greater than the nil ductility transition temperature (NDTT) listed in (ASME l1l, Subsections) NC-2300 and ND-2300.

RBS will retest and qualify the crane for use in temperatures below 700 F as warranted to support cask loading plans because operations of the crane are not limited to areas inside the operating plant structures. The results from successful retesting will be incorporated into site procedures in the form of revised minimum temperature limitations.

b) When the cold proof testing was performed for the indoor portion of the crane during the original installation of the crane, at what temperature was the test performed and what minimum temperature of operation is currently used for the indoor portion of the crane.

Response

The pre-operational testing of the crane was performed prior to turnover of responsibility from the constructor to RBS. Consequently, temperatures from the test are not available.

However, RBS dry cask procedures limit the minimum ambient temperature inside the Fuel Building to >70 0F during cask operations. As stated above, RBS will retest and qualify the crane for use in temperatures below 700F as warranted to support cask loading plans. The results from successful retesting will be incorporated into site procedures in the form of revised minimum temperature limitations. This applies to both inside and outside the building operations.

c) In NUREG-0554, Section 2.4 it is stated that following the proof test "the nondestructive examination of critical areas should be repeated at 4-year intervals or less." Please indicate whether nondestructive tests were performed after the proof test of the indoor portion of the crane during the original installation, and describe at what interval and to what extent nondestructive examinations have been conducted for critical areas.

Attachment 4 to RBG-46478 5 of 21

Response

Review of the 1983 crane load test records indicates the crane was not used to lift loads during construction. Search of the RBS electronic database (IDEAS) provided historical evidence of inspections, including surface examination, of crane parts - every 24 months back to 1999. Earlier records were not readily available, however the regularity of these inspections provides confidence that inspections have been performed.

Note that Attachment 4 to the LAR is a comparison of RBS crane attributes to requirements for upgrading to a single failure proof crane as per NUREG-0554 rather than demonstrating compliance to the NUREG. Also note that the portions of the RBS crane to which the coldproof testing requirements apply are the ferritic load carrying members subject to brittle fracture. Therefore, the parts of the crane tested inside the fuel building in September, 1983, and outside in April, 2004, are the same.

Use of the FBCHC after construction but prior to preparations for loading dry casks has been occasional and limited to the transfer of high integrity (radwaste) containers (HICs).

The typical weight of a HIC is -50,000 lbs which is < 50% of the FBCHC rated capacity (250,000 Ibs).

Current requirements include regular, periodic inspections of load bearing members or inspections prior to use as required by governing codes and in accordance with the RBS Preventative Maintenance Program.

5. Section 4.7.2.1 of attachment 1 of the LAR discusses how the redundant crane rigging is used. In this section in reference to the successful engagement of the redundant rigging it is stated that "successful engagement of the redundant rigging is visually confirmed."

a) Please identify and discuss any other means that are used to confirm the successful engagement of the redundant rigging.

Response

The successful engagement of the redundant rigging includes both the engagement of the Link Locks of the Lower Links into the windows of the Lift Yoke and achieving tautness in the redundant slings.

Following observation that the Lower Links are properly inserted into the Lift Yoke, the Link Locks are then engaged into the Lift Yoke window openings. The Link Lock engagement in the Lift Yoke window openings is confirmed when the colored marking of the Link Locks are observed against the window opening surface. See attached Photograph #1 showing a Link Lock engaged. There are four such Link Lock engagements in the Lift Yoke, two in the Lift Yoke front strongback and two in the Lift Yoke rear strongback.

Beyond the visual observation of the Link Lock engagement in the Lift Yoke opening window, Link Lock engagement is further confirmed by the ability to remove the slack in the redundant slings when the Main Hook is lowered.

Photograph #2 shows the slings in the slacked condition prior to lowering the Main Hook.

to RBG-46478 6 of 21 Following lowering the Main Hook, the top plate of the Lower Link raises above the top of the Lift Yoke and the top of the Link Locks are against the inside top of the window in the Lift Yoke as seen in Photograph #3. The redundant slings become taut as shown in Photograph #4.

b) Explain why visual confirmation is considered sufficient.

Response

The visual indications for Link Lock engagement in the Lift Yoke window opening and achieving tautness in the redundant slings are clear and unambiguous. This is facilitated by the use of different color coatings which clarify visibility. The rigging personnel and their supervision have been trained to recognize the visual indications.

c) Inclusion of the inspection requirement in the cask loading procedures is listed in Attachment 3 to LAR in the list of regulatory commitments. Please describe what criteria will be used to verify that the redundant rigging is properly engaged, and discuss how it has incorporated in the training.

Response

The criteria for proper engagement is included in the controlling procedures and covered in the training for personnel responsible for making the lift. Specific criteria elements include:

Visual verification that the Lower Links are properly aligned and seated in the Lift Yoke, see Photograph #1. This includes the position of the painted sides of the Link Locks in the Lift Yoke window and the seating of the Lower Link Top Plate on top of the Lift Yoke.

Visual verification that the Link Locks have engaged in the Lift Yoke openings as is shown in Photograph #1. Visual verification is to be performed by both a trained rigging worker and by either the person responsible for the lift (Person In Charge or PIC) or the Cask Loading Supervisor.

Visual verification that the redundant slings are taut.

These visual verifications will be documented in the controlling procedure(s).

Personnel performing the engagement of redundant rigging will be trained to perform this evolution. The method of visually confirming that redundant rigging is "successfully engaged" is an objective in DFS Loading Operations training. The photos described above, or similar, will be used as training aids as well as oral presentations of the engagement process.

- - to RBG-46478 7 of 21 The visual indications for the Link Lock engagement in the Lift Yoke window opening and achieving tautness in the redundant slings are discussed in the response to RAI #5 a).

The color marking on the upper sides of the link locks and the looseness or sag in the redundant slings are clear and unambiguous. The rigging personnel and their supervision have been trained to recognize the visual indications.

Additionally, qualification of the redundant rigging system considered various values for pre-load and damping in the slings. See the response to question RAI #8 b).

6. In section 4.7.6.5 of attachment 1 of the LAR submittal, a drop is postulated to occur while the loaded transfer cask is suspended above the impact limiter on the pedestal at elevation 98'-1. On FSAR figure 9.1-9, this area is identified as the 'spent fuel cask washdown area," and the drawing indicates that a pipe tunnel is located on the elevation directly below the washdown area. The FSAR also states that safety-related electrical cables and one safety-related pipe are among the SSCs contained in the pipe chase area. The discussion in the LAR only discusses the impact the drop would have on the structural integrity of the transfer cask. Please discuss the impact of the postulated drop on the structural integrity of the facility and any potential impact to safety-related pipes and electrical equipment located in the pipe chase on the elevation below.

Response

An evaluation of the structural integrity of the Fuel Building structure due to a drop of the loaded transfer cask into the cask pit is not included in the LAR because this event is bounded by the 125-ton shipping cask drop already licensed as described in RBS USAR Section 9.1.4.3. A 125-ton shipping cask, assumed to fall 20' onto the concrete pedestal at elevation 95'-0", is analyzed for the effect on the Fuel Building structure as part of the River Bend Station licensing basis.

The analysis concluded that although damaged, the concrete floor of the Cask Washdown Pit (which is also the ceiling of the tunnel under it) would not suffer gross failure or collapse, in part, because the concrete is contained by metal decking. Subsequently, there is no adverse impact to safety related piping and electrical cabling in the tunnel.

7. Appendix A to attachment 1 of the LAR submittal gives a step-by-step list of the operational activities required for spent fuel pool cask handling operations when using the fuel building cask handling crane. Please specify what, if any new procedures will be required, identify what current procedures require updating, what inspections are planned, how operators will be trained and on the new equipment configurations and procedures, and what administrative controls if any will be utilized prior to or during cask handling.

- to RBG-46478 8 of 21

Response

New Dry Fuel Storage (DFS) Procedures, which control activities involving FBCHC operation, that will be written include:

1. DFS-0002, Dry Fuel Cask Loading

2. DFS-0003, Dry Cask Transport and Storage

3. DFS-0004, MPC Unload Procedure

4. DFS-0005, DFS Rigging Plan

5. DFS-0100, FB 113-04 Door (this is the door opening to the outside Cask Crane Structure)

These procedures also control the sequence of operational activities. The exact sequence may vary slightly from those shown in Attachment 1, Appendix A depending upon plant conditions.

This Appendix has been revised for clarity and to reflect further operational experience in the use of the crane. These procedures also control the use of the FBCHC Main Hook and Auxiliary Hook use. The Main Hook is used for critical lifts. All critical lifts of the MPC, MPC Lid, HI-TRAC, HI-TRAC Top and Pool Lids, containing nuclear fuel or over nuclear fuel, will be made using the Main Hook. The Auxiliary Hook is occasionally used to relocate ancillaries. An example is moving the Lift Yoke Extension from its normal storage location (which the Main Hook can not reach) to a location where it can be attached to the Main Hook. Another example is moving tool boxes, and ancillaries into the Fuel Building at the beginning of a loading campaign. The Auxiliary Hook may also be used to move component lids, within its capacity and not over nuclear fuel to position them for other evolutions.

The current procedure that requires updating is MLP-7500, Operation of the Spent Fuel Cask Crane. The trained Person In Charge (PIC), with responsibility for the lift, and the trained Cask Crane Operator, with responsibility for crane operation, will establish the crane hoist and travel speeds for loaded cask lifts within the following procedural constraints:

Use Crane "inching speed" at 0.5 fpm where appropriate. 'Inching speed may be used, at the flagman's (as the PlC's designee) discretion or at the PlC's discretion, for lift phases where precise load positioning is appropriate.

Do not cycle the cask crane by"jogging" or"plugging". The PIC and the crane operator have been trained to use the crane's "inching speed" and not use 'jogging" or "plugging" of the crane.

The manufacturer's design maximum hoisting speed is 6 fpm. The calculated maximum speed is 5.88 fpm.

The manufacturer's design maximum trolley travel speed is 50 fpm.

Inspections and Tests, performed by trained personnel, of the FBCHC include:

1. PMID-50035555-01, Periodic Crane Inspection to RBG-46478 9 of 21

2. MLP-7500, Operation of the Spent Fuel Cask Crane (Section on Frequent Inspection (those performed prior to daily use))

Training for crane operators and personnel performing Dry Fuel Storage handling will be provided in the DFS Loading Operations training program.

Administrative Controls, included in procedures, to be utilized prior to and during cask handling include:

1. Only trained personnel are permitted to operate the crane or rig or handle loads

2. Prior to FBCHC use in a loading campaign, its inspections and re-certifications must be current

3. Prior to critical lifts, the work supervisor must verify that the ambient temperature requirements are met

4. Prior to critical lifts outside of the Fuel Building, the work supervisor must verify that the current and forecasted meteorological conditions are acceptable

5. All rigging used must be in the site rigging program and inspected per materials handling procedures prior to use

6. All special lifting devices to be used must have current inspections and re-certifications

7. All critical lifts are made with the FBCHC Main Hook

8. Load Lift height limitations within the cask drop analysis basis

9. Loaded HI-TRAC horizontal travel between the Cask Pool and the Cask Pit and between the Cask Pit and the Stack-up area will utilized latched redundant crane links

10. Loaded HI-TRAC vertical lifts over the Cask Pool lower shelf and the Cask Pit will be over appropriately designed and located Impact Limiters.

11. Lifts over spent fuel must meet the surveillance requirements of STP-701-7500, Spent Fuel Cask Crane Travel-Spent and New Fuel Storage and Transfer Pools.

8. In response to the compliance to NUREG-0554 Section 4.1, item 6, given on page 20 of the attachment to the April 19, 2005 supplemental submittal, it is indicated that the crane does not have a dual load path rope reeving system, and that for most horizontal load movements, redundant rigging is engaged to lift the yoke to provide single failure protection against drops.

In section 4.7.2.1 it is stated that " After initial engagement of the lift yoke, the slings have some slack in them." In section 4.7.2.2 "Load Transfer during Postulated Failure Scenarios",

the load path slings are assumed to have no slack. The assumption is based on the use of operating administrative controls to ensure that the slings in the load path have a minimal amount of slack without carrying any significant portion of the load.

a) Please discuss how balancing and distribution of the load is accomplished with redundant rigging engaged.

to RBG-46478 10 of 21

Response

The intent is for the FBCHC main hook to carry the load, with the redundant rigging slings only carrying sufficient load to remove any visible slack in the slings.

