RBG-47072, License Amendment Request 2010-04, Heavy Load Movement Over Fuel Assemblies

License Amendment Request 2010-04, Heavy Load Movement Over Fuel Assemblies

ML102630247
Person / Time
Site:	River Bend
Issue date:	09/09/2010
From:	Mike Perito Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-47072, TAC MA7365
Download: ML102630247 (21)

Text

Entergy Operations, Inc.

River 8end Station 5485 US Highway 61 St. Francisville, LA 70775 Tel 225 381 4374 SEnteigy Fax 225 381 4872 mperito@entergy. corn Michael Perito Vice President, Operations River Bend Station RBG-47072 September 9, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request 2010-04 Heavy Load Movement Over Fuel Assemblies River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47

REFERENCES:

(1) River Bend Station License Amendment Request 1999-31, "Heavy Load Exception to Allow Movement of Spent Fuel Pool Gates to Replace Gate Seal"," dated December 16, 1999 (2) Issuance of Amendment No. 108 to River Bend Station Operating License, dated January 13, 2000 (TAC No. MA7365)

RBF1-10-0125 File No.: G9.5

Dear Sir or Madam:

In accordance with 10CFR50.59(c) and 10CFR50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment of Facility Operating License No. NPF-47, for River Bend Station (RBS). This request involves an unreviewed safety question (USQ) concerning the movement of spent fuel pool gates, which constitutes a "heavy load" movement over fuel assemblies.

The proposed change was reviewed against the criteria of 1 OCFR50.92, and was determined to not involve a significant hazards consideration. Attachment 1 provides a description of the proposed changes and the associated justification (including the determination of no significant hazards consideration). Attachment 2 contains the mark-up of affected pages reflecting the amendment being requested. The proposed changes have been reviewed by the RBS Onsite Safety Review Committee.

Entergy has reviewed this request against the criteria of 10CFR50.22 for environmental considerations. The proposed change does not involve a significant hazards consideration. Also, the type and amount of effluent released from RBS is not changed.

Further, the amount of individual or cumulative occupational dose does not increase significantly as a result of this change. Therefore, based on the foregoing, Entergy has concluded that the proposed change meets the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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In accordance with 10CFR50.91, Entergy is notifying the State of Louisiana of this LAR by transmitting a copy of this letter and attachments to the designated state official.

Commitments contained in this letter are summarized on Attachment 4.

Entergy requests approval of this change by September 9, 2011. Once approved, the amendment will be implemented within 60 days of issuance. If you have any questions regarding this request or require additional information, please contact Mr. David N.

Lorfing at (225) 381-4157.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 9, 2010.

Respectf ully, Michael Perito Vice President - Operations Attachments: 1. Evaluation of Proposed Change

2. Mark-up of Affected Pages

3. Excerpt of RBS drawing ES-62E

4. List of Commitments I

cc: U. S. Nuclear Regulatory Commission Region IV 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Sr. Resident Inspector P. O. Box 1050 St. Francisville, LA 70775 Mr. Jim Calloway Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326 Mr. Jeffrey P. Meyers Louisiana Department of Environmental Quality Attn: OEC-ERSD P.O. Box 4312 Baton Rouge, LA 70821-4312 U.S. Nuclear Regulatory Commission Attn: Mr. Alan Wang Mail Stop MS 0-8 B1 Washington, DC 20555-0001

Attachment 1 RBG-47072 Evaluation of Proposed Changes

Evaluation of Proposed Changes Page 1 of 10

1. Summary Description This amendment request proposes to add a permanent exception to River Bend Station Technical Requirements Manual (TRM) section 3.9.14, "Crane Travel - Spent and New Fuel Storage, Transfer, and Upper Containment Fuel Pools," to allow for movement of fuel pool gates over fuel assemblies for maintenance. This exception will also be described by revision to Updated Safety Analysis Report (USAR) section 9.1.2.2.2, "Fuel Building Fuel Storage," and section 9.1.2.3.3, "Protection Features of Spent Fuel.

Storage Facilities."

