ML17341A617

Forwards Updated Rept on Interim Action for Control of Heavy Loads in Response to Sections 2.2,2.3 & 2.4 of Encl 3 to NRC 801222 Review Request

ML17341A617
Person / Time
Site:	Turkey Point
Issue date:	11/12/1981
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR L-81-473, NUDOCS 8111170282
Download: ML17341A617 (20)

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.BOX 529100 MIAMI, FL 33152+lllfg~+jr~-~%i+.FLORIDA.POWER.S.LIG~MPANY November 12, 1981 L-81-473 Office of Nuclear Reactor Regulation Attention:

Mr.Darrell G.Eisenhut, Director Division of Licensing U.S.Nuclear Regulatory Commission Washington, D.C.20555

Dear Mr.Eisenhut:

Re: Turkey Point Units 3 8 4 Docket No.50-250, 50-251 Control of Heavy Loads As requested by an NRC letter, dated December 22, 1980, Florida Power 8 Light has conducted a review of controls for the handling of heavy loads at Turkey Point Units 3 8 4.This review was conducted in accordance with NUREG 0612,"Control of Heavy Loads at Nuclear Power Plants-Resolution of TAP A-36." An update to our report of interim action taken on this subject and a report in response to Sections 2.2, 2.3, and 2.4 of Enclosure 3 to the December 22, 1980 letter are attached.$4l+~Robert E.Uhrig Vice President Advanced Systems and Technology REU/PLP/Qbd cc: Mr.J.P.O'Reilly, Region II Harold F.Reis, Esquire NO'l/L 6 t98f~-"'~RmuIA1Otg JQ 3 COAIMIg 10II/re~8iiii70282 Bi'iii2 PDR ADOCK 05000250', PD~R PEOPLE...SERVING PEOPLE ATTACHMENT Re: Turkey Point Units No.3 and No.4 Interim Actions for Control of Heavy Loads The NRC letter dated December 22, 1980 (subject: Control of Heavy Loads)requested implementation of interim actions for the training, qualification, and conduct of crane operators.

Florida Power 5 Light will implement, at Turkey Point Unit No.3 and 4, Section 2-3.1 (gualifications for and conduct of Operators) of Chapter 2-3 of ANSI Standard B 30.2-1976 with the following exceptions to the referenced paragraphs:

Paragraph 2-3.1.2.We will require an eye test of 20/40 in both eyes for new employees.

Paragraph 2-3.1.7.f, g and h.Because of the power requirements of the crane motor heaters, we will meet the intent of these requirements by using the crane dead man switch instead of the main line disconnect devices.Paragraph 2-3.1.7.We will test those controls necessary for the crane operations to be conducted.

Paragraph 2-3.1.7.n.

Safety during maintenance work on cranes will be in accordance with the plant clearance procedure.

The remainder of Chapter 2-3 of the ANSI Standard (i.e.: Handling the Load, Attaching the Load, Moving the Load, Hoist Limit Device, Signals, ili scellaneous) will be met in a general manner in procedures or in cr ane operator training with the following exception:

Paragraph 2-3.2.4.a.

At shift change, we will try out the upper limit device under no load unless a load is hanging from the hook at shift change or unless no crane operation in the area of the upper limit is anticipated.

TURKEY POINT UNITS 3 AND 4 RESPONSE TO NRC RE UEST FOR ADDITIONAL INFO%STION ON CONTROL OF HEAVY LOADS-NUREG 0612 SECTIONS 2.2 2.3'ND 2.4 SPECIFIC R~EUIREMENTS' TABLE OF CONTENTS Section Introduction Title~Pa e Specific Requirements for Overhead Handling Systems Operating in the Vicinity of Fuel Storage Pools (Section 2.2)Overhead Handling System Operating in the Containment (Section 2.3)IV Overhead Handling Systems Operating in Plant Areas Containing Equipment ,Required for Reactor Shutdown, Core Decay Heat Removal, or Spent Fuel Pool Cooling (Section 2.4).Summary and Clarification of Response to'General Requirements (Section 2.1)VI References APPENDIX List of Fi ures~Fi ures 1 Safe Load Path-Turbine Gantry Cranes 2a~2b.Safe Load Path-Reactor Polar Crane-Unit f33 Safe Load Path-Reactor Polar Crane-Unit//4 Safe Load Path-Spent Fuel Cask Handling Cranes Safe Load Path-Intake Structure Bridge Crane ATTACHMENT I.Introduction This report is submitted in response to the NRC generic letter"Control of Heavy Loads"'ated December 22, 1980.The NRC letter requests a two part response to the"Request for Addi'-tional Information" (Enclosure 3 of the letter).The first part of the response, concerning the general requirements for overhead load handling systems, has been previously submitted.