This condition is established by:

1. Raising the FBCHC main hook and Lift Yoke (with attached HI-TRAC) sufficiently high so that the redundant rigging Link Locks can be engaged in the lift yoke window openings, which is visually verified as discussed in detail in the response to Plant Systems' RAI #5.

2. Once the redundant rigging Link Locks have been verified as engaged in the window openings in the Lift Yoke, the FBCHC main hook and lift yoke (with attached HI-TRAC) is slowly lowered until the visible slack is removed. The removal of the sling slack is readily apparent to field personnel.

b) Since the assumption that load paths sling have no slack is based solely on administrative controls which relies on visual confirmation that all slack has been removed, the possibility that some slack will remain still exist. Please discuss the sensitivity of the redundant links to changes in slackness, including results of analyses which were performed to demonstrate the impact that variation in slack would have on load transfer during postulated failures.

Response

RBS personnel recognize the importance of the redundant rigging being taut but not carrying a significant load.

Loading depends on the sling pre-load or tautness. Sling pre-load contributes to the load drop distance when the primary load path is removed. The redundant rigging qualification analysis considers various initial pre-loads in the slings; they were assumed to be taut and pre-loaded to varying degrees. Based on manufacturer's input, a mathematical expression was developed relating the stretch of the slings to the load in the slings. From this, a range of pre-loads from a value of taut but with no pre-load (0 Ibs) to about half of the full load was considered. Additionally, damping values of the redundant link system were varied to account for uncertainty in the damping introduced by the slings.

This provided the basis to establish a range of peak loads and dynamic amplification factors of the redundant sling system. Using this method, a maximum redundant link system load and a corresponding dynamic amplification factor was developed and used for qualification.

RAI from Mechanical and Civil Engineering Branch

1. It is stated that the previous seismic analysis was performed with no load on the crane hook, and a re-analysis was performed, and the analysis results indicated that the crane system is to RBG-46478 11 of 21 qualified to hold the maximum critical load during a design basis seismic event, except two welds and the welds were upgraded. Please provide information to the following questions:

(a) Define the boundary of the crane system (b) Have the beams and columns that support the crane qualified in the re-analysis?

(c) Provide the magnitude of the maximum critical load and the governing load combinations (d) Describe the re-analysis procedures (e) Describe the method(s) you used to verify that all components of the crane system are qualified except the two welds.

Response

(a) and (b) The re-analysis included the Crane Runway Girders and all building structural elements and their connections, lateral braces for the runway girders and connections, trolley main load girt and connections, trolley drive girt and connections and the trolley end trucks.

(c) The crane was evaluated for a load of 250K (125 tons) at various heights and with the trolley at various locations on the runway. The maximum interaction ratio calculated was for the trolley member connections (1.615) and the crane rope (factor of safety of 1.475).

These were evaluated for the load combination:

D + SSE + 250 k (lifted)

(d) and (e) A three dimensional finite element computer model of the crane system was developed for elastic analysis for elements discussed in (a) above, and included the SSE seismic response for the subject elevation. Prior to this analysis, the existing crane design bases considered SSE acting on the crane system but without a load on the hook.

The analysis was performed using multiple cases with the lifted load at different heights and trolley locations along the rail. The peak forces in elements, determined using response spectra analysis, were then combined with the static effects due to dead load and the lifted load to develop the maximum forces in elements. The calculation concluded that two welds were overstressed.

The crane qualification calculation identifies unacceptable configurations that require reconciliation. Modifications to the crane (welds) were designed, verified and installed under a separate documentation package.

Acceptance criteria were developed for each evaluated element. The acceptance criteria were selected as 1.5 times AISC allowable stresses, not to exceed the yield strength of the material. The ultimate strength of the crane was used as a basis for its acceptance criteria.

2. It is stated that, if outdoor cask handling is underway and weather conditions unexpectedly deteriorate rapidly, sufficient time exists to move the suspended cask to a safe location in a controlled, deliberate manner. Please provide the basis that support your conclusion of "sufficient time exists."

to RBG46478 12 of 21

Response

The outdoor handling of a loaded HI-TRAC transfer cask is a periodic, short-duration, transient operation required only during cask loading. As committed in LAR Section 4.6, outdoor cask handling will not be permitted if the weather is expected to be conducive to tornado formation. The weather expected during outdoor cask handling operations will be verified to be acceptable prior to commencing outdoor cask handling using sources such as the National Oceanic and Atmospheric Administration (NOAA) and the National Weather Service (NWS) via the Internet or other appropriate communication tools.

There is a NWS radio / alert system in the plant control room. The site procedure for severe weather requires that if a tornado or severe thunderstorm warning is issued by NWS for West Feliciana Parish, or other surrounding parishes, or if a tornado is sighted, then a plant wide announcement of the condition is made and, by procedure, any fuel handling or radioactive material transport activities underway are to be immediately brought to a safe condition and stopped. The Fuel Building door at the FBCHC is also to be closed. Weather conditions will also be monitored continuously while outdoor cask handling operations are ongoing. Therefore, a tornado touching down on site during outdoor cask handling operations with no notice whatsoever would be an unexpected and highly unlikely occurrence.

Both the HI-TRAC transfer cask and HI-STORM overpack are designed to withstand tornado winds and tornado-generated missiles. Once the transfer cask is placed atop the overpack or placed on the ground, it is in an analyzed condition. This reduces the tornado missile threat to an even shorter period of time where the HI-TRAC transfer cask is suspended outdoors from the crane main hook (i.e., in transit from the Fuel Building to a position above the HI-STORM overpack). The tomado-generated missile would also have to make its way through the crane superstructure and hit a relatively small target area in the cask structural load path to be of concern. An evaluation of the time it would take to lower the transfer cask to the ground or move it back into the Fuel Building if a tornado unexpectedly occurs has been performed as discussed below.

The Fuel Building Cask Handling Crane main hoist maximum lowering speed with the rated load on the hook is 5.9 ft/min. The maximum crane main trolley speed with the rated load on the hook is 50 ft/min. The transfer cask bottom is approximately 20 feet above the ground when suspended in the outdoor crane structure. The farthest point out from the Fuel Building that the transfer cask travels in the outdoor crane structure is approximately 40 feet. Using arbitrarily chosen nominal lowering and trolleying speeds (i.e., less than the maximum values), the estimated time it would take to lower the transfer cask to the ground or trolley the cask back into the Fuel Building in the event a tornado is observed in the area during outdoor cask handling operations is illustrated in the table below.

Hoist Lowering Lowering Time to Trolley Trolley Time to Speed Distance Lower Speed Distance Trolley (ft/min) (ft.) (min.) (ft/min) (ft.) (min.)

5 20 4 40 40 1

- to RBG-46478 13 of 21 These periods of time, plus any time required for supervisory personnel to decide to execute these maneuvers would result in the cask being placed in a safe location either inside the Fuel Building, on top of the mating device or on the ground in the outdoor crane structure in less than 15 minutes after plant entry into the associated adverse operating procedure. This time is considered sufficient to ensure the transfer cask can be moved to a safe location in a deliberate and controlled manner in the event a tornado unexpectedly occurs.

RAI from Spent Fuel Pool Organization The following information is needed to complete review of the three reports submitted in the Entergy Letter, dated July 12, 2005.

1. Holtec Report No. HI-2022956, 'HI-TRAC Impact Limiter Qualification at River Bend. Rev. 1' SFPO reviewed structural performance of the impact limiter to ensure that the cask is protected such that the maximum cask deceleration is less than 64.8 g for which the HI-TRAC transfer cask, MPC, and fuel assemblies have been demonstrated to be structurally adequate during a cask vertical drop accident.

1.1 Submit a copy of Reference 11 on relevant crush strength for the General Plastic Last-a-Foam FR-3700 polyurethane foam to demonstrate that appropriate stress-strain curve is considered in evaluating impact limiter lock-up effects.

Basis. The crush strength of the 13 pcf foam, as reported in Reference 11 and Figure 5 of the report, is markedly different from that based on the 9/92 edition of the Last-a-Form FR-3700 data sheet available to the staff. For instance, Figure 5 lists crush strengths of 819 psi and 10,936 psi for strains at 30% and 80%, respectively. However, the corresponding strengths available to the staff are 582 psi and 5,206 psi. Use of the Figure 5 crush strength will underestimate impact limiter vertical deformation, which, in turn, may render the calculation incapable of evaluating impact limiter lock-up effects.

Holtec Response:

Our copy of the last-a-foam catalog is dated 2/97 and includes not only the 9192 data sheet that is referred to by the staff in the RAI, but also includes data sheets for dynamic crush strength for fr-3700 material. The dynamic crush data that Holtec used in the simulations is attached as requested. Holtec has discussed the issue concerning The 9/92 data sheet vs the 6/96 data sheet with general plastics (Mr. Glenn Strom) and the difference in the data appears to have its roots in changes in the testing apparatus and measurement technique. In response to a direct question by Holtec to Mr. Strom concerning which data set is appropriate when the user is performing a non-linear dynamic simulation (as opposed to a simple energy balance), the general plastic response was that the use of the 6/96 data was more appropriate.

Having provided the above response, Holtec has rerun two simulations using the 9/92 data as input to provide a comparison of results and assess the effect of the two different data sets for the 13pcf density material. The following table provides the results of the additional analyses and the comparison with the results in the report.

- to RBG-46478 14 of 21 Item Cask Impact Impact Item Cask Impact Impact Deceleration Limiter Limiter Deceleration Limiter Limiter 6196 Data (g's) Crush Strain 2/92 (g's) Crush Strain used in report (in) (%) Data (in) (%)

(From Figs. 12 and 16)

Drop into 48 12.84 55.2 Drop 55.44 15.53 66.8 Cask Pit into

__ __ __ __ __ __ C ask Pit _______Pi Drop into 32.4 9.67 41.6 Drop 30.61 12.43 53.5 CWA into CWA The tabular comparison results above show that for the drop into the cask pit the use of lower crush strength (2/92 data) does cause a greater crush; however the deceleration is still acceptable. For the drop into the CWA, the impact limiter also experiences greater crush with the "2/92" crush data, but the impact limiter does not experience increased g's because the crush does not reach the region where the stiffness begins to increase.

In conclusion, the 6/96 data set is the appropriate data set to use per manufacturer's recommendation; however, the proposed impact limiters continue to perform their function even if the 2/92 data is assumed to apply.

to RBG-46478 15 of 21 Attachment (2 pages, dated 6196) from 2/97 last-a-foam catalog + 1 page 2/92 input for additional vn simulations

- . . . .I ..- - - - - l- - 1 -1..-- I .