2. Description Of Proposed Change The proposed change would add a permanent exception to TR 3.9.14, allowing travel of loads in excess of 1200 pounds (hereafter referred to as "heavy loads") over fuel assemblies in the spent fuel storage pool. The exception would allow movement of the gates, provided we comply with the defense-in-depth recommendations, or take alternative compensatory measures, given in NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

Corresponding sections of the RBS USAR will be revised to be consistent with the exception and to state that the provisions of NUREG-0612 will be met. The load of the gate (approximately 1600 pounds) and the rigging (approximately 400 pounds) exceeds the analyzed load for travel over the spent fuel storage racks. In accordance with the guidance in NRC Bulletin 96-02, "Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment," issued April 11, 1996, and 10CFR50.59, these changes are deemed to involve an unreviewed safety question.

Therefore, Entergy is submitting this request in accordance with 1 OCFR50.59(c) and 10CFR50.90.

3. RBS Current Licensing Basis The fuel building fuel storage facilities consist of three separate but interconnected stainless steel-lined concrete pools. The spent fuel storage pool is the largest of these pools. Adjacent to the spent fuel storage pool are the cask pool and the lower inclined fuel transfer system pool. Each of these two pools is separated from the fuel storage pool by a full-height wall broken by a watertight gate. The watertight gates are normally open. These gates are closed to seal their respective pools during cask handling and equipment maintenance operations. The gates are designed as Seismic Category I structures to withstand all loads and loading combinations, as defined in Section 3.8 of the RBS USAR. The gates are equipped with inflatable pneumatic seals to provide the necessary watertight barrier.

Movement of heavy loads is precluded by restrictions in TR 3.9.14 from traveling over spent fuel assemblies in the fuel building spent fuel or upper containment fuel storage pool racks. Administrative controls impose limits on loads weighing more than 1200 pounds. These limits assure that, in the unlikely event of a load drop over fuel assemblies, offsite radiological consequences will not exceed Standard Review Plan section 15.7.4 guidelines.

Evaluation of Proposed Changes Page 2 of 10 USAR Section 9.1.2.2.2, "Fuel Building Storage," discusses the use of the 15-ton fuel storage bridge crane for the high-density spent fuel rack installation. Subsequent to the installation of these racks, the crane is used only to move light loads over stored spent fuel. Administrative controls exist to prevent transport of heavy loads over stored spent fuel.

USAR Section 9.1.2.3.2.2, "Fuel Building Fuel Storage," describes the storage rack structure as being capable of withstanding the impact resulting from a falling object possessing 3800 foot-pounds kinetic energy. The structural design of the racks is such that under this impact force, no lateral displacement of fuel occurs; therefore, subcritical spacing is maintained.

USAR Section 9.1.4.3, "Safety Evaluation, Fuel Handling System," states that, for the fuel building, the kinetic energy of any dropped object does not exceed that of a channeled fuel assembly as described in USAR Section 15.7.4, with the exception of new fuel when being transported by the fuel building bridge crane.

During the original plant operating licensing process for RBS, the NRC reviewed the RBS program for control of heavy loads. In NUREG-0989, NRC Safety Evaluation Report for RBS, Supplement 2, the NRC Staff concluded that RBS implementation of the guidelines for Phase 1 of NUREG-0612 was acceptable and no further action for Phase 2 was required. Our commitment to the guidelines in NUREG-0612 was reiterated in response to NRC Bulletin 96-02, "Movement of Heavy Loads Over Spent Fuel, Fuel in the Reactor Core, or Over Safety Related Equipment." (See letter no. RBG-42916 from Entergy to NRC, dated August 29, 1996.)

RBS performed an assessment of Regulatory Issue Summary 2008-28, "Endorsement of Nuclear Energy Institute Guidance for Reactor Vessel Head Heavy Load Lifts." Gaps identified by that assessment were corrected, such that the station is now in compliance with that guidance.

4. Details of Proposed Changes to RBS Current Licensing Basis The proposed changes add an exception to the movement of loads over the spent fuel pool. The exception is necessary to allow for movement of the spent fuel pool gates, which weigh more than the currently analyzed load over the spent fuel pool, for gate repair or seal replacement. Specific changes are as follows (revisions indicated by underline):

(a) TR 3.9.14, "Crane Travel, Spent and New Fuel Storage, Transfer, and Upper Containment Fuel Pools," will be changed as follows:

TLCO 3.9.14: Except for movement of spent fuel pool gates, loads in excess of 1200 pounds shall be prohibited from travel over fuel assemblies in the spent or new fuel storage, transfer or upper containment fuel pool racks, and all loads shall be prohibited from travel over irradiated fuel when water level is < 23' over the irradiated fuel.