This report contains the second response providing information on the specific requirements.

Section II, III and IV of this report provides the information corresponding to Sections 2', 2.3 and 2.4 of the"Request for Additional Information."Section V p'rovides a summary with a clarification of the pre-vious response based upon findings in this report.II.S ecific Re uirements for Overhead Handlin S stems Ooeratin Section 2.2 of Enclosure 3 of the December 22, 1980 NRC generic letter requests specific information concerning the design and operation of load-handling systems in the vicinity of stored, spent fuel.It requests that the information provided should demonstrate that adequate measures, have been taken to ensure that in this area, either the likelihood of a load drop which might damage spent fuel is extremely small, or that the consequences of such a drop will not exceed the limits set by the evaluation criteria of NURFG 0612, Section 5.1.The following discussion demonstrates how the above requirements are met in this area..The following is a list of heavy load handling systems physi-cally capable (i.e., ignoring interlocks, moveable mechanical stops, or operating procedures) of carrying load's which.could, if dropped, land'r fall into the spent fuel pool.'Name~Ca acit.Equipment Spent Fuel Cask Crane (1 serves both units)105 tons-main hook 15 tons-aux.hook hhiting Company Fuel Pool Bulkhead Monorail (1 ea.unit)2 tons American Chain and Cable The Spent Fuel Handling Machine and the New Fuel Monorail are not included above since these devices do not handle"heavy loads",'ce., loads weighing more than the weight of a spent fuel assembly with lifting tool.This exclusion is based upon Section 2.2.2 of Enclosure 3 of the NRC generic letter.The S ent Fuel Cask Crane is used to transport the spent fuel cask in and out of the spent fuel storage pools of both.units.Although the crane is rated for 105 tons, the Technical Specifi-cations prohibit the handling of loads larger than 25 tons in the pool.The Technical Specifications also prohibit movement of a spent fuel shipping cask over fuel assemblies stored in ,the spent fuel storage pool.To assure that this requirement will not be violated, FPSL has installed a shipping cask crane movement interlock system.The crane is s~itched into this re-stricted movement mode when the cask is being handled in the spent fuel pool.This is a requirement of Operating Procedure 16702.1"Spent Fuel Shipment Using Model NFS-4 Shipping Cask." Bypassing of the limit switches during cask handling operations is allowed only after the cask has been lowered to the bottom of the pool to allow trolley movement to facilitate unlatching of the crane hook from the cask lifting yoke.The operability of the restricted-zone interlocks is verified prior to their required use in accordance with ANSI B30.2"Overhead and Gantry Cranes." Since the Technical Specifications and the interlock system prohibit the movement of a shipping cask over spent fuel, an accident resulting in a shipping cask falling upon stored fuel assemblies could only occur from the dropped cask tipping dur-ing its fall.The potential radiological consequences result-ing from such an accident were evaluated and found to be well within 10CFR100 limits assuming the spent fuel has decayed a minimum of 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />.Technical Specification 3.12"Cask Handling" assures that this assumption remains valid.The cask drop accident was reviewed by the NRC staff to deter-mine if K ff could be significantly affected by a change in eff fuel assembfy configuration resulting from the dropped cask im-pacting the fuel storage racks.Based upon the review (Reference 7)it was concluded that the required use of borated water at the refueling boron concentration in the spent fuel pools will assure that Keff remains less than 0.95 for all possible cask droP accidents..

A Keff of less than 0.95 satisfies NRC require-ments and assures that no undesirable criticality conditions will result from a dropped and tipped cask accident.The fuel pool slab was evaluated for a vertical cask.drop assuming a 2 foot free fall and a water depth of 40 feet.The evaluation determined that the fuel pool integrity is main-tained in the event of a cask, drop accident.

The foregoing discussion and evaluation of the cask handling system and potential cask drop accidents has been previously-submitted and accepted by the NRC staff (Reference 8)and is reiterated here for the sake of completeness.