GENERAL PLASTICS MANUrACTURING CO, P.O. BOX 9097. TACOMA WA 98409 TEL 47?3-500 117 Aw..5 LAST-A-FOAM 1 FR-3700 DYNAMIC CRUSH STRENGTH

@ 75°F, PARALLELTO RISE (PSI CREnJS DENSrmf 10 20 30 40 60 60 6 70 75 e0 3 90 74 73 74 77 aS 95 116 143 217 4 129 112 112 116 125 145 168 210 272 438 S 170 153 158 165 183 221 282 335 4S2 765 6 214 198 205 220 249 312 377 493 688 1219 71 260 247 259 281 325 419 514 686 989 1830 8 308 299 316 348 409 542 674 917 1381 2632 s 3s8 355 379 420 502 68e 859 118t 181 3667 10 tl 12 410 547 644 413 545 647 445 584 696 498 649 779 603 78S 95t 837 1107 1362 1070 143S 1784 1505 2056 2578 2365 3335 4180 4987 6930 8761 I

13 749 759 819 929 1137 16s2 2188 3189 5173 10938 14 862 e88 953 1080 1344 1981 2653 3900 6332 13508 1s 99.4 1013 1009 1253 1574 2353 3184 4724 7679 16524 16 1114 1155 1257 14A2 1827 2770 3789 5675 9237 20041 17 1254 1309 1428 1647 2105 3238 4476 6767 11031 24119 18 1402 1473 1613 1869 2410 3760 5253 8017 13089 28823 12 150 1653 18al 2110 274 4341 6130 9444 15439 34222 20 1727 1839 2023 2370 3109 4986 7116 11066 18112 40388 21 1905 2040 2251 2650 350S 5701 8222 12904 21144 47398 22 2093 22SS 2494 2s52 3937 6491 0480 14982 24588 55335 23 2292 2483 2754 3275 4404 7363 10842 17323 28425 64285 24 2501 2726 3031 3623 4911 8323 12381 19954 32753 74337 25 2722 2983 3326 3994 5459 9377 14091 22903 3759s 8558s 39 4012 4513 5096 6268 8913 163"4 25764 43504 71191 163427

1 I

6/3196 j

to RBG-46478 16 of 21

-ii -

GENERAL PLASTICS MANUFACTURINQ CO., P.O. BOX 9097, TACOMA WA 98409 TEL 20873-5000 LAST-A-FOAM FR-3700 DYNAMIC CRUSH STRENGTH 0

@ 75 F, PERPENDICULAR TO RISE (PSI)

CRUSH %

DENSITY 10 20 30 40 s0 60 65 70 75 s0 3 54 49 50 55 61 70 s0 99 135 216 4 86 8l 84 92 103 125 148 189 264 435 5 124 119 125 137 156 197 239 312 448 759 6 167 164 175 191 219 287 354 472 693 1208 7 215 215 232 252 292 395 496 673 1009 1811 8 268 272 296 322 375 522 666 s20 1407 2601 9 325 335 368 400 469 668 866 1218 1900 3619 10 387 404 447 486 573 836 1100 1571 2502 4916 11 496 516 554 625 769 1114 1490 2189 3518 7021 12 595 621 668 756 937 1371 1844 2717 4374 8797 13 705 738 795 901 1125 1664 2251 3329 5372 10889 14 825 866 934 1063 1335 1997 2717 4035 6529 13335 1s 956 1007 1088 1241 1570 2372 3247 4844 7862 16178 16 1099 1161 1255 1437 1629 2795 3849 5769 9391 19464 17 1254 1329 1438 1652 2116 3268 4529 6820 11139 23240 16 1422 1511 1638 1887 2432 3797 5295 8013 13128 27560 19 1603 1709 153 2142 2779 43 6 e155 0361 I

15302 32477 20 1797 1922 2087 2419 3159 5040 7119 10880 17929 38049 21 2007 2152 2339 2720 3574 5766 8195 12587 20796 44335 22 2231 2399 2611 3045 4028 6568 9395 14499 24012 51400 .

23 2472 2665 2904 3397 4521 7454 10729 16634 27608 59309 24 2729 2950 3218 3776 5058 8430 12209 19013 31617 68131 25 3003 3255 3556 4185 s541 9502 13847 21657 36073 77939 30 4666 5122 5630 6727 9354 16600 24891 39662 66382 144476 6/3/96 1

I to RBG-46478 17 of 21 output[24].y4 Value (psi) 0 0 0.05 300 0 1- 535 _06 _ 12 0.2 542 I 0.65 0.3 582 07 _ __. 1973 0.-4 651 0.75 _2938 0.5 791 0850 0.6 1111 0.85 7474 0.65 1427 E 09 -. 9742X 2/92 crush vs. strain data used in additional VN simulations

2. Holtec Report No. HI-2043278, 'Evaluation of Postulated HI-TRAC 125D Transfer Cask Drop Accidents at River Bend Station," Rev. 2 2.1 Submit finite element modeling details for the lid-to-shell partial penetration weld joint and the gap interface between the MPC closure lid and the shell body. With respect to the weld, provide justification for using directly the uniaxial stress-strain material properties for evaluating the calculated von Mises stress, which is primarily biaxial in nature.

Basis. In Figure 9 of the report, the lid-to-shell weld is shown to be subject to material yielding while the lower shell near the bottom plate of the MPC remains elastic, for a 7" vertical drop of the loaded transfer cask. In a separate calculation package for the MPC subject to a 25-ft drop, the most critically stressed and strained location, however, is shown to be at a lower shell section near the bottom plate. It's unclear whether any modeling anomalies have been introduced to the weld finite element scheme, such as type, size, number of elements, and order of integration for determining stress/strain performance of the weld. Holtec should provide information to show that the weld details are adequately modeled so as not to invalidate the reported stress/strain results.

Holtec Response:

In the HI-TRAC drop analysis, the MPC lid-to-shell weld joint was modeled by using the LS-DYNA command "*CONSTRAINEDSPOTWELD" at 26 locations around the circumferential weld line of the quarter MPC model with full consideration of the 1/16" gap between the lid and the shell body (a constrained spot weld every 2"). Since the Y/2" thick MPC shell was modeled with shell elements, each pair of constrained shell/lid nodes that represent the local weld connection are distanced 0.625", which is the sum of the lid-to-shell radial gap (1/16") and one half of the shell thickness (1/4"). The following figure shows the weld connection of the LS-DYNA MPC model. The figure shows the top view of the MPC lid (modeled using solid elements), and an end view of the shell (modeled using thin shell elements). It should be pointed out that the HI-STORM FSAR has demonstrated that the MPC lid-to-shell weld joint will not fail as long as the design basis deceleration is not exceeded, which is true for the analyzed 7" drop event.

Because the weld joint is not explicitly modeled with solid or shell elements in the 7" HI-TRAC drop analysis as described above, the Von Mises stress shown in Figure 9 of the to RBG-46478 18 of 21 report actually represents the stress status of the MPC shell at the weld connection. The Von Mises stress (i.e., effective stress) combines stresses in two or three dimensions into a single number (a scalar) using the following formula.

2 2 2 1 [(a a)2+(az)2+(az ax)2+6(rx, +r, +T:r )]V/2 Once the resulting effective stress reaches the limiting value of an isotropic material determined in the uniaxial tensile test, material yielding begins according to the von Mises yield criterion. Finite element results are typically presented using von Mises stress for ductile material under complex stresses. Since the MPC stainless steel is an isotropic ductile material, the use of uniaxial stress-strain material properties in conjunction with von Mises stress in the finite element drop analysis is considered to be appropriate.

As shown in figure 9 of the report, the MPC shell at the shell-to-lid weld connection yields in the analyzed 7" HI-TRAC drop event as a result of the local bending introduced by the small gap between the MPC lid and the shell; the impact does not result in global deformation in the MPC shell. In a separate analysis (documented in HI-2043276) where the MPC directly drops from 25 ft above a rigid target, however, the impact is so severe that the bottom section of MPC buckles immediately as the impact stress wave starts to propagate upward. Dissipating part of impact energy through deformation, the bottom section of the MPC shell acts like an impact limiter that may significantly diminish the otherwise high stresses in the rest of shell above the buckled section. Moreover, the small gap between the MPC lid and the shell may prevent the top section of the shell from being buckled, although the top of shell does experience much greater stress than the 7" drop case.

to RBG-46478 19 of 21

3. Holtec Report No. HI-2043276. 'Analvsis of a Postulated MPC Drop Accident during MPC Transfer Operation," Rev. 0 3.1 Considering true stress and true strain, perform a supplemental LS-DYNA analysis of the MPC to demonstrate that the strains at the lid-to-shell weld and the lower shell section near the bottom plate remain to be bounded by the material failure strains.

Basis. Contrary to that required by the LS-DYNA to use true stress and true strain in its large-strain computation algorithm, engineering stress-strain relationship appears to have been considered in modeling the elasto-plastic drop analysis of the MPC. The staff notes that the materials at both the top and bottom parts of the MPC are subject to major yielding and resulting stress relaxation at the lid-to-shell weld may affect appreciably the stress state change for the lower shell. Proper account of stress-strain relationship is essential for evaluating maximum strains at critical locations of the MPC.

Holtec Response:

The use of engineering stress-strain relationship for the MPC model is conservative, since the true stress-strain relationship for stainless steel, which accounts for the reduction of the loaded area of the specimen in the tensile test, has a much greater material failure true strain. The above statement is consistent with NRC staffs position in the ASLB (safeguards) hearing regarding the aircraft impact evaluation for the PFS ISFSI. Since the mathematical relationship between engineering stress/strain and the true stress/strain (can be derived by assuming both constancy of volume and a to RBG-46478 20 of 21 homogeneous distribution of strain along the gage length of the tension specimen) breaks down after necking of the tension specimen, the complete true stress-strain curve for a material can only be obtained through actual measurements in the tensile test.

Nevertheless, a supplemental LS-DYNA analysis has been performed by using the true uniaxial stress-strain relationship presented by the NRC staff in the ASLB hearing to demonstrate the conservatism; the true stress-strain curve shown below was originally obtained by the Sandia National Laboratories.

True Stress-Straln Curve for MPC Shell Type 304 StaInle ss Ste .1at 450F 1200

. ... ,00- .

100 0 600 ___ __ _i 0.00 0.10 0.20 C.30 OGAO 0. 0.60 0.70 0.80 0.90 1.00 Stratin The following figure shows the plastic strain result from the supplemental LS-DYNA analysis. The maximum plastic strain of the MPC shell (0.09897) is smaller than that reported in Figure 5 of HI-2043276 (i.e., 0.2125) where the engineering stress-strain relationship was used. The plastic strain results comparison confirms that the use of engineering stress strain relationship is conservative for the drop analysis.

to RBG-46478 21 of 21 Fringe Levels 25' MPC DROP Time *- 0.017599 Time 0.017599 Fringe Levels Contours of Effective Plastic Strain 9.897"02-nn max Ipt. value min=D. at elemi 70399 8.907e-02_ 11 max=0.0989705. at elemi 62834 7.91 Be-02 _IL 6.928e-002 _jj 5.93le-002 4.949e"02 ,

3.959e-102 _ ;

2.969e-002 _ .

1.979e-"02 9.897e-"03 -

0.OOOIO0l -_

3.2 Discuss why an irregular stress state in the circumferential direction, as displayed in Figure 4 of the report, should result in an uniform plastic strain state, shown in Figure 5.

Basis. The irregular light green/yellow stress contours near the closure lid end do not suggest that uniform plastic strain state is attainable in the upper MPC shell.

Holtec Response: The plastic strain distribution shown in Figure 5 was obtained at the time instant (0.0181 03 sec) when all MPC shell finite elements had experienced their peak stresses that determine the final plastic strain state. The stress distribution presented in Figure 4, however, is for a much earlier time instant (0.0087997 sec). The instantaneous stress status in a dynamic problem (such as the MPC impact event) does not reflect the final plastic strain distribution of the structure, which is quite different from a static problem. Therefore, an instantaneous irregular stress distribution in the circumferential direction of the shell, which could be caused by local effects such as the symmetric boundary condition of the model on the stress wave propagation, does not imply that the distribution of the peak stresses experienced by the MPC shell over the impact process is irregular. Because of the symmetry in both geometry and loading, the MPC shell will experience a symmetric (or uniform) distribution of peak stresses in the drop event although the peak stresses occur at different time instants. The obtained steady plastic strain distribution in Figure 5 of the report reflects the distribution of the peak stresses that the MPC shell experiences during the impact process.

Attachment 5 RBG-46478 Photographs of Redundant Rigging

Redundant Rigging Engagement Photograph #1 The FBCHC Main Hook and attached Lift Yoke have been raised to achieve seating of the Lower Link in the Lift Yoke. Visual observation of the Lower Link top plate's seating on the top of the Lift Yoke Strongback is used to verify that proper seating of the Lower Link in the Lift Yoke. The painted top sides of the Link Locks can be fully seen. The Link Lock has been engaged (pivoted outward into the window in the Lift Yoke Strongback).

Photograph #2 A view of the redundant link slings, at same conditions as shown in Photograph #1. The slings are visibly slack.

, --%.. :1

1. --. "ij Photograph #3 The FBCHC Main Hook and attached Lift Yoke have been lowered so that the top of the Link Locks are against the inside top of the window in the Lift Yoke. This position permits putting tension on the Redundant Link Slings by lowering of the FBCHC Main Hook.

Photograph #4 The FBCHC Main Hook and attached have been lowered slightly to cause the Redundant Link Slings to become visibly taut.

The tautness of the slings confirms that the Link Locks have been engaged.