Evaluation of Proposed Changes Page 3 of 10 TSR 3.9.14.1: The fuel building crane loads shall be verified to weigh less than or equal to 1200 pounds, except for movement of spent fuel pool gates.

(b) USAR Section 9.1.2.2.2, "Fuel Building Fuel Storage," will be changed to state, in part, the following:

The 15-ton fuel building bridge crane is used for the rack installation.

Subsequent to the installation of the racks, the crane will be utilized for transporting only light loads over stored spent fuel, except for the movement of spent fuel pool gates. Administrative controls exist to prevent the transport of heavy loads other than fuel pool pates over spent fuel.

(c) USAR Section 9.1.2.3.3, "Protection Features of Spent Fuel Storage Facilities," will be changed to state, in part, the following:

The layout of the fuel handling areas around the fuel pool in the fuel building (Fig.

1.2-20 and 1.2-22) is designed such that the traversing of any heavy objects over stored spent fuel is precluded. The only heavy obiects that will be moved in the vicinity of stored spent fuel are spent fuel pool gates, as required for repair or seal replacement. The load handling of the gates will be performed in accordance with the intent of NUREG-0612 guidelines for reducing potential for an accidental load drop. Loads associated with movement of spent fuel pool gates are approximately 2000 pounds, which accounts for the weight of a gate plus the rigging. The spent fuel cask pool and the spent fuel cask trolley are physically outside the boundaries of the fuel pool, with the only interconnection being a fuel transfer slot which is sealed by a watertight gate. Therefore, the spent fuel cask handling crane, which passes over the cask storage area, cannot in any way be traversed over any portion of the fuel pool.

5. Technical Evaluation The fuel building storage facilities consist of three interconnected stainless steel-lined concrete pools. The spent fuel storage pool is the largest of these pools. Adjacent to the fuel storage pool are the cask pool and the lower inclined fuel transfer system (IFTS) pool. Each of those pools is separated from the fuel storage pool by a full-height wall encompassing a watertight gate. The watertight gates are normally open. These gates are closed to seal their respective pools during dry fuel storage cask loading and equipment maintenance operations. The gates are designed as Seismic Category 1 structures to withstand all loads and loading combinations, as defined in Section 3.8 of the RBS USAR. The gates are equipped with inflatable pneumatic seals to provide the watertight barrier.

The gate seal life had been evaluated to be 14 years. The RBS preventive maintenance program requires the gate seals to be replaced on a ten year'frequency. The previous seal replacement performed in February 2000. The late date for the next scheduled replacement is July 29, 2012. This date is within the recommended service life limits of the seals.

Evaluation of Proposed Changes Page 4 of 10 The NRC issued guidance for controlling heavy loads in NUREG-0612. The proposed changes will allow movement of a heavy load over spent fuel using the guidelines of NUREG-0612. The proposed method for conduct of the movements involves the use of two cranes to provide redundancy for the load. This method is described below. Plan drawing ES-062E (Attachment 3) is marked with the proposed pathway for the movement. The IFTS pool gate is designated on design documents as FNS-GATE1, and the cask pool gate is designated as FNS-GATE2.

Proposed method:

a. Spent fuel pool gates weigh approximately 1600 lbs. each. Each of these gates are to be lifted using MHF-CRN1, fuel building bridge crane (lifting capacity, 15 tons), and the auxiliary hook of MHF-CRN2, spent fuel cask crane (lifting capacity, 15 tons). Neither of these two cranes can be brought directly over the spent fuel gates. Based on a dry run of the cranes, the closest the bridge crane hook can be brought over the spent fuel gates is approximately 3'-2", and the closest the auxiliary hook of the spent fuel cask crane can be brought over the spent fuel gate is approximately 6'-0". Therefore, the horizontal distance between the two hooks will be approximately 9'-2".