It has been demonstrated that a cask drop accident over the spent fuel assemblies is unlikely due to the design of the cask handling system and that, in.the event of such an accident, the consequences are within-acceptable limits.In addition, in order to achieve maximum practicable"defense-in-depth" the interim requirements and general guidelines of NUREG 0612 are being implemented for the operation of the Spent Fuel Cask Crane.This includes a safe load path which is shown on Figure 3.The Fuel Pool Bulkhead Monorail is used to lift and move the pool gate bulkhead from the normal location on the inside face of the spent.fuel pool to the designated storage loca-tion.The monorail is located directly above the inside face of the wall and does not travel over the spent fuel racks.A special procedure MP 1407.23"Removal and Installa-tion of the Spent Fuel Pit Keyway Gate" has been prepared for the handling of the bulkhead which delineates steps and the proper sequence to be followed.III.R ecific Re uiremenrs for Overhead llandlin S seems 0 sr~aria in the Containment Section 2.3 of Enclosure 3 of the December 22, 1980 NRC generic letter requests specific information concerning the design and operation of load-handling systems in the vicinity, of the reac-tor core.It requests that the information provided should demonstrate that adequate measures have been taken to ensure that, in this area, either the likelihood of a load drop which might damage spent fuel is extremely small, or that the conse-quences of such a drop will not exceed the limits set by the evaluation criteria of NUREG 0612, Section 5.1.The following d'iscussion demonstrates how the above requirements are met.The following crane is physically capable (i.e., ignoring inter-locks, moveable mechanical stops,, or operating procedures) of carrying heavy loads over the.reactor vessel.Name~Ca acicy Equipment Desi natbr Polar Crane 135 tons-Main Hook 35 tons-Aux Hook f~hiting Company 3.

The Manipulator Crane is not listed since it does not handle"heavy loads", i.e., loads weighing more than the weight of a spent fuel assembly with lifting tool.The Turkey Point Plant Maintenance Procedure 0736,"Heavy Load Handling" defines a safe load path (Figures 2a and 2b)which prohibits hook travel over the reactor vessel without prior special approval.However, during plant maintenance and refueling operations it is sometimes necessary to carry heavy loads over the reactor vessel.Special procedures have been prepared for those loads which are handled periodically over the reactor vessel and have been referenced in FP&L's first phase response (Reference 5).These proce-dures identify the required equipment; inspection and acceptance criteria required before movement of the load;the steps and proper sequence to be followed'n handling the load;the load path and any special precautions.

Any load lifts not covered by a special procedure are controlled generically by the Plant Maintenance Procedure 0736 previously mentioned.

This proce-dure requires that approval from the Maintenance Superintendant be obtained prior to movement of these loads over the reactor vessel.The Maintenance Superintendant will assure that the proper controls are present.In addition to these procedures, which are available at'he site for review, safe operation of the cranes is assured by the crane maintenance and operator training and qualification

'programs whi'ch'follow'ANSI; B30.2".-1976 guidelines., Based upon FP&L's review of the procedures, equipment and personnel used in load handling operations over the core, we believe that the likelihood of the load drop in the area is extremely small.IV.~S ecific Re uirements for Overhead Handlin S stems 0 eratin in Plant Areas Containin E ui ment Re uired for Reactor Shut-down, Core Deca Heat Removal or Spent Fuel Pool Coolin Section 2.4 of Enclosure 3 of the December 22, 1980 NRC generic letter requests specific information concerning the design: and operation of load-handling systems in the vicinity of equipment or components required for sa'fe reactor shutdown and decay heat removal.It requests that the information provided should demonstrate that adequate measures have been taken to ensure that in these areas, either the likelihood of a load drop->which might prevent safe reactor shutdown-is extremely small, or that damage to such equipment from load drops vill be limited in or-der not to result in the loss of their safety-related functions.

The following discussion demonstrates how the above requirements are met.The following is a list of cranes from which a load drop.may result in damage to any system required for plant shutdown or decay heat removal, taking no credit for any interlocks, tech-nical specifications, operating procedures or detailed struc-tural analysis.This list includes those cranes of this type in Group I of Table 1 of the initial response to the NRC generic letter.Name Charging Pump Mono-rails~ca acit (tons)Equipment Desi nator American Chain and Cable Safety Injection Pump Monorails American Chain and Cable Main Steam Platform Spent Fuel Cask Bridge Crane 105 Main Hook 15 Aux.Hook American Chain and Cable Whiting Company Turbine Building Gantry Crane Units 3&4 145 Main Hook 35 Aux.Hook Whiting Company Turbine Building Gantry Crane Units 1&2 70 Main Hook 15 Aux.Hook Harnischfeger Intake Structure Bridge Crane 25.Whiting Company Reactor Polar Cranes 135 Main Hook Whiting Company 35 Aux Hook listed since a load drop from these monorails could potentially damage a safe shutdown system.In every case, however, the component which could potentially be damaged from a load drop would be inoperative for maintenance purposes.These monorails are used for maintenance of these pumps only and are not required to carry heavy loads over operational safety related equipment to reach the laydown area.The Technical Specifications require that one redundant system must be operational in order to remove the other train from service for maintenance.

Therefore, plant safe shutdown capability would not be defeated by a load drop on a component which is being serviced, since a backup system will be operational.