Attachment 6 RBG-46478 NUREG-0612 AND NUREG-0554 Comparison Matrix for the RBS Fuel Building Cask Handling Crane

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 1 of 44 Document Guidance Evaluation Notes and Section Safe load paths for heavy load movements have been defined at RBS. The FBCHC is prevented, The consequences of a postulated Safe load paths should be defined for by design, from traveling over the drop of the MPC lid into the loaded the movement of heavy loads to reactor vessel and the spent fuel MPC have been evaluated and found NUREG-0612 minimize the potential for heavy loads, pool. Loaded spent fuel casks are to not result in an unacceptable fuel Section if dropped, to impact irradiated fuel in not handled over irradiated fuel. configuration and the radiological 5.1.1(1) the reactor vessel and in the spent fuel The MPC lid is the sole heavy consequences are bounded by the pool, or to impact safe shutdown load handled by the FBCHC that previously evaluated fuel handling equipment. must be suspended over exposed accident described in RBS USAR spent fuel in the loaded canister Section 15.7.4.

to properly conduct spent fuel cask loading operations.

Procedures should be developed to RBS' heavy load control program NUREG-0612 cover load handling operations for includes procedures to cover load Lift height limits, consistent with the Section heavy loads that are, or could be handling operations for heavy drop analyses will be included in the 5.1.1(2) handled over, or in proximity to loads, including those handled by operating procedures, as appropriate.

irradiated fuel or safe shutdown teFCC equipment.

Crane operators are trained in the area of heavy load handling, safe load paths, and the potential Crane operators should be trained, consequences of load drops over NUREG-0612 qualified, and conduct themselves in the reactor vessel, spent fuel Section) accordance with Chapter 2-3 of ANSI pool, and safe shutdown 5.1.1(3) 830.2-1 976. equipment. They conduct themselves appropriately in accordance with this training. The training is based upon ANSI B30.2-1976.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 2 of 44 Document Guidance Evaluation Notes and Section The redundant rigging system (Figure 3 of Attachment 2 to LAR 2004-26) is comprised of upper links, lower links, The special lifting devices used and connecting slings. The upper with the FBCHC to handle heavy links are attached to the crane NUREG061withd thequiCHC torhadle heavyg structure and are not a special lifting Section Special lifting devices should satisfy cask loading operations (i.e. the device. The upper links are designed theguielins o ANI N4.6-9 5.1.(4) lcasykeloaingyopeerations(ioe, the with safety factors of 3 and 5 to yield MPC lift cleats) satisfy the and ultimate strength, respectively.

guidelines of ANSI N14.6-1993. The lower links also do not meet the definition of a special lifting device.

However, Entergy has chosen to design them in accordance with the guidance of ANSI N14.6-1993.

The lifting devices used with the Slings are used to lift and lower the FBCHC tohandleheavyloads empty MPC, the MPC lid, and the NUREG-0612 Lifting devices that are not specially required for dry storage cask redundant load path that is engaged SEction designed should be installed and used loading operations that are not re most horizonta transfergask Section in accordance with the guidelines of specially designed (i.e., slings, for most horizontal transfer cask 5.1.1(5) ANSI B30.9-1971. rigging, connecting devices) movements. The redundant load path satisfy the guidelines of ANSI slings connect the upper and lower B30.9-1984. crane links (see Figure 3 in 9 9Attachment 2 to LAR 2004-26).

The FBCHC is inspected, tested, NUREG-0612 The crane should be inspected, tested, with ANSI n30.2-1976. Twor Section and maintained in accordance with wic Ansi are 5.1.1(6) Chapter 2-2 of ANSI B30.2-1 976. periodic inspections are performed, on a 6-month and an 18-month frequency.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 3 of 44 Document Guidance Evaluation Notes and Section The crane should be designed to meet NCSplmna E o B the applicable criteria and guidelines of The FBCHC was designed to NRC Supplemental SER for RBS NUREG-0612 Chapter 2-1 of ANSI 830.2-1976 and meet the applicable criteria and dated January, 1985, Section 2d3.7 Section CMAA-70 or suitable alternative guidelines of CMAA 70-1971 and concludes wit the FBCHC design 5.1.1(7) provided the intent of ANSI B30.2 and ANSI B30.2-1967. complies with CM 1975 and CMAA-70 is satisfied. . ._ANSI B30.2-1976.

The FBCHC is being upgraded only to the extent that a redundant rigging feature is being Special lifting devices that are used for incorporated in the design. The heavy loads in the area where the redundant rigging is engaged crane is to be upgraded should meet above the crane hook and, ANSI N14.6-1978, including Section 6 therefore, does not meet the NUREG-0612 of that document. If only a single lifting definition of a special lifting Load drops have been postulated in Section device is provided instead of dual device. Below the hook, the lift the areas where the lift yoke 5.1.6(1)(a) devices, the special lifting device yoke and MPC lift cleats are extension is used.

should have twice the design safety designed in accordance with factor as required to satisfy the ANSI N14.6 with twice the design guidelines of NUREG-0612, Section safety factor. The lift yoke 5.1.1(4). extension is designed in accordance with ANSI N14.6 but the design safety factors are not doubled.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 4 of 44 Document Guidance Evaluation Notes and SectionII Lifting devices that are not specifically designed and that are used for handling heavy loads in the area where the crane is to be upgraded should meet ANSI B30.9- 1971, uSlings" as specified in NUREG-0612, The FBCHC is being upgraded Section 5.1.1(5), except that one of the only to the extent that a following should also be satisfied redundant rigging feature is being unless the effects of the drop of the incorporated in the design. The particular load have been analyzed slings used in the redundant and shown to satisfy the evaluation rigging (above the crane hook)

NUREG-0612 criteria of NUREG-0612, Section 5.1: are designed in accordance with Section ANSI B30.9. MPC lift slings, MPC 5.1.6(1)(b) (i) Provide dual or redundant slings lid lift slings, and other connection or lifting devices such that the devices used below the crane failure a single component failure hook are designed in accordance or malfunction in the sling will not with ANSI B30.9 to twice the load result in uncontrolled lowering of called for in meeting Section the load; 5.1.1(5).

OR (ii) In selecting the proper sling, the load used should be twice what is called for in meeting NUREG-0612, Section 5.1.1(5).

This criterion is not applicable NUREG-0612 New cranes should be designed to because the FBCHC is not a new Section meet NUREG-0554 crane. The FBCHC was designed 5.1.6(2) before the issuance of NUREG-I__ _ 10554. 1

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 5 of 44 Document Guidance Evaluation Notes and SectionI Interfacing lifting points, such as lifting lugs or cask trunnions should also meet one of the following for heavy loads handled in the area where the crane is to be upgraded unless the effects of the drop of the particular load have been analyzed and shown to satisfy the evaluation criteria of NUREG-0612, Section 5.1:

The lifting trunnions of the HI-(a) Provide redundancy or duality such TRAC transfer cask have a thata single lift point failure will not design safety factor greater than NUREG-061 2 result in uncontrolled lowering of 10 times the maximum combined Section the load; lift points should have a static and dynamic load. A 5.1.6(3) design safety factor with respect to dynamic load factor of 1.15 is ultimate strength of five (5) times applied to the mass of the lifted the maximum combined concurrent load.

static and dynamic load after taking the single lift point failure.

OR (b) A non-redundant or non-dual lift point system should have a design safety factor of ten (10) times the maximum combined concurrent static and dynamic load.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 6 of 44 Document Guidance Evaluation Notes The design stress limits of the FBCHC structural members are in accordance with CMAA 70-1971. Load-carrying parts other The allowable design stress limits for than structural members and NUREG-0554 the crane intended for plant operation hoisting ropes are designed to a Section 2.1 should be those indicated in Table maximum stress level of 20% of (Item 1) 3.3.3.1.3-1 of CMAA 70 reflecting the ultimate strength of the material.

appropriate duty cycle in CMAA 70. The crane was also re-qualified by analysis in 2002 considering a load on the hook using CMAA 70-2000 allowable stresses and loadings.

The sum total of simultaneously The FBCHC was designed not to applied loads (static and dynamic) exceed material yield strengths should not result in stress levels under static and dynamic loading NUREG0554causing permanent deformation, other conditions. Dynamic loading is Section 2.1 than localized strain concentration, in addressed in the design through FBCHC main hoist speed is 6 fpm.

(Item 2) any part of the handling system during the use of a 15% impact load either the construction or the operation factor based on a hoist speed of phase. 30 ft/min or less (ref. CMAA specification No. 70, 1971).

The FBCHC main hook hoist is designed for stepped, variable The effects of cyclical loading induced speed operation with a load on NUREG-0554 by jogging or plugging an the hook ranging from 0.5 fpm Section 2.1 uncompensated hoist control system (inching speed) to 6 fpm (normal (Item 3) should be included in the design speed). The use of inching specification. speed during cask handling

a. prevents cycling due to jogging or plugging. Therefore, this requirement does not apply.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 7 of 44 Document and Section Guidance Evaluation Notes A single-failure-proof crane should be Component parts of the FBCHC designed to handle the maximum are designed for an MCL of 125 critical load (MCL) that will be tons - the maximum weight of the NUREG-0554 imposed. However, a slightly higher HI-TRAC transfer cask. The Sect-on 2.2 design load should be selected for intent of this guideline is met by Item 21) component parts that are subjected to requiring hoisting ropes and other (item wear and exposure. An increase of load-carrying parts (other than approximately 15% of the design load structural members) to have a for these components would be a rated-load minimum safety factor reasonable margin. of five.

NUREG-0554 The MCL rating should be clearly The FBCHC MCL is marked on Section 2.2 marked on the crane. the crane.

(Item 2)

Single-failure-proof cranes may be required to handle occasional The FBCHC is designed and noncritical loads of magnitude greater used to lift spent fuel shipping than the MCL during plant and storage cask components as NUREG-0554 maintenance periods. For such cases, well as other waste containers.

Section 2.2 the maximum noncritical load will be The heaviest of these lifts is the No lifts greater than the MCL (rated (Item 3) the design rated load (DRL). The HI-TRAC 125D spent fuel transfer capacity) are permitted with the design of certain components may be cask, which has a maximum lifted decided to a greater extent by the MCL weight of 125 tons. Therefore, the rating even though standard MCL and the DRL are the same commercial practice may be used for for this crane.

the DRL rating.

NUREG-0554 The DRL rating should be marked on The MCL and DRL are the same Section 2.2 the crane separately from the MCL for the FBCHC. Therefore, no (Item 4) marking. separate DRL marking is

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 8 of 44 DocumSent Guidance Evaluation Notes The FBCHC is located inside the RBS Fuel Building and operates both indoors and outdoors. It is kept indoors when not in use.

.Because of its Fuel Building The operating environment, including location, the FBCHC is not maximum and minimum pressure, loain'h F Ci o maximum rand minimupressur e, affected by potential containment NUREG-0554 maximumpressurization events; therefore Section 2.3 temperature, humidity and emergency the rate of pressure increase and corrosive or hazardous conditions should be specified for the crane and the effects of a corrosive litn fitrs environment (i.e., containment spray) are not applicable.

Appropriate environmental conditions of service are established in the procurement specification.

The FBCHC indoor test lift was required to be performed at a Cask loading procedures will require temperature of 200F or higher. an ambient temperature > 700F for all For cranes already built and operating; The actual indoor test lift was hayla it.Ti scnitn NUREG-0554 such cranes should be tested by performed in September, 1983. with NUREG-0612, Appendix C, page Section 2.4 subjecting the crane to a test lift at the The FBCHC outdoor test lift was C-2, item (2). Entergy may perform a (Item 1) lowest anticipated operating performed at a minimum load test in the future if experience temperature. temperature of 74.50F. Dry spent dictates a lower operating fuel cask loading operations will tates desirating not be conducted at temperatures temperature is desirable.

below 70 0F.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 9 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section Cask loading procedures will require sThe FBCHC's minimum design an ambient temperature > 70'F for all Minimum operating temperatures heavyFlodClifts.Thisiismonsisten NUREG-0554 should be specified in order to reduce temperature is 20F. Dry spent heavy load lifts. This is consistent Section 2.4 the possibility of brittle fracture of the fuel cask loading operations will with NUREG-0612, Appendix C, page (Item 2) ferritic load-carrying members of the not be conducted at temperatures C-2 item (2). Entergy may perform a crane. below 700F. load test in the future if experience bo dictates a lower operating temperature is desirable.

In order to ensure resistance to brittle .

fracture, material for structural Ca ladingtperoeures wil oreqlr members essential to structural Structural steel used in the an ambient temperature > 700F for all NUREG-0554 integrity should be tested in FBCHC is ASTM A36. Material heavy load lifts. This is consistent Section 2.4 accordance with the following impact certifications for steel used in with NUREG-0612, Appendix C, page (Item 3) test requirements. Either drop weight construction of the FBCHC do not C-2, item (2). Entergy may perform a test per ASTM E-208 or Charpy tests include impact test results. load test in the future if experience testAper ATM-370 oyC y tess i d idictates a lower operating per ASTM A-370 may be used for temperature is desirable.