b. Select all of the rigging equipment (slings, chains, hoists, shackles, etc.) for a minimum rated capacity of 5 tons.

c. Connect the rigging equipment to the lugs on the lifting beam and to the crane hooks.

d. Move the cranes such that the centerline of the hooks is aligned with the centerline of FNS-GATE1.

e. Gate FNS-GATE1 is to be rigged first. Attach the lifting beam to the top of FNS-GATE1.

f. Using the lower hoist, lift the gate enough to clear the hinges. Do not apply more than 3700 lbs of force for releasing the gate from its hinges.

g. After the initial lift, move the gate westward sufficiently to clear the hinges.

h. Move the gate northwards parallel to the east wall of the spent fuel pool by moving both the cranes simultaneously until the gate reaches the opening for FNS-GATE2.

i. Rotate the gate enough to be able to move it through the gate opening in the wall. Move the gate under the auxiliary hook of the cask crane by using the two upper hoists and ensuring that the bottom of the gate clears the bottom of the opening in the wall. At this position, the full load of the gate will be carried by the auxiliary hook of the cask crane.

j. Move the gate eastward to the center of the cask crane.

Evaluation of Proposed Changes Page 5 of 10

k. Raise the pool gate by raising the cask crane hook until the bottom of the gate is approximately 6" above the upper shelf in the cask pool).

1. Move the gate northward and place it on the floor close to the north wall with the upper part of the gate resting against the north wall. As a good practice, tie resting gate to pool handrails.

m. Reduce the length of the rigging above the gate by removing the hoists and

-dynamometer. Reattach the auxiliary hook.

n. Raise the gate to clear the floor or any obstructions by approximately 6" and move it to its laydown area.

o. Follow the above sequence in reverse order for reinstallation of the gate.

p. Perform rigging for FNS-GATE2, when required, in a manner similar to that outlined for FNS-GATE1.

Justification:

The proposed load lift of the fuel pool gate for replacement of the seal conforms to all of the NUREG-0612 guidelines except for the use of a non-single-failure-proof crane over the spent fuel pool. The defense-in-depth approach of NUREG-0612, Section 5.1, includes:

a. sufficient operator training and equipment inspection to assure reliable operation of handling,

b. safe travel paths through procedures and operator training to avoid heavy loads being carried, and,

c. mechanical stops or electrical interlocks to prevent movement of heavy loads over irradiated fuel, or in proximity to equipment associated redundant shutdown paths.

Section 5.1 also allows certain alternative measures to compensate for deficiencies in (b) and (c) above. These alternative measures can include increasing crane reliability by providing dual load paths for certain components and increased safety factors.

The proposed load lift of the fuel pool gates meets the intent of the above approach and also meets the intent of NUREG-0612, Section 5.1.6, "Single-Failure Proof Handling System," based on the following considerations:

a. The fuel building bridge crane has a rated capacity of 15 tons and the auxiliary hook of the cask crane also has a rated capacity of 15 tons. The main hook of the cask crane is rated for 125 tons. Both of these cranes meet NUREG-0612 criteria from Section 5.1.1 for cranes. Both of these cranes are qualified for applicable seismic loading. Though neither of these cranes is single-failure proof, the load lift meets the intent of the Section 5.1.5 (I) (a) specifying use of

Evaluation of Proposed Changes Page 6 of 10 single-failure proof crane. This is achieved by providing crane redundancy by lifting the gate using two cranes - the bridge crane and the cask crane. If the cask crane hook restraining mechanism fails, the full load of the fuel pool gate will be supported by the bridge crane. The fuel pool gate will lower, but will not impact the fuel pool racks as the bottom of the gate will still remain well above the top of the fuel racks.

b. The crane redundancy will not apply to the cask crane when the load is fully transferred to this crane, once the gate has been moved into the cask pool.

However, an accidental drop of the gate from the cask crane in the cask pool would be enveloped by the load drop analysis already performed for the cask drop. Reference the RBS USAR, Section 9.1.4.3, for a summary of the cask drop analysis.

c. The rated capacity of each of the two cranes is 15 tons (except for the main hook of the cask crane which is 125 tons), and the total weight of the lifted load is approximately 2000 pounds. Therefore, there is ample safety margin for this load.

d. All slings and associated rigging equipment meet the requirements of NUREG-0612, Section 5.1.1(5) and 5.1.6(l) (b) (ii), for the single-failure-proof handling systems. Interfacing lift points have a minimum factor of safety of five (5) with respect to ultimate load for dual or redundant lift points and a minimum factor of safety of ten (10) for non-dual or non-redundant lift points.

USAR Sections affected by this rigging activity will be revised following NRC approval of License Amendment Request 2010-04. Rigging work will be done in accordance with RBS procedures. Affected RBS procedures will be revised to include the proposed load lift of the spent fuel pool gates. The safe load path for movement of the load will be included in the appropriate procedure. Crane operator training will be conducted prior to performing the move. Lifting and rigging equipment will be inspected prior to the movement.

6. Precedence License Amendment Request 1999-31 (Reference 1) was submitted and processed on an exigent basis in support of refueling outage no. 9 following the failure of the IFTS gate seal approximately four months prior to the outage. It is now being requested that the exception for movement of the gates over fuel assemblies for maintenance be made permanent.

7. Regulatory Evaluation Heavy loads are precluded by TR 3.9.14 from traveling over spent fuel assemblies in the fuel building spent fuel or upper containment fuel storage pool racks. Established administrative controls impose limits on loads weighing more than 1200 pounds. These limits assure that, in the unlikely event of a load drop over fuel assemblies, offsite radiological consequences will not exceed Standard Review Plan section 15.7.4 guidelines. USAR Section 9.1.2.2, "Fuel Building Storage," describes the use of the 15-

Evaluation of Proposed Changes Page 7 of 10 ton fuel building bridge crane for the high-density spent fuel rack installation.

Subsequent to the installation of these racks, the crane is used only to move light loads over stored spent fuel.

Administrative controls exist to prevent transport of heavy loads over stored spent fuel.

USAR Section 9.1.2.3.2.2, "Fuel Building Fuel Storage," discusses that the storage rack structure can withstand the impact resulting from a falling object possessing 3800 foot-pounds kinetic energy. The structural design of the racks is such that under this impact force, no lateral displacement of fuel occurs; therefore, subcritical spacing is maintained.

USAR Section 9.1.4.3, "Safety Evaluation, Fuel Handling System," discusses that, for the fuel building, the kinetic energy of any dropped object does not exceed that of a channeled fuel assembly, with the exception of new fuel when being transported by the fuel building bridge crane.

The proposed changes add a permanent exception to the movement of loads over the spent fuel pool. The exception is necessary to allow for movement of the spent fuel pool gates, which weigh greater than the currently analyzed load over the spent fuel pool, for gate repair or seal replacement.

8. No Significant Hazards Consideration Determination Entergy proposes-to change the USAR to incorporate revisions to the TRM through the approval of this LAR. The changes will allow a permanent exception for movement of the spent fuel pool gates, each of which represents a load greater than the current analyzed load, over fuel assemblies. According to the guidance in NRC Bulletin 96-02, "Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment" issued April 11, 1996, the proposed changes to the USAR and TRM create an unreviewed safety question. In accordance with 10CFR50.59(c),

Entergy is submitting an application for amendment of the license, pursuant to 10CFR50.90, to request NRC review and approval of the proposed change.

The Commission has provided standards for determining whether an amendment involves no significant hazards consideration, which are stated in 10CFR50.92(c). A proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in theprobability or consequences of an accident previously evaluated; or (2) create the possibility of anew or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Entergy has evaluated the proposed license amendment in accordance with 10CFR50.91 (a), and is providing its analysis of the issue of no significant hazards consideration using the three standards in 10CFR50.92(c).

a. Involved a significant increase in the probability or consequences of an accident previously evaluated.

The RBS fuel building fuel storage facilities consist of three interconnected stainless steel-lined concrete pools. The spent fuel storage pool is the largest of these pools.

Adjacent to the fuel storage pool are the cask pool and the lower IFTS pool. Each of these two pools is separated from the fuel storage pool by a full-height wall

Evaluation of Proposed Changes Page 8 of 10 encompassing a watertight gate. The watertight gates are normally open, but are closed to seal their respective pools during cask handling and equipment maintenance operations. It is necessary to lift the gates from the pools for seal replacement. The total weight of the gate including the rigging equipment is 2000 pounds. This lift is considered as a heavy, load lift since it is higher than the current analyzed light load limit of 1200 pounds for movement of loads over fuel asseblies. TRM 3.9.14 prohibits any load in excess of 1200 pounds from travel over fuel assemblies in the storage pool.

Each of the gates is designed with a pneumatic seal that, when pressurized, seals the respective pool from the spent fuel pool, forming a watertight barrier. No provisions for moving the gates over fuel assemblies were included in the licensing basis for RBS heavy loads. However, the qualified life for the gate seals necessitates that they be replaced several times over the life of the plant. Therefore, approval of an exception to the current prohibition is required to allow for replacement of the gate seals.

To perform the movement of the gate from its installed position to a position where the seal can be replaced, an engineering plan that meets the intent of NUREG-0612, "Control of Heavy Loads," has been developed. There are numerous design features, which comply with NUREG-0612 guidelines, which will preclude'the gate from dropping onto the spent fuel assemblies during the movement activity. These features include the design of the lifting devices, design of the cask and fuel bridge cranes, crane operator training, and the use of written procedures. The guidance in NUREG-0612 will be met in all respects, except that in lieu of a single failure-proof crane, the method will employ redundant and diverse means to meet the intent of single-failure proof movements.

It is proposed for the subject spent fuel pool gate lift to use a rigging method that complies with the intent of NUREG-0612 guidance. The proposed method will be accomplished through the use of fuel building bridge crane and the cask crane at the same time to provide the redundancy required to make the lift single-failure proof and satisfy NUREG-0612 single-failure proof criteria.

In the proposed method, the fuel building bridge crane and the cask crane will be used to perform the gate lifting and movement. The intent of NUREG-0612 is that in lieu of providing a single-failure-proof crane system, the control of heavy loads guidelines can be satisfied by establishing that the potential for a heavy load drop is extremely small.

The gate lifting using the bridge crane and cask crane will conform to NUREG-0612 guidelines in that the probability of the gate drop over the spent fuel assemblies is extremely small. Both cranes have a rated capacity of fifteen tons. The maximum weight of the gate and rigging is one ton. Therefore, there is ample safety factor margin

-for lifting and movements of the subject spent fuel pool gate. Special lifting devices, which have redundancy or ultimate strength of at least ten times the lifted load, will also be utilized during the rigging process. Even though neither the fuel building bridge crane or the cask crane is a single-failure proof crane, rigging the spent fuel pool gate using these cranes will provide the required redundancy that meets the intent of NUREG-0612 single-failure proof criteria.

The proposed load lift of the fuel pool gate for replacement of the seal conforms to all of the NUREG-0612 guidelines included in Section 5.1.5(1)(a) and 5.1.6. The design of the lifting lugs and associated rigging (e.g., chains, slings, shackles, hoists, etc.) conforms to the guidelines of NUREG-0612, Section 5.1.6, and "Single-Failure Proof Handling

Evaluation of Proposed Changes Page 9 of 10 System." The auxiliary hook of the cask crane has a rated capacity of fifteen tons. The cask crane is not a single-failure-proof crane. However, it meets NUREG-0612 criteria of Section 5.1.1(6) and is designed for seismic loading. As discussed above, the cask crane, alone, will handle the gate only after the gate is located inside the cask pool where drop of the gate above the spent fuel rack is no longer a concern. The cask pool area has been evaluated for an accidental drop of the spent fuel cask. There is no safety-related equipment inside the cask pool. The maximum weight of the gate and rigging is 2000 pounds. Therefore, there is ample safety factor margin for lifting the gate with the cask crane.

The probability and consequences of a seismic event are not affected by the proposed gate lift. The consequences of a seismic event during the gate lifting are insignificant since both cranes, the fuel building bridge crane and the cask crane, are seismically qualified for the lifted load. In addition, the design of all rigging conforms to NUREG-0612 guidelines, with a safety factor of 10 for the weight of the load.

Consistent with the defense-in-depth approach outlined in NUREG-0612, the movement will be conducted according to load handling instructions. Operator training will be conducted on the activity prior to the movement, and the equipment will be inspected before the movement will be performed. NUREG-0612 gives guidance that when a particular heavy load must be brought over spent fuel, alternative measures may be used. The combination of preventative measures, as proposed, minimizes the risks inherent in hauling large loads over spent~fuel to permissible levels. With these provisions and the guidance in NUREG-0612, the increase in probability of a load drop is negligible.

It is therefore concluded that the proposed gate lifting and movement does not involve a significant increase in the probability or consequences of an accident previously evaluated.

b. Create the possibility of a new or different kind of accident from any accident previously evaluated.

The lifting of the fuel pool gate in the spent fuel pool as described above minimizes the possibility of a heavy load drop onto spent fuel assemblies as not credible in accordance with NUREG-0612 single-failure-proof criteria. In addition, movement of the gate in the cask pool using the cask crane does not create the possibility of a new or different kind of accident. The cask drop accident scenario in the current RBS licensing basis (since the cask crane is not a single-failure-proof crane) envelops the accidental drop of the gate in the cask pool during handling by the cask crane. The analyzed weight of a cask is 125 tons, as compared to the 1 ton combined weight of the gate and the rigging.

It is therefore concluded that the proposed gate lifting does not create the possibility of a new or different kind of accident from any previously analyzed.

c. Invoke a significant reduction in a margin of safety.

By following the guidance in NUREG-0612, the movement of the spent fuel pool gates will have no impact on the analyses of postulated design basis events for RBS. The NRC guidance provides an acceptable means of ensuring the appropriate level of safety

Evaluation of Proposed Changes Page 10 of 10 and protection against load drop accidents. Therefore, there is no reduction in the margin of safety associated with postulated design basis events at RBS in allowing the proposed change to the RBS licensing basis. RBS will continue to meet its commitment to comply with NUREG-0612.

9. Environmental Evaluation A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10CFR20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

ATTACHMENT 2 RBG-47072 Mark-up of Affected Pages Technical Requirements Manual page TR 3.9-9 USAR Pages 9.1-12 and 9.1-22

'Except for movement of spent fuel pool gates, Crane Travel - Spent and New Fuel Storage, Transfer and Upper Containment Fuel Pools TR 3.9.14 TR 3.9.14 C1 ane Travel - Spent and New Fuel Storage, Transfer and Upper Cc ntainment Fuel Pools TLCO 3.9.14 -IVLoads in excess of 1200 pounds shall be prohibited from travel over fuel assemblies in the spent or new fuel, storage, transfer or upper containment fuel pool racks and all loads shall be prohibited from travel over irradiated fuel when water level is < 23' over the irradiated fuel.

APPLICABILITY: With fuel assemblies in the spent or new fuel storage, transfer or upper containment fuel pools.

ACTIONS CONDITION REQUIRED'ACTION COMPLETION TIME A. With the requirements A.1 Place the crane load in Immediately of the above a safe condition.

specification not satisfied.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSR 3.9.14.1 The fuel building crane loads shall be Before travel over verified to.weigh less than or equal to fuel assemblies in 1200 pounds the spent or new fuel storage pools and the lower transfer pools TSR 3.9.14.2 The reactor bui\ding pol ar crane loads Before travel over T shall be verifie to weigh less than or fuel assemblies. in equal to 1200 po ds. the upper transfer and containment fuel pools C,except for movement of spent fuel pool gates.ý RIVER BEND TR 3.9-9 Revision 123 (13vii)

RBS USAR The design of the racks precludes accidental insertion of the fuel assemblies between adjacent racks and ensures the required spacing and mechanical support of the neutron-absorbing material for reactivity control.

The fuel building spent fuel racks employ a fixed neutron absorber or poison material for criticality control. Boraflex II, manufactured by Brand Industrial Services, is used. This material ha's been tested in a fuel pool-like environment to 10(11) rad and found to behave acceptably. Alteration in Physical properties and off gassing due to irradiation and material chemical or galvanic interaction with the rack structure have been considered in the design of the racks.

The installation of the high density spent fuel storage racks is accomplished in two stages. The first stage includes the installation of 30 adapter plates welded to the floor embedment

,plates. These plates. serve as supports for the racks providing both horizontal and vertical downward restraints. The second stage to be accomplished prior to the first refueling outage includes the installation of all 20 racks. Special tools are used for the initial alignment of adapter plates and leveling of racks. After installation is complete, pool can be flooded in preparation for storage of spent fuel assemblies.

• -*10 .- *8 Spent control rod blades are stored on control rod blade storage hangers, two to a hanger, on hooks at the 101' elevation of the spent fuel pool. During control blade transit, the minimum required submergence is maintained at no less than 6 feet 9ý inches. Once the spent control blade is resting on the hanger, the tops of the highest spent control blades in underwater storage are covered by a minimum of 10 feet of water.

8+--o 10<--

• --+8A 9->2 e--*1 9->13 The 15-ton fuel building bridge crane is used for the rack installation. Subsequent to the installation of the racks, the crane will be utilized for transporting only light loads over stored spent fuel, except for movement of spent fuel pool gates.

Administrative controls exist to prevent the transport of heavy loads other than spent fuel pool gates over stored spent fuel.

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inserted language is indicated as underlined Revision 21 9.1-12

RBS USAR Since the fuel storage racks are made of noncombustible material and are stored under water, .there is no potential fire hazard.

The large water volume also protects the spent fuel storage racks from potential pipe breaks and associated jet impingement loads.

9.1.2.3.3 Protection Features of Spent Fuel Storage Facilities

"-+13

1. The layout of the fuel handling areas around the fuel pool 'in the fuel building (Fig. 1.2-20 and 1.2-22) is designed such that the traversing of any heavy objects over stored spent fuel is precluded. The only heavy objects that will be moved in the vicinity of stored spent fuel are fuel pool gates, as required for repair or seal replacement., The load handling of the pool gates will be performed in accordance with the intent of NUREG-0612 guidelines for reducing potential for an accidental load drop. Loads associated with movement of fuel pool gates are approximately 2000 pounds, which accounts for the weight of a gate plus the rigging. The spent fuel cask pool and the spent fuel cask trolley are physically outside the boundaries of the fuel pool, with the only interconnection being a fuel transfer slot which is sealed by a watertight gate. Therefore, the spent fuel cask handling crane, which passes over the cask storage area, cannot in any way be traversed over any portion of the fuel pool.

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In addition, the spent fuel cask trolley has a fixed main hoist, i.e., the hoist centerline is fixed between the runway rails with no capability for traversing between the runways. This arrangement precludes an off-center lowering of the spent fuel cask, and a vertical cask drop cannot impinge upon spent fuel racks.

The fixed main hoist arrangement also makes a cask drop at an angle unlikely. The consequences of a cask drop, at an angle or vertically, may result in local yielding and possible rupture of the cask pool liner. The watertight gate which is in the sealing position during cask transfer operations prevents loss of water from the spent fuel pool and no damage to the spent fuel results.

No safety-related equipment is located near the spent fuel cask pool or near the spent fuel cask handling area.

During all cask handling operations, the watertight gate is closed, thus restricting any water loss resulting from the consequences of a cask drop accident and postulated damage to the cask storage area.

Revision 21 9.1-22

Attachment 3 RBG-47072 Excerpt of RBS drawing ES-62E-6

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DRAWING DETAIL ES-062E (REV 6)

Attachment 4 RBG-47072 List of Commitments RBG-47072 Page 1 of 1 This table identifies actions discussed in this letter 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 completion One-time Continuing date Commitment Action Compliance

1. Affected RBS procedures will be revised X Prior to any to include the proposed load lift of the spent movement of fuel pool gates. The safe load path for the gates over movement of the load will be included in the fuel assemlies.

appropriate procedure.

2. Crane operator training will be X Prior to any conducted prior to performing the move. movement of the gates over fuel assemlies.

3. Lifting and rigging equipment will be X Prior to any inspected prior to the movement, movement of the gates over fuel assemlies.

4. Corresponding sections of the RBS X Prior to any USAR will be revised to be consistent with movement of the exception and to state that the the gates over provisions of NUREG-0612 will be met. fuel assemlies.

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