The Hain Steam Platform Monorails are used to remove safety related valves.However, these valves can only be removed when the plant is shut down and their safety related function not required.These monorails handle no other heavy loads.

The Spent Fuel Cask Brid e Crane is located on the Reactor Auxiliary Building roof and serves both units.The principal function of this crane is the movement of the spent fuel cask as described in Section II of this report.Under normal conditions this is the heaviest load handled by the crane in the vicinity of safety related equipment or fuel.Cask drop analyses along the cask travel path were performed (see Reference 8)wherein it was determined that postulated accidents can be acceptably accomodated and unit safe-shutdown capability is maintained.

The crane is also used to handle relatively light loads over the Reactor Auxiliary Building roof.There is no safety related equipment within the operating envelope of the crane hook which could be directly impacted by a load drop.Safety related components within the Reactor Auxiliary Building are protected from potential load drops by a reinforced concrete roof with a minimum thickness of one foot supported by structural steel framing.The Component Coolin'g Mater equipment under the crane operating envelope is similarly protected by steel framing and heavy duty grating.In order to assure that only light loads are handled in these areas, the plant Maintenance Procedure 0736"Heavy Load Handling" restricts the handling of loads greater than 5 tons over the concrete roof area and 1760 pounds over the Component Cooling.Mater area grating (refer to Figure 3).Also, as mentioned previously, the interim requirements and general guidelines of NUREG 0612 are being implemented for the operation, maintenance and qualification of operators for this crane to minimize the possibility of a load handling accident and to achieve maximum"defense-in-depth".

The Unit No.l and 2 (fossil)and Unit No.3 and 4 Turbine~Uantr Cranes can operate over the Unit No.3 and 4 Turbine Building.Two reinforced concrete enclosed switchgear rooms, one for each unit, are located within the range of Turbine Gantry Crane operating envelope.Although it is considered highly unlikely that a heavy load drop could penetrate the two foot thick concrete roof and cause sufficient damage to equipment located in this room that would result in defeating plant safe shutdown capability or decay heat removal, the handling of heavy loads is restricted in this area.A safe load path has been defined for this crane (refer to Figure 1)which prohibits the handling of loads in excess of 5 tons in this area.In addition to the safe load path, in order to achieve maximum practicable"defense-in-depth", the interim requirements and general guidelines of.NUREG 0612 have been adopted for.the operation, maintenance and qualification of operators for this crane.The Intake Structure Brid e Crane could potentially carry heavy loads over the Intake Cooling Mater (ICM)pumps.However, a review of the loads handled by this crane has identified no heavy loads which are normally carried over the ICM pumps, Also, if a heavy load drop is postulated it is considered un-likely that such an event could cause sufficent damage to the redundant ICW systems to defeat safe shutdown and decay heat removal.To assure that no heavy loads are carried over the pumps a safe load path has been defined which restricts load handling in this area (refer to Figure 4).Also, the interim requirements and general guidelines of NUREG 0612 have been implemented for this crane.The Reactor Building Pol'ar Crane is operated during plant cold shutdown and refueling modes.During these modes the residual heat removal (RHR)system is required to remain functional to remove decay heat from the reactor core.Since the piping for thi's system is within the hook envelope of the reactor polar crane, heavy load drops are reviewed.The majority of the RHR piping in the containment is located within the confines of the reinforced concrete internal struc-ture.The piping within this area is considered to be adequately protected from load drops.On the one side of the buil'ding the piping exits the internal structure and follows the containment wall to the piping penetration area.Although there is.structuxal steel framing between the piping and the crane which will provide some protection, load handling will be restricted in this area.This area is indicated on the safe load path sketches on Figure 2a and 2b.As previously stated in Section III of this report, the NUREG 0612 general guidelines and interim requirements have been adopted for the operation of the Reactor Building Polar Crane.V.Summar and Clarification of Res onse to General Re uirements This report documents the final phase of FPL&L's revi'ew of the controls for the handling of heavy loads at Turkey Point Units 3 and 4 as requested by the NRC generic letter dated December 22, 1980.As a result of the findings in this report, the safe load path sketches presented in the first phase response have been changed'complete set of the new safe load path sketches are presented in Figures 1 through 4.The results of Florida Power and Light Company's review of NUREG 0612 finds no equipment modifications required to meet the NUREG 0612 specific requirements.

New proceduxes, training programs and other actions necessary to comply with the interim requirements and general guidelines are being implemented and have been addressed in the previous response.A training program in accordance with ANSI B 30.2-1976 has been developed and our standard company physical for new employees generally meets or exceeds the physical requirements of the ANSI standard.Some minor exceptions to the ANSI standard have been taken and are listed in the attachment at the end of this report.These training programs and procedures will be available at the site for review.