.i Impact testing.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 10 of 44 and Section Guidance The minimum operating temperature based on the drop weight test should be obtained by following procedures in Paragraph NC-2300 of Section III of the ASME Code. The minimum operating temperature based on the Charpy V-notch impact test should be obtained by following procedures in paragraph ND-2300 of Section III of the ASME Code. Alternative methods of fracture analysis that achieve an equivalent margin of safety against Cask loading procedures will require fracture may be used if the include an ambient temperature > 700 F for all toughness measurements on each Structural steel used in the heavy load lifts. This is consistent NUREG-0554 heat of steel used in structural FBCHC is ASTM A36. Material with NUREG-0612, Appendix C, page Section 2.4 members essential to structural certifications for steel used in C-2, item (2). Entergy may perform a (Item 4) integrity. In addition, the fracture construction of the FBCHC do not load test in the future if experience analysis that provides the basis for include impact test results. dictates a lower operating setting minimum operating temperature is desirable.

temperatures should include consideration of stress levels; quality control; the mechanical checking, testing, and the temperatures at which the DRL test is run relative to operating temperature.

For crane girder material section thickness over 64 mm (2.5 in), it is recommended that the NC-2300 requirements be used exclusively.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 11 of 44 and Section Guidance As an alternative to the above recommendations, the crane and lifting fixtures for the cranes already fabricated or operating may be subjected to a coldproof test consisting of a single dummy load test follows:

Metal temperature of the structural members essential to the structural integrity of the of the crane handling system should be at or below the minimum operating temperature. The corresponding dummy load should be equal to 1.25 times the MCL. If the desired minimum operating NUREG-0554 temperature cannot be achieved Section 2.4 during the test, the minimum operating (Item 4) temperature should be that of the test (continued) until the crane is retested at a lower temperature. The coldproof test should be followed by a nondestructive examination of the welds whose failure could result in the drop of a critical load. The nondestructive examination of critical areas should be repeated at 4-year intervals or less.

Cranes and lifting fixtures made of low-alloy steel such as ASTM A514 should be subjected to the coldproof test in any case.

J Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 12 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section Cast iron should not be used for load- No cast iron is used for any NUREG- bearing components such as rope component subject to cyclic 0554 drums. Cast iron may be used for stress, except for the main trolley Section 2.4 items such as electric motor frames traverse drive gear cases, wheel (Item 5) and brake drumse bearing capsules, brake wheels, d band some brake parts.

The FBCHC design does not include a main bridge. Seismic calculations The cranes should be designed to The FBCHC main trolley, show that the main hoist wire rope retain control of and hold the load, and auxiliary trolley, and auxiliary exceeds its yield strength under SSE NUREG- the bridge and trolley should be bridge are designed to ensure the of safety of 1.475 against ultimate Section 2.5 designed to remain in place on their bridge and trolleys remain in (Item 1) respective runways with their wheels place and their wheels do not solely by the main hoist. Resundant prevented from leaving the tracks leave their rails and no trolley part olly be main hoi dunan alls during a seismic event. load in case of failure in the primary load path in areas where load drops have not been analyzed.

If a seismic event comparable to a safe NUREG- shutdown earthquake (SSE) occurs, The FBCHC is designed to 0554 the bridge should remain on the ensure the bridge and trolleys will Section 2.5 runway with brakes applied, and the not leave their rails during or after (Item 2) trolley should remain on the crane a safe shutdown earthquake.

girders with brakes applied.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 13 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section The crane should be designed and constructed in accordance with regulatory position 2 of Regulatory The FBCHC was qualified for NUREG- Guide 1.29, "Seismic Designnomlpeainsuiga NUREG- Classification". The MCL plus normal operation assuming a The seismic analysis evaluated the Section 2.5 operational and seismically induced 1.15 dynamic load factor dro rated load on the hook with the hoist Sem 3. pendulum and swinging load effects on the load during a safe shutdown rope extended to various lengths.

the crane should be considered in the seismic event.

design of the trolley, and they should be added to the trolley weight for design of the bridge.

Load girt and drive girt end

. . .connection welds on the FBCHC All weld joints whose failure could connec weld on- thucHC result in the drop of a critical load trolley were non-destructively NUREG- should be nondestructively examined. All FBCHC welds were visually examined following recent 0554 G - Ifanyofneseruteldyjoit u geamrined. examined. All welds of the main modifications implemented to 0554 If any of these weld Joint geometries hoist gears, pinions, and shaft increase the trolley's seismic tearing, the base metal at the joints assemblies were MT inspected. capacity. Other welds on the trolley should be nondestructively examined, were non-destructively examined on a sampling basis to assure the quality of the component.

A fatigue analysis should be considered for the critical load-bearing NUREG- structures and components of the The FBCHC is a low duty cycle 0554 crane handling system. The cumulative device. A fatigue analysis is not Section 2.7 fatigue usage factors should reflect required.

effects of the cyclic loading from both the construction and operating periods.

NUREG- Preheat temperatures and post-weld Preheat temperatures and post-0554 heat treatment (stress relief) weld heat treatment of weldments Section 2.8 temperatures for all weldments should were performed and documented (Item 1) be specified in the weld procedure. as required by AWS D1.1-1 972.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 14 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section Giac All welding was performed and Per NUREG-0612, Appendix C, page documented in accordance with C-3, item (3), some crane weldments NUE-AWS D1l1- 7.Ohrta h may not have been heat treated per NUREG- Welds described in the .1-1972. herst te Subarticle 3.9 of AWS D1.1-1972. As 054recommendations of Section 2.6 manadaxlayhitrdcr a'substitute for weld heat treatment, 0554 should be post-weld heat treated in weldments, which were thermally welds whose failure could result in Itio 2)8 accordance with Subarticle 3.9 of AWS stress relieved, welds associated the drop of a critical load should be (Item 2) 13.1 'Structural Welding Code". with all other bridge and trole non-destructively examined to weldments were not subjece to acrtain that the weldments are post-weld heat treatment (stress acceptable. See notes for NUREG-

e. 0554, Section 2.6 above.

NUREG- All auxiliary hoisting systems of the The FBCHC auxiliary hook is not 0554 main crane handling system that are employed to lift or assist in Section 3.2 employed to lift or assist in handling handling heavy loads during cask (Item 1) critical loads should be single failure loading operations.

proof.

The FBCHC main hoisting A complete review of cask Auxiliary systems or dual components mechanism is not single-failure operations, including potential load NUREG- should be provided for the main proof by design. Redundant drops has been performed.

0554 hoisting mechanism so that, in case of rigging is employed during most Evaluations and analyses of Section 3.2 subsystem or component failure, the horizontal movements of the cask hypothetical drops required to be (Item 2) load will be retained and held in a to provide temporary single- postulated have been performed. No stable or immobile safe position. failure-proof protection against unacceptable consequences of load drops. drops are predicted.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 15 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE and Section Guidance The main and auxiliary hoists have limit switches that stop the hook in its highest and lowest safe positions. Two limit switches, each of a different design and in series, limit upward travel of each hook. A block type switch is used on the cable and a screw type on the drum, which are adjusted such that if one fails the other will shut off power to the motor and set the brakes. The limit switch actuating mechanisms are located so that the switches will trip under all The automatic controls and limiting conditions of hoist load and hoist speed, The main hoist is equipped with an in sufficient time to prevent contact of the devices should be designed so that, load block with the drum, upper sheaves, alternator-excited eddy current when disorders due to inadvertent or any part of the trolley. The main hoist lowering control brake system, which operator action, component is also provided with a slack cable limit is capable of maintaining a controlled NUREG- malfunction, or disarrangement of switch to prevent hoisting or lowering lowering speed of the 125-ton rated against a slack cable. And with a 0554 subsystem control functions occur centrifugal limit switch to apply the load, in the event of a loss of all AC Section 3.3 singly or in combination during the load holding brakes in the event of an power or electrical failure of the (Item 1) handling, and assuming no overspeed. The centrifugal limit switch is hoist's motor controller. Emergency components have failed in the located such that if a shaft or coupling lowering of the main hoist using the subsystems, these disorders will not fails and causes disengagement of the eddy current brake requires that the main hoist motor and one holding brake, prevent the handling system from it would still trip upon the ensuing two hoist holding brakes be manually stopping and holding the load. overspeed and engage the remaining released.

holding brake to stop uncontrolled movement of the load. The centrifugal limit switch is also located such that there is no coupling between the switch and the main hoist gears.

Each hoist is provided with an overload cutoff that senses an overload on the hoist and stops the hoisting motion, but allows safe lowering of the load to the floor. The load limiting device is adjustable up' to 130% of rated load.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 16 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE and Section Guidance Evaluation Notes The FBCHC operator cab includes a safety switch to disconnect the main power feed NUREG- An emergency stop button should be conductors from the motor control 0554 stations. The cab also includes a Section 3.3 added at the control station to stop all areset-stop" pushbutton station (Item 2) motion. with a red stop button that opens the main line electrical contactor.

Opening this contactor will stop all motion.

The FBCHC main and auxiliary hoists are provided with holding brakes that are automatically applied to the hoist motor shaft when the motor is de-energized.

The main hoist is equipped with Ac e t an alternator-excited eddy current A crane that has been immobilized lowering control brake system, NUREG- becau se of or failure of malfunction which is capable of maintaining a 0554 controls or components while holding a controlled lowering speed of the Section 3.4 critical load shoul be ad abletophod the 125-ton rated load, in the event of (Item 1) load or set the load down while repairs a loss of all AC power or or adjustments are being made, electrical failure of the hoist's motor controller. Emergency lowering of the main hoist using the eddy current brake requires that the two hoist holding brakes be manually released.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 17 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section Means should be provided for using the devices required in repairing, The main hoist is equipped with adjusting, or replacing the failed an alternator-excited eddy current component(s) or subsystem(s) when lowering control brake system, failure of an active component or which is capable of maintaining a NUREG- subsystem has occurred and the load controlled lowering speed of the 0554 is supported and retained in the safe 125-ton rated load, in the event of Section 3.4 (temporary) position with the handling a loss of all AC power or It 2) system immobile. As an alternative to electrical failure of the hoist's (Iem repairing the crane in place, means motor controller. Emergency may be provided for safely transferring lowering of the main hoist using the immobilized hoisting system with the eddy current brake requires its load to a safe laydown area that has that the two hoist holding brakes been designed to accept the load while be manually released.

the repairs are being made.

The design of the crane and its operating area should include provisions that will not impair the safe The FBCHC operates and is NUREG- operation or safe shutdown of the mitie nteFe ulig 0554 reactor or cause unacceptable release maintained in the Fuel Building.

Section 3.4 of radioactivity when corrective repairs, Its operation and maintenance do (Item 3) (Ite repacemnts 3) replacements, an and adjstmntsare adjustments are not affect the to operate ability or be of the reactor shutdown safely.

being made to place the crane handling system back into service after component failure(s).

A complete review of cask Design of the rope reeving system(s) The FBCHC does not have a dual operations, including potential load NUREG- should be dual with each system drops has been performed.

0554 providing separately the load balance ( ae reeving stem . Evaluations and analyses of Section 4.1 on the head and load blocks through The reeving arrangement is a hypothetical drops required to be (Item 1) configuration of ropes and rope multi-part, double reeved system, postulated have been performed. No equalizer(s). utilizing one piece of wire rope. unacceptable consequences of load drops are predicted.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 18 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document and Section Guidance Evaluation Notes The FBCHC sheaves are Selection of the hoisting rope or provided with cable retainers to running rope should include prevent the cables from leaving NUREG- consideration of the size, construction, the sheave grooves. The hoisting 0554 lay, and means or type of lubrication, if ropes are right regular lay, pre-Section Sction 4.1 required, to maintain of the individual efficient when wire strands working formed steel with independent

4) wire rope centers. Rope (Item 2) each section of rope passes over the lubricants (including those for individual sheaves during the hoisting pre-lubricating the internal core operation. and rope lays during weaving) are not water soluble.

The effects of impact loadings, acceleration, and emergency stops The FBCHC wire rope was should be included in selection of rope selected so that the rated hoist NUREG- reeving systems. The maximum load load plus the weight of the load 0554 (including static and inertia forces) on block, divided by the number of Section 4.1 each individual wire rope in the dual parts of rope does not exceed 20 (Item 3) reeving system with the MCL attached percent of the nominal breaking should not exceed 10% of the strength of the rope (a safety manufacturer's published breaking factor of five).

strength.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 19 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation l Notes The ratio of wire rope yield strength to ultimate strength may vary sufficiently for different production runs to The FBCHC hoisting ropes are influence the wire rope rating in such a designed so that the rated hoist manner that the initial safety margin load plus the weight of the load NUREG- selected would be too small to prevent block for that hoist, divided by the 0554 the critical load from straining the wire number of parts of rope for the Section 4.1 rope material beyond the yield point hoist does not exceed 20 percent (Item 4) under abnormal conditions. It would, of the nominal breaking strength therefore, be prudent to consider the of the rope (a safety factor of wire rope yield strength as well as the five).

ultimate strength when specifying wire rope in order to ensure the desired margin on rope strenqth.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR I RBG-46478 Page 20 of 44 I THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section The FBCHC is a 'stand-by" service crane (used The maximum fleet angle from drum to approximately every 18 months), Per NUREG-0612, Appendix C, page lead sheave in the load block or where fatigue failure of the wire C-3, item (4), in lieu of meeting this between individual sheaves should not rope is highly unlikely. CMM 70- fleet angle recommendation, a 'more exceed 0.061 rad (3-1/2") at any one 1971 (the code of record for the frequent inspection program" for the point during hoisting except that for the RBC FBCHC) did not specify wire rope is acceptable for ensuring last 1 m (3 ft) of maximum lift elevation rope reeving fleet angle the integrity of the rope. For this NUREG- the fleet angle may increase slightly. limitations. The crane service, the crane manufacturer 0554 4 The use of reverse bends for running manufacturer's internal standard recommends inspecting the wire rope Secio wreroes 41 holdbeimt runninge practice for hoist wire rope either prior to, or after use of the (Item 5) use of larger sheaves should be reeving design was to limit the crane (i.e., on an 18-month interval).

considered for those applications maximum fleet angle at any point RBS maintenance procedures require where a disproportionate reduction i within the reeving system to 4.75 inspection of the wire rope every six wire rope fatigue life would be degrees to ensure satisfactory months, which meets the NUREG-expected from the use of standard ropeme eeving 0612 recommendation for more sheave diameters for reverse bends. RBS FBCHC does not expose frequent inspections.

the wire rope to a reverse bend condition.

The equalizer for stretch and load on the rope reeving system may be of For most horizontal load movements, either beam or sheave type or The FBCHC hoist is equipped redundant rigging is engaged to the combinations thereof. A dual rope with a sheave-type equalizer, not lift yoke to provide single failure NUREG reeving system with individual a bar-tye equalizer The hoist protection against drops. A complete NUEG attaching points and means for reeving arrangement is a review of cask operations, including Section 4.1 balancing or distributing the load part, double-reeved system, potential load drops has been (Item 6) between the two operating rope utilizing one piece of wire rope. performed. Evaluations and analyses reeving systems will permit either rope Th rn osnthv ul of hypothetical drops required to be system to hold the critical load and load athne des n h stem postulated have been performed. No transfer the critical load without pa rope reeving sysem. unacceptable consequences of load excessive shock in case of failure of drops are predicted.

the other rope system.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 21 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Evaluation Notes and Section Guidance The pitch diameter of running sheaves and drums should be selected in accordance with the recommendations For most honzontal load movements, of CMAA Specification #70. The dual remost rgng is load tove reeving system may be a single rope The pitch diameter of the FBCHC redundant rgging is engaged to the from each end of a drum terminating at running sheaves is in accordance lift yoke to provide single failure NUREG- one of the blocks or equalizer with with CMM 70-1971. The hoist protection against drops. A complete 0554 provisions for equalizing beam-type reeving is a conventional double review of cask operations, including Section 4.1 load and rope stretch, with each rope reeved system, utilizing one piece potential load drops has been (Item 7) designed for the total load. of wire rope. The crane does not performed. Evaluations and analyses Alternatively, a 2-rope system may be have a dual load path rope of hypothetical drops required to be used from each drum or separate reeving system. postulated have been performed. No drums using a sheave equalizer or unacceptable consequences of load beam equalizer or any other drops are predicted.

combination that provides two separate and complete reeving systems.

For most horizontal load movements, In the event of a failure of either redundant rigging is engaged to the The load hoisting drum on the trolley the main hoist drum shaft or drum lift yoke to provide single failure should be provided with structural and bearing at the drive end of the protection against drops. A complete NUREG- mechanical safety devices to limit the drum, no mechanical or structural review of cask operations, including 0554 drop of the drum and thereby prevent it . . potential load drops has been Section 4.2 from disengaging from its holding disengagement of the main hoist performed. Evaluations and analyses brake system if the drum shaft or drumngagme hoist of hypothetical drops required to be bearings were to fail or fracture, drumesfrmtehitstohlig postulated have been performed. No unacceptable consequences of load drops are predicted.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 22 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section Giac For most horizontal load movements, redundant rigging is engaged to the The FBCHC is designed to lift yoke to provide single failure NUREG- The head and load blocks should be maintain the vertical load balance protection against drops. A complete 0554 designed to maintain a vertical load about the center of lift from the review of cask operations, including Section 4.3 balance about the center of lift from load block through the head potential load drops has been (Item 1) load block through head block and block, but does not have a dual performed. Evaluations and analyses have a reeving system of dual design. (redundant) reeving system of hypothetical drops required to be design. postulated have been performed. No unacceptable consequences of load drops are predicted.

The load-bock assembly should be The FBCHC design does not provided with two load-attaching points have redundant load-attaching (hooks or other means) so designed points. The main hook is of the NUREG- that each attaching point will be able to sister-hook type and has a design NUREG-0612, Appendix C, page C-0554 support a load of three times the load factor of safety to ultimate of 5.0. 3, item (5) for operating plants allows Section 4.3 (static and dynamic) being handled For most horizontal load for a sister hook in lieu of two (item 2. without permanent deformation of any movements, redundant rigging is attachments points to meet the intent (Iem part of the load-block assembly other engaged to the lift yoke to provide of this guidance.

than localized strain concentration in single failure protection against areas for which additional material has drops (See Section 4.7.2 of been provided for wear. Attachment 1 to LAR 2004-26).

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 23 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document and Section Guidance Evaluation Notes The FBCHC structural The individual component parts of the components were designed for vertical hoisting system components, 100% static rated load (maximum which include the head block, rope critical load) and analyzed for a reeving system, load block, and dual 1.15 dynamic load factor. The The following tests and inspections load-attaching device, should each be crane main hook was factory were not required by the FBCHC designed to support a static load of tested at 1.25 times its rated load. procurement specification (1975):

200% of the MCL. A 200% static-type Hoisting ropes and load-carrying load test should be performed for each parts other than structural

200% MCL static load test for NUREG- load-attaching hook. Measurements of members have a design safety the hook(s) 0554 the geometric configuration of the factor of five. Structural members

Measurements of the Section 4.3 hooks should made before and after are designed with stress geometric configuration of the (Item 3) the test and should be followed by a allowables in accordance with ehook(s) before and after load nondestructive examination that should CMM 70-1971.

consist of volumetric and surface testing examinations to verify the soundness The main hook was MT- hook before and after load of fabrication an ensure the integrity of examined before and after load testing the hooks. The load blocks should be testing. The main hook forging . NDE of the load block(s) nondestructively examined by surface billet was UT-examined to verify and volumetric techniques. The results the soundness of the raw material of examinations should be documented used to fabricate the main hook.

and recorded. Examination results are documented.

The calculated maximum main hoist The maximum FBCHC normal design "rated load' speed is 5.88 fpm, Maximum hoisting speed for the critical hoisting speed for the MCL is 6 which exceeds the 5 fpm speed NUREG- ~ load should be limited to that given in fpm and 'inching speed' is 0.5 reomndinCA7011fr l0554 the "slow" column of Figure 70-6 of fpm. CMAA 70-1 971, Table 70-6 the maximum crit loeed yields 5

CM Seciictithi0.s cpacitys5 pcrae, s dfo maximum rope line speed at the drum this capacity crane. of 35 fpm, which is less than the suggested line speed limit of 50 fpm.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 24 of 44 Document Guidance Evaluation Notes and Section Giac No specific provisions for addressing the consequences of two-blocking are included in the FBCHC design. Each hoist NUREG- The reeving system should be includes limit switches to stop the 0554 designed to prevent the cutting or hook at its highest and lowest Section 4.5 crushing of the wire rope if a "two- safe positions. Two differently (Iteml) blocking" incident should occur. designed limit switches, used in series, provide redundancy and diversity to limit the upward travel of each hoist hook.

The FBCHC design includes load limiting devices that stop hoisting operations upon indication of an NUREG-0612, Appendix C, page C-overload condition. No specific 3, item (7) suggests interlocking The mechanical and structural provisions for addressing the circuitry to preclude bridge and trolley NUREG- components of the complete hoisting consequences of two-blocking movement while hoisting the load in 0554 system should have the required are included in the FBCHC lieu of load hang-up protection. The Section 4.5 strength to resist failure if the hoisting design. Each hoist includes limit FBCHC does not have this (Item 2) system should "two-block" or if 'load hsitghestand loe hook at its interlocking circuitry. Cask loading hang-up" should occur during hoisting. Two differently designed limit procedures will prohibit simultaneous usifeedtin dseiges, proidet FBCHC trolley and hoisting switches, used in series, provide movement.

redundancy and diversity to limit the upward travel of each hoist hook.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 25 of 44 Document Guidance Evaluation Notes Each hoist includes limit switches to stop the hook at its highest and lowest safe positions. Two The designer should provide means differently designed limit within the reeving system located on switches, used in series, provide the head or on the load-block redundancy and diversity in combinations to absorb or control the limiting the upward travel of each kinetic energy of rotating machinery hoist hook. A block-type limit during the incident of two-blocking. As switch is used on the cable and a an alternative, the protective control screw-type is used on the drum.

system to prevent the hoisting system They are adjusted such that if from two-blocking should include, as a one limit switch fails the other NUREG- shuts off power to the motor and minimum, two independent travel-limit 0554 sets the brakes. The actuating devices of different designs and Section 4.5 mechanisms of the limit switches activated by separate mechanical (Item 3) are located so that they trip the means. These devices should de-energize the hoist drive motor and the limit switches under all conditions main power supply. The protective of hoist load and hoist speed in control system for load hang-up, a part sufficient time to prevent contact of the overload protection system, of the load block with the drum, should consist of load cell systems in upper sheaves, or any part of the the drive train or motor-current-sensing trolley.

devices or mechanical load-limiting devices. Each hoist includes an overload cutoff that senses the load on the hoist and stops the hoisting motion in an overload condition.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR I RBG-46478 Page 26 of 44 I THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section The load control for the main Although the two main hoist holding The location of mechanical holding hoist is provided by an eddy brakes are each capable of resisting brakes and their controls should current control brake for hoisting the maximum hoist motor torque, they provide positive, reliable, and capable and lowering motions. cannot be 'manually applied" in the NUREG- means to stop and hold the hoisting Accompanying the control brake event an electrical control malfunction 0554 drum(s) for the conditions described in are two independent shoe-type occurs and power to the hoist motor Section 4.5 the design specification and in this holding brakes that are cannot be shut off. In this event, the It 4 recommendation. This should include automatically applied to the hoist hoist brakes may be indirectly set by (Iem ) capability to withstand the maximum motor shaft when the motor is de- either pressing the crane "power torque of the driving motor if a energized. Both of the holding stop" button or by pulling the handle malfunction occurs and power to the brakes have a minimum rated on the main line disconnect switch driving motor cannot be shut off, braking torque of 150% of the (mounted in the operator's cab) to the motor full load torque. "open/off' position.

NUREG- The auxiliary hoist, if supplied, should 0554 be equipped with two independent The FBCHC auxiliary hoist is not Section 4.5 travel-limit switches to prevent two- used in cask handling operations.

(Item 5) blocking.

Lifting devices that are attached to the load block such as lifting beams, yokes, ladle or trunnion-type hooks, slings, toggles, and devises should be NUREG- conservatively designed with a dual or See evaluation for NUREG-0612, 0554 auxiliary device or combinations Sections 5.1.1(4), 5.1.1(5),

Section 4.6 thereof. Each device should be 5.1.6(1)(a), and 5.1.6(1)(b).

designed or selected to support a load of three times the load (static or dynamic) being handled without permanent deformation.

If side loads cannot be avoided, the Side loading of the FBCHC is not NUREG- reeving system should be equipped requird or te durin cSk 0554 with a guard that would keep the wire required or expected during cask Section 4.7 rope properly located in the grooves on puredlyvgertca.vites All lifts are the drum. prl etcl

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 27 of 44 Document Guidance Evaluation Notes and Section The FBCHC structural members are designed so that the stress in The proper functioning of the hoisting the material does not exceed NUREG- machinery during load handling can CMAA 70-1971 limits when lifting 0554 best be ensured by providing adequate the rated load. FBCHC load-Section 4.8 support strength of the individual carrying parts other than (Item 1) component parts and the welds or structural members are designed bolting that binds them together. with a safety factor of five against ultimate strength when lifting the rated load.

The FBCHC is not of the single- A complete review of cask

. . failure-proof design. For most operations, including potential load NUREG- Were gea tradins bar erposed . horizontal load movements, drops has been performed.

0554 48 hoisting drum, these gear trains should redundant rigging is engaged to Evaluations and analyses of Section 4.8 e beistingle failurum prf be of traindsho the lift yoke to provide single hypothetical drops required to be (Item 2) dual designg failure protection against drops postulated have been performed. No d d (See Section 4.7.2 of Attachment unacceptable consequences of load 1 to LAR 2004-26). drops are predicted.

Each holding brake should have more than full-load stopping capacity but should not have excessive capacity The FBCHC main and auxiliary NUREG- that could cause damage through hoist holding brakes have a 0554 sudden stopping of the hoisting minimum rated braking torque of Section 4.9 machinery. A minimum brake capacity 150% of the hoist motor full load (Item 1) of 125% of the torque developed torque.

during the hoisting operation at the point of brake application has been determined to be acceptable.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 28 of 44 Document Evaluation Notes aDoSet Guidance and Section The minimum hoisting braking system The FBCHC main hoist includes should include one power control an eddy current control brake and braking system (not mechanical or two independent shoe-type Normal main hoist motor shaft speed drag brake type) and two holding holding brakes. The holding is 1800 RPM. The main hoist NUREG- brakes. The holding brakes should be brakes are automatically applied lowering control is protected by a 0554 applied when power is off and should to the hoist motor shaft when the centrifugal-type overspeed switch, S0to4 be automatically applied on overspeed motor is de-energized. The which is set to open (i.e., cut power ecion 4. to the full holding position if a holding brakes have a minimum to) the lowering circuit, setting the two (Ie malfunction occurs. Each holding rated braking torque of 150% of hoist holding brakes, at an brake should have a torque rating not the hoist motor full load torque. approximate motor shaft speed of less than 125% of the full-load hoisting The holding brakes are designed 1950 RPM.

torque at point of application (location to retard the load if uncontrolled of the brake in the mechanical drive). lowering is sensed.

The minimum number of braking The FBCHC main hoist includes NUREG- systems that should be operable for a control brake and two 0554 emergency lowering after a single independent holding brakes, Section 4.9 brake failure should be two holding leaving two brakes available in (Item 3) brakes for stopping and controlling (Item drum rotation. ' the event of a single brake failure.

One of the two FBCHC main NUREG- The holding brake system should be hoist holding brakes is located 0554 single failure proof, i.e., any outboard of the gear case on an Section 4.9 component or gear train should be dual extended pinion shaft. There is (Item 4) if interposed between the holding no coupling between this brakes and the hoisting drums. outboard brake and the gear case.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 29 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes Manual operation of the hoisting brakes may be necessary during an emergency condition, and provisions for this should be included in the design conditions. Adequate heat dissincfrom the brake should be The main hoist is equipped with an alternator-excited eddy current dissipation the dake shot lowering control brake system, ensured so that damage does not which is capable of maintaining a occur if the lowering velocity is controlled lowering speed of the NUREG- permitted to increase excessively. It hoist's 125-ton rated load in the 0554 may be necessary to stop the lowering event of a loss of all AC power or Section 4.9 operation periodically to prevent electrical failure of the hoist's (Item 5) overheating and permit the brake to motor controller. Emergency dissipate the excess heat. Portable (eddy contrake)Emergenc instruments should be used to indicate thedy current brake) lowering of the lowering speed during emergency thoin hoist requires that the operations.

hoperations.f If a malfunction brake m ou ofana ction tohoist holding are spring-set on brakes, a loss ofwhich power, holding brake were to occur and be manually released.

emergency lowering of the load became necessary, the holding brake should be restored to working condition before any lowering is started.

The FBCH main trolley includes a Bridge and trolley drives [should be] hydraulically operated brake, NUREG- provided with control and holding brake mounted on the main trolley The auxiliary bridge is not provided 0554 systems that would be automatically motor extension shaft, to control with a separate drive. The auxiliary Section 5.1 applied when the power is shut off or if movement and an electric parking bridge is fixed to the main trolley and Iem o . an overspeed or overload condition brake that is only engaged when movement is controlled by the main

( occurs because of malfunction or the magnetic main power line trolley drive.

failure in the drive system. disconnect is open (de-energizing the motor).

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 30 of 44 Document Guidance Evaluation Notes To avoid the possibility of drive motor overtorque within the control system, The FBCHC The main trolley the maximum torque capability of the hydraulic control brake has a NUREG- driving motor and gear reducer for minimum braking torque of 100%

0554 trolley motion and bridge motion of the of the main trolley motor full load Section 5.1 overhead bridge crane should not motor torque. The electric parking (Item 2) exceed the capability of gear train and brake has a minimum braking brakes to stop the trolley or bridge from torque of 75% of the main trolley the maximum speed with the DRL motor full load motor torque.

attached.

tolly]ndicreenta or

[Brige Controls for the FBCHC main NUREG- [Bridge and trolley] incremental or trolley are full magnetic reversible 0554 fratia ihound beproveded by suc with five steps of variable speed.

Section 5.1 items as variable speed controls or The main trolley also includes an (Item 3) inching motor drives. inching motor with a maximum speed of 0.5 fpm.

The FBCHC The main trolley hydraulic control brake has a NUREG- [Bridge & trolley] control and holding minimum braking torque of 100%

0554 brakes should each be rated at 100% of the main trolley motor full load Section 5.1 of maximum drive torque that can be motor torque. The electric parking (Item 4) developed at the point of application. brake has a minimum braking torque of 75% of the main trolley motor full load motor torque.

Iftwo mechanical brakes, one for The FBCHC main trolley NURE4G- control and one for holding, are hydraulic control brake is 0554 provided, they should be adjusted with actuated by a foot lever located in Section 5.1 one brake in each system leading the the cab. The electric parking (Item 5) other and should be activated by brake only engages when the release or shutoff of power. This magnetic main [power] line applies to both trolley and bridge. disconnect is in the open position.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 31 of 44 and Section Guidance Evaluation Notes NUREG- The [bridge and trolley] brakes should The FBCHC trolley brakes have 0554 also be mechanically tripped to the Section 5.1 on" or uholding position in the event of no such feature.

Sectin6) a malfunction in the power supply or an (Item 6) overspeed condition.

The FBCHC operating cab includes a ureset-stop" control NUREG- Provisions should be made for manual panel that opens the main Section 5.1 emergency operation of the [bridge [power] line magnetic contactor, (Item 7) and trolley] brakes. cutting all power hoist. The electric the trolley to trolley and parking can then be engaged.

The FBCHC main trolley drive is equipped with a foot-operated, NUREG- The [bridge and trolley] holding brake hydraulic shoe-type brake for 0554 should be designed so that it cannot be normal service braking. The Section 5.1 used as a foot-operated slowdown shoe-type parking (holding) brake (Item 8) brake. is non-foot-operated and automatically engages in the

_ power-off' condition.

The FBCHC has no drag brakes.

A hydraulic brake is used for NUREG- trolley control. The hydraulic foot-0554 [Bridge and trolley] drag brakes should adjusting and receives periodic Section 5.1 not be used, inspection and adjustment in (Item 9) accordance with he manufacturer's recommendations.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 32 of 44 Document Guidance Evaluation Notes and Section Giac The term "opposite driven wheels" refers to the rotation of the drive wheel at each end of a crane bridge or trolley when NUREG- Opposite-driven wheels on bridge or facing the end of each axle.

0554 trolley that support bridge or trolley on When originally manufactured, The FBCHC main hoist does not Section 5.1 their runways should be matched and the FBCHC main trolley drive's have a bridge.

Section 5.10 their)rushoulds bc miamethed a mechanically shaft connected, (item 10) should have identical diameters. "opposite-driven wheels" were matched for diameter in accordance with the manufacturer's specified tolerance limits.

NUREG- Trolley and bridge speed should be The FBCHC main trolley has an The FBCHC Main Trolley functions as 0554 limited. The speed limits indicated for inching speed of 0.5 fpm and a Section 5.1 slow operating speeds for trolley and maximum normal speed of 50 a bridge as used in CMAA-70-1 971, SItio151 bridge in specification CMAA470 are fpm, which is classified as "slow" Table 70-6.

(Iem ) recommended for handling MCLs. in CMAA-70-1971, Table 70-6.

The FBCHC bridge and trolley drive motors and electrical controls are not equipped with either overspeed or overtravel NUREG- Limiting devices, mechanical and/or protective devices. Overtravel is 0554 electrical, should be provided to control stopped by contact of the bridge Section 5.2 or prevent overtravel and overspeed of and trolley-mounted bumpers (ie ) the trolley and bridge. with bridge and runway-mounted (Item 1) tend travel stops. The FBCHC is precluded by design from travel outside of the safe load path designated for cask handling operations.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 33 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section The FBCHC trolley is provided NUREG- Buffers for bridge and trolley travel with bumpers having sufficient 0554 should be included at the end of the energy absorbing capability to Section 5.2 railsh stop the bridge and trolleys when (Item 2) . either is traveling at a speed of 40% of rated load speed.

Safety devices such as limit-type The FBCHC trolley does not have NUREG- switches provided for malfunction, such limit-type devices. Bumpers 0554 inadvertent operator action, or failure are provided at the ends of the Section 5.2 should be in addition to and separate rails. The FBCHC is precluded by (Item 3) from the limiting means or control design from travel outside of the (tm) fmtlimiting mea opera. safe load path designated for devices provided for operation. cask handling operations.

The horsepower rating of the hoist driving motor should be matched with The calculated required 125-ton the calculated requirement that main hoist horsepower is 55.5, NUREG- includes the design load and based upon an actual hoist speed 0554 acceleration to the design hoisting of 5.9 fpm. This is 7-1/2% less Section 6.1 speed. Overpowering of the hoisting than the rated motor horsepower (Item 1) equipment would impose additional of 60 hp. This surplus motor strain on the machinery and load- horsepower is within acceptable carrying devices by increasing the design limits.

hoisting acceleration rate.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 34 of 44 Document Guidance Evaluation Notes and Section To preclude excessive drive-motor torque, the maximum torque capability of the electric motor drive for hoisting should not exceed the rating or capability of the individual components of the hoisting system required to hoist The two main hoist upper limit the MCL at the maximum design hoist switches will interrupt the hoisting NUREG- speed. Overpower and overspeed motion and set the two holding 0554 conditions should be considered an brakes, each of which is capable Section 6.1 operating hazard, as they may of stopping the upward (Item 2) increase the hazard of malfunction or movement of the load block the inadvertent operation. It is essential recommended 3 inches, that the controls be capable of preventing a two-block event.

stopping the hoisting movement within amounts of movement that damage would not occur. A maximum hoisting movement of 8 cm (3 in) would be an acceptable stopping distance.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 35 of 44 and Section Guidance ________ __ _ _ _

Electric circuitry design should be carefully considered so that the controls and safety devices ensure safe holding of the critical load when called upon to perform their safety function. For elaborate control The FBCHC design includes a systems, radio control, or ultimate radio remote controller. A transfer control under unforeseen conditions of switch and interlocking circuitry distress, an 'emergency stop button" permits control from only the NUREG- should be placed at ground level to bridge-mounted control panel or 0554 remove power from the crane the remote controller at any one For the FBCHC, the DRL and MCL Section 6.1 independently of the crane controls. time. The radio remote control are the same.

(Item 3) For cranes with a DRL rating much system has the same operational higher than the MCL rating, it may be features for bridge, trolley, and necessary to provide electrical or hoist operation as the bridge-mechanical resetting of overload mounted control panel, including sensing devices when changing from an emergency stop button.

one operation to the other. Such resetting should be made away from the operator cab location and should be included in an administrative control program.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR I RBG-46478 Page 36 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE DocumentGudneEautoNts and Section Guidance The (driver) control systems should be designed as a combination of electrical and mechanical systems and may include such items as contactors, The main hoist controls are relays, resistors, and thyristors in designed as a combination of combination with mechanical devices electrical and mechanical and mechanical braking systems. The systems as described, in control system(s) provided should accordance with the design include consideration of the hoisting (raising and lowering) of all loads, standards in place at the time.

The mechanical and electrical NUREG- included the rated load, and the effects systems associated with the 0554 of the inertia of the rotating hoisting hoist(s) have been designed with Section 6.2 machinery such as motor armature, due consideration of the effects of shafting and coupling gear reducer, all applicable and significant and drum. If the crane is to be used for loads, forces, and moments. The lifting spent fuel elements, the control FBCHC is physically unable to system should be adaptable to include access individual spent fuel interlocks that would prevent trolley assemblies in the spent fuel and bridge movements while the load racks.

is being hoisted free of a storage rack, as may be recommended in Regulatory Guide 1.13, "Spent Fuel Storage Facility Design Basis".

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 37 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes Means should be provided in the motor All motors meet applicable NEMA control circuits to sense and respond to MG1 standards. The FBCHC such items as excessive electric main hoist motors are provided current, excessive motor temperature, with thermal detectors embedded overspeed, overload, and overtravel. in the stator windings that trip the Controls should be provided to absorb motors in the event they NUREG- the kinetic energy of the rotating overheat. The main hoist motor 0554 machinery and stop the hoisting controls also include the following Section 6.3 movement reliably and safely through protective devices: current a combination of electrical power overload protection, undervoltage controls and mechanical braking protection, phase loss protection, systems and torque controls if one overspeed protection, hoist rope or one of the dual reeving overtravel protection, hoist systems should fail or if overloading of overload protection, and hoist an overspeed condition should occur. slack line protection.

Increment drives for hoisting may be provided by step-less controls or inching motor drive. If jogging or The main hoist and trolley are NUREG- plugging is to be used, the control provided with inching motors that 0554 circuit should include features to travel at 0.5 fpm. Jogging or Section 6.4 prevent abrupt change in motion. Drift plugging is not required for cask point in the electric power system, handling activities.

when provided for bridge or trolley movement, should be provided only for the lowest operating speeds.

Safety devices such as limit-type The FBCHC is provided with limit NUREG- switches provided for malfunction, switches and load-limiting 0554 inadvertent operator action, or failure swic hes d are Section 6.5 should be in addition to and separate devices. These devices are from the limiting means or control separate from norsal operating devices provided for operation. controls.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 38 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document and Section Guidance Evaluation Notes The operating control system, NUREG- The complete operating control system including the ustop-reset' panel is 0554 and provisions for emergency controls located in the operator's cab, 0554 for the overhead crane handling located between the main hoist Section 6.6 system should preferably be located in and the auxiliary hoist at the end (Iem ) a cab on the bridge. of the auxiliary bridge facing the centerline of the main trolley.

The radio remote control device I emulates all operations of the NUREG- bridge-mounted control panel.

0554 When additional operator stations are During remote operation, the 0554 considered, they should have control function of foot operated braking Section 6.6 systems similar to the main station. is achieved automatically (item 2) following bridge motor de-energization.

Manual controls for hoisting and trolley movement may be provided on the NUREG- trolley. Manual controls for the bridge The radio remote control device 0554 may be located on the bridge. Remote emulates all operations of the Section 6.6 control or pendent control for any of bridge-mounted control panel.

(Item 3) these motions should be identical to those provide on the bridge cab control panel.

The radio remote control station Cranes that use more than one control includes a transfer switch and NUREG- station should be provided with interlocking circuitry to restrict Section 6.6 electrical interlocks that permit only crane control to either the bridge-(Item 66 one control station to be operable at mounted control station or the (Item 4) any one time. remote control station at any time.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 39 of 44 Document Guidance Evaluation Notes and Section NUREG- In the design of the control system, The bridge-mounted and radio 0554 provision for and locations of devices remote control stations include an Section 6.6 for control during emergency emergency stop button.

(Item 5) conditions should be provided.

Installation instructions should be provided by the manufacturer. These The crane operating and NUREG- should include a full explanation of the maintenance manual was 0554 crane handling system, its controls, provided by the manufacturer to Section 7.1 and the limitations for the system and Entergy and have been translated should cover the requirements for Entorgyand been translated installation, testing, and preparations for operation.

During and after installation of the crane, the proper assembly of NUREG- electrical and structural components FBCHC functional testing 0554 should be verified. The integrity of all including no-load and full load Section 7.2 control, operating, and safety systems tests of all motions.

should be verified as to satisfaction of installation and design requirements.

NUREG- A complete check should be made of A complete mechanical and 0554 all the crane's mechanical and electrical check of the crane was Section 8.1 electrical systems to verify the proper made to prepare the crane for SIecto 81) installation and to prepare the crane for testing.

(Item 1) testing.

Information concerning proof testing on components and subsystems that was NUREG- required and performed at the Documentation of all required 0554 manufacturer's plant to verify the ability factory and field tests was Section 8.1 of components or subsystems to factorydandpafield thesta (Ieo 81 perform should be available for the procurement documents.

checking and testing performed at the place of installation of the crane system.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 40 of 44 Document Guidance Evaluation Notes and Section The crane system should be static load The FBCHC was load-tested both NUREG- tested at 125% of the MCL. The tests indoors (as part of initial should include all positions generating 0554 maximum strain in the bridge and acceptance) and outdoors (as Section 8.2 trolley structures and other positions as part of post-modification testing of (Item 1) recommended by the designer and the outdoor crane structure) at manufacturer. 1.25 times the rated load.

After satisfactory completion of the 125% static test and adjustments required as a result of the test, the crane handling system should be given full performance tests with 100% of the NUREG- MCL for all speeds and motions for 0554 which the system is designed. This The FBCHC was given a loaded Section 8.2 should include verifying all limiting and running test of all motions at 1.25 It 2 safety control devices. The features times its rated capacity.

(tem 2) provided for manual lowering of the load and manual movement of the bridge and trolley during an emergency should be tested with the MCL attached to demonstrate the ability to function as intended.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 41 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document Guidance Evaluation Notes and Section When equipped with an energy-controlling device between the load and head blocks, the complete hoisting machinery should be allowed to two-block during the hoisting test (load block limit and safety devices are bypassed). This test, conducted at Per NUREG-0612, Appendix C, Page NUREG- slow speed without load, should - C-3, item (8), the FBCHC main hoist 0554 provide assurance of the integrity of A two-blocking test was not includes two travel limit switches, Section 8.3 the design, the equipment, the performed on the FBCHC. each of independent design, used in (Item 1) controls, and the overload protection series, andealode limng devic devices. The test should demonstrate seres, and a load limitng device.

that the maximum torque that can be developed by the driving system, including the inertia of the rotating parts at the overtorque condition, will be absorbed or controlled during two-blocking or load hang-up.

The complete hoisting machinery A load hang-up test was not should be tested for the ability to performed on the FBCHC. Each sustain a load hang-up condition by a hoist is provided with an overload The FBCHC does not have the NUREG- test in which the load-block-attaching c X interlock circuitry suggested by 0554 points are secured to a fixed anchor or cutoff that senses an overload on NUREG-0612, Appendix C, page C-Section 8.3 an excessive load. The crane t t aops e oing 4, item (9), Cask loading procedures (Item 2) manufacturer may suggest additional motion, but allows sae lowe 4ite l (9) prohibit simultaneous FBCHC or substitute test procedures that will limiting device is adjustable up to trolley and hoisting movement.

ensure the proper functioning of 130% of rated load.

protective overload devices.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 42 of 44 Document and Section Guidance Evaluation Notes Operational tests of crane systems should be performed to verify the A functional test of the FBCHC NUREG- proper functioning of limit switches and was performed to verify its 0554 other safety devices and the ability to complete range of travel and Section 8.4 perform as designed. However, special functionality with and without a arrangements may have to be made to load on the main and auxiliary test overload and overspeed sensing hooks.

devices.

Essentially, the MCL rating of the crane should be established as the rated load capacity, and the design The rated load for each hoist is rating for the degradable portion of the clearatedarked on each The handling system should be identified to aruy marked on the crane. The NUREG- obtain the margin available for the design rated load (125 tons). The 0554 maintenance program. The MCL crane receives periodic Section 8.5 should be plainly marked on each side rereceive penanc of the crane for each hoisting unit. It is preventive maintenance and recommended that the critical-load- inspection to address degradation handling cranes should be issues.

continuously maintained above MCL capacity.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 Page 43 of 44 THE RBS FUEL BUILDING CASK HANDLING CRANE Document and Section Guidance Evaluation Notes The crane designer and crane manufacturer should provide a manual of information and procedures for use in checking, testing, and operating the crane. The manual should also NUREG- describe a preventive maintenance An O&M manual was provided 0554G program based on the approved test with the FBCHC. The 0554 results and information obtained durin recommendations in this manual Section 9 the testing. It should include such have been included in the site (item 1) items as servicing, repair replacement operating and maintenance requirements, visual examinations, procedures for the crane.

inspections, checking, measurements, problem diagnosis, nondestructive examination, crane performance testing, and special instructions.

The operating requirements for all travel movements (vertical and horizontal movements or rotation, An O&M manual was provided NUREG- singly or in combination) incorporated with the FBCHC. The 0554 in the design for permanent plant rcmedtosi hsmna Section 9 cranes should be clearly defined in the recommendations inthis manual (item 2) operating manual for hoisting and for hatin and intenance trolley and bridge travel. The designer operating and maintenance should establish the MCL rating and procedures for the crane.

the margin for degradation of wear-susceptible component parts.

Attachment to NUREG-0612 AND NUREG-0554 COMPARISON MATRIX FOR RBG-46478 THE RBS FUEL BUILDING CASK HANDLING CRANE Page 44 of 44 Document Guidance Evaluation Notes While it is a non-safety-related A quality assurance program should be component, The FBCHC will be NUREG- established to the extent necessary to designated as "Quality Assurance 0554 include the recommendations of this Program Applicable" in the RBS Section 10 report for the design, fabrication, quality assurance program. All iem 1) installation, testing, and operation of modifications, maintenance, crane handling systems for safe testing, and inspections will be handling of critical loads. performed as safety-related activities.

The FBCHC was a commercial-In addition to the quality assurance grade purchase made in the late-program established for site assembly, 1970s. While 10 CFR 50 installation, and testing of the crane, R.G.pedi 1.2 rqAuidamnce adino applicable procurement documents Apni 1 quirementsdand NUREG- should require the crane manufacturer apply, the procurement 0554 to provide a quality assurance program specification required the supplier Section 10 consistent with the pertinent provisions to have an inspection, testing, (Item 2) of Regulatory Guide 1.28, "Quality documentation program to Assurance Program Requirements ensure the crane met the (Design and Construction),' to the requirements of the specification.

extent necessary. In addition, certain key fabrication steps were witnessed or verified by the architectlengineer for RBS.

NUREG- The (quality assurance) program NUREG-0554 did not exist at the 0554 should address all the time the FBCHC was designed Section 10 recommendations in this NUREG. Also and fabricated. Crane operator (Item 3) included should be qualification qualifications are part of the RBS requirements for crane operators. training program.

v t e Letter Sequence Request
TAC:MC6327, (Approved, Closed)
Initiation Request, Request Acceptance... Supplement, Supplement, Supplement Administration Withholding Request Acceptance Meeting Questions 19 August 2005 Answers Results Approval, Approval Other:
MONTHYEAR2005-12-06 [Table View]

RBG-46478, Revised License Amendment Request (LAR) 2004-26, Use of the Fuel Building Cask Handling Crane for Dry Spent Fuel Cask Loading Operations Dated March 8, 2005

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Subject:

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Dear Sir or Madam:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 REFERENCES

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