VI References 1.NUREG 0612-"Control of Heavy Loads at Nuclear Power Plants" 2.NRC Generic Letter-"Control of Heavy Loads" dated December 22, 1980.3.Enclosure 2 of Generic Letter-"Staff Position-Interim Actions for Control of Heavy Loads" 4.Enclosure 3 of Generic Letter-":Request for Additional Information on Con'trol of Heavy Loads" 5.FPL letter L-81-382 to.Mr.Eisenhut of NRC dated September 4, 1981,"Co'ntrol of Heavy Loads" (First Phase response).

6.Plant Maintenance Procedure 0736-"Heavy Load Handling" ,7.Safety Evaluation by the Office of Nuclear Reactor Regulation-Supporting Amendment No.23 to License No.DPR-31 and Amendment No.22 to License No.DPR-41.8.FPL letter L-78-324 to Mr.Stello of NRC dated October 4, 1978"Control of Heavy Loads" APPENDIX L~~~

(.I II(I).IAY 13/K I I I LOIIIIIA I'I2',Vl II A I IGIII (;Oh'I'AIIY IrIII>JI'C I DI(>.18UT rJ (MAL, V-l~fKR'f~r a ar 5TEh M QBWGAh;WRY' Pt<1 Hh~k(~)R~o~HEAD~~p~QB&P (: ,dttB~~64lC+i+i C(3(2+@CO%'P~~P g(7r ir Ne~r bent I I LC Q<<D IEZI RES1IIICTBD A(IF-.A I-<K HALIDLIIaq (AG LOA.Dar)(1zQ~Safe load path is outside of cross-hatched areas.PTGURE 2a-SAFE LOAD PATH REACTOR POLAR CRANE UNIT 3 FOAM 73 ACV.7/14 CI II(IX IIV~I~ILI)44)IN I I)VII Il.i I I()ill (4)hll'AIIY I ll~4,'I~I'Iii)JI 4 I N<.4.4~I C.OOt.ggl STRA+Qe<Ge~h.j.Wali q gAY E~~~Sf@rQ CTE,<I=RY4.'tub,1 f,g~4h:fpQ~O'P~em~C 6)+p Cow lb.ig-He)oY~p Y 4 ogi~,, h:sQ"y 6416mt.<~ih<u-+'SA)~4 Fw:[F f(RB~QRK:Tt=D hghh Fog HAADLIQc)o>4Q~D~%k/60 Safe load path is outside of cross-hatched areas.FIGURE 2b-SAFE LOAD PATH REACTOR POLAR CRANE UNIT 4 c~uGC tua7A4 Pvrtpsc Hml~xwxw v~c.ww~Ea5 yet~eg (~ggacT100 win's C.G+jOa0&t>$(OOL;X.~PgX~lQ~MATt.'g FUN<gyes~~~X, g<CP~CR xXv31 COB{TlY~K cp~cV-ua~y sio VBV3 EV~P)T CMK WA<E(h~~b.&/HMf/C."" PocF L.S<E~r J'odex RWll iE-CZLDC:

I%2 RE~R~~TDO~RAP FQg EAvDLIQO OF LOAD&(ORBÃ%%FR Safe load path is outside of cross-hatched areas.FZODRE 3-SAFE LOAD FATE SPENT FUEL CASK HANDLING CRANE C I I I I q CIRC..%~4<CcoL.L~404XGg~AF5 l/I-I i I I I l I I-l i I ii I I H I I mI-I I s a iJ.I I I I I I I~(..I I s I I~I I=I II I I I%I I I I I I i I I I i II I-I I I I I C)n I r I di LBQEPD ggg RB Sl RlC'QBD QRj~tOP'HhQDQ~Of LQh~(jar (EP, TH~660 Safe load path is outside of cross-hatched areas.FIGURE 4-SAFE LOAD PATH INTAKE STRUCTURE'BRIDGE CRANE STATE OF FLORXDA)), COUNTY OF DADE)ss John A.DeMastry, being first duly sworn, deposes and says: That he is Manager, Nuc1ear Licensing Light Company, the Licensee herein;of Florida Power S That he has executed the foregoing document;that the state-ments made in this said document are true and correct to the best of his knowledge,.information, and belief, and that he is authorized to execute the document on behalf of said Licensee.John A.'eHastry Subscribed and sworn to before me this~day of-->>NOTARY PUBLXC, and fo" the County of Dade, fS tate,,'o f;,.'"F 1 or i Notary Public.Stato of Florida at Largo My commission expires: