NRC Generic Letter 1985-11: Difference between revisions

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| number = ML031150689
| number = ML031150689
| issue date = 06/28/1985
| issue date = 06/28/1985
| title = NRC Generic Letter 1985-011: Completion of Phase Ii of Control of Heavy Loads at Nuclear Power Plants NUREG-0612
| title = NRC Generic Letter 1985-011: Completion of Phase II of Control of Heavy Loads at Nuclear Power Plants NUREG-0612
| author name = Thompson H L
| author name = Thompson H
| author affiliation = NRC/NRR
| author affiliation = NRC/NRR
| addressee name =  
| addressee name =  
Line 15: Line 15:
| page count = 20
| page count = 20
}}
}}
{{#Wiki_filter:TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:
{{#Wiki_filter:TO ALL LICENSEES FOR OPERATING REACTORS
  Gentlemen:
  SUBJECT:  COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEAR
            POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- 11)
  On December 22, 1980, NRC issued a generic letter (unnumbered) which was supplemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612,
  "Control of Heavy Loads at Nuclear Power Plants". This letter requested that you implement certain interim actions and provide the NRC information related to heavy loads at your facilities. Your submittals were requested in two parts; a six month response (Phase I) and a nine month response (Phase II).
  All licensees have completed the requirement to perform a review and submit a Phase I and a Phase II report. Based on the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I), further action is not required to reduce the risks associated with the handling of heavy loads (See enclosed NUREG-0612 Phase II). Therefore, a detailed Phase II
  review of heavy loads is not necessary and Phase II is considered completed.


SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEARPOWER PLANTS" NUREG-0612. (GENERIC LETTER 85- 11)On December 22, 1980, NRC issued a generic letter (unnumbered) which wassupplemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612,"Control of Heavy Loads at Nuclear Power Plants". This letter requestedthat you implement certain interim actions and provide the NRC informationrelated to heavy loads at your facilities. Your submittals were requestedin two parts; a six month response (Phase I) and a nine month response(Phase II).All licensees have completed the requirement to perform a review and submita Phase I and a Phase II report. Based on the improvements in heavy loadshandling obtained from implementation of NUREG-0612 (Phase I), further actionis not required to reduce the risks associated with the handling of heavyloads (See enclosed NUREG-0612 Phase II). Therefore, a detailed Phase IIreview of heavy loads is not necessary and Phase II is considered completed.However, while not a requirement, we encourage the implementation of anyactions you identified in Phase II regarding the handling of heavy loadsthat you consider appropriate.For each plant which has a license condition requiring commitmentsacceptable to the NRC regarding Phase II, an application for licenseF amendment may be submitted to the NRC to delete the license condition citingthis letter as the basis. If you have any questions, contact your ProjectManager or Don Neighbors (301) 492-4837.
However, while not a requirement, we encourage the implementation of any actions you identified in Phase II regarding the handling of heavy loads that you consider appropriate.


Sincerely,Original Signed byHuah L. Thompson, Jr.Hugh L. Thompson, Jr., DirectorAs SDivision of Licensing
For each plant which has a license condition requiring commitments acceptable to the NRC regarding Phase II, an application for license F amendment may be submitted to the NRC to delete the license condition citing this letter as the basis. If you have any questions, contact your Project Manager or Don Neighbors (301) 492-4837.


===Enclosure:===
Sincerely, Original Signed by Huah L.Thompson, Jr.
As Stated )*See previous concurrencesORB#1:DL* ORB#1:DL* BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DLCParrish JDNeighbors SVarga RBernero GLainas HThompson3/7/85 5/6/85 3/11/85 3/13/85 3/19/85 5/:hd/85AD/L* OELD*TNovak 8506270M .3/21/85 4/22/854{fs Enclosure 1HUREG-0612, NCONTROL OF HEAVY LOADS AT.,NUCLEAR POWER PLANTS' ,RESOLUTION OF PHASE IIGeneric Technical Activity A-36 was established to systematically examine thestaff's licensing criteria, adequacy of measures in effect at operating plantsand recommend necessary changes to assure the safe handling of heavy loads.The task involved review of licensee information, evaluation of historicaldata, performance of accident analyses and criticality calculations,development of guidelines for operating plants,. and.review of licensingcriteria. The review indicated that the.major causes of load handlingaccidents include operator errors, rigging failures, lack of adequate inspec-tLon and inadequate procedures. The results of the review culminated in theissuance of NUREG-0612, Control 'of Heavy Loads at Nuclear Power Plants' inJuly 1980. NUREG-0612 described a resolution of Task A-36.NUREG-0612 presents an overall philosophy that provides a defense-in-depthapproach for controlling the handling of heavy loads. The approach is directedto preventing load drops. The following summarizes this defense-in-depthapproach:1. Assure that there is a well designed handling system.2. Provide sufficient operator training, load handling instructions, andequipment inspection to assure reliable operation of the handling system.3. Define safe load travel paths and procedures and operator training toassure to the extent practical that heavy loads are not carried over ornear irradiated fuel or safe shutdown equipment.4. Provide mechanical stops or electrical interlocks to prevent movement ofheavy loads over irradiated fuel or in proximity to equipment associatedwith redundant shutdown path .25. Where mechanical stops or electrical interlocks cannot be provided.provide a single-failure-proof crane or perform load drop analysesto demonstrate that unacceptable consequences will not result..IBy Generic Letters dated December 22, 1980, and February 3, 1981- (GenericLetter 81-07), all utilities were requested to evaluate their plants againstthe guidance of NUREG-0612 and to provide their submittals in two parts; PhasesI (six month response).and Phase !I (nine month response). Phase I responseswere to address Section 5.1.1 of NUREG-0612 which covers the following areas:1. Definition of safe load paths2. Development of load handling procedures3. Periodic inspection and testing of cranes4. Qualifications, training and specified conduct of operators-L5. Special lifting devices should satisfy the guidelines of ANSI 114.6 6.6. Lifting devices that are not specially designed should be installed andused in accordance with the guidelines of ANSI 830.97. Design of cranes to ANSI 830.2 or CMAA-70Phase II responses were to address Sections 5.1.2 thru 5.1.6 of NUREG-0612which cover the need for electrical interlocks/mechanical stops, oralternatively, single-failure-proof cranes or load drop analyses in the spentfuel pool area (PWR), containment building (PWR), reactor building (BWR), otherareas and the specific guidelines for single-failure-proof handling systems.We have completed our review of the utilities' submittals for Phase I fornearly all operating reactors. Only one plant still remains to be reviewed.During our review we verified that the seven guidelines listed above wereproviding the desired level of safety indicated in NUREG-0612. By way ofthe utilities' responses to the criteria of NUREG-0612, Section 5.1.1and through discussions with our consultants based on their experiencesfrom the reviews, we have concluded that the Phase I guidelines have providedan increased awareness by the utilities of the importance of heavy loadhandling.Our review has indicated that satisfaction of the Phase I guidelines assuresthat the potential for a load drop is extremely small. We have noted d3improvements in heavy load handling procedures and training and crane andhandling tool inspection and testing. These changes have been geared tolimiting the handling of heavy loads over safety-related equipment and spentfuel to the extent practical, but where this can not be ivoided, poaccomplishing it with the operational and other features of the froaram imDlementedin Phase I. We therefore conclude that the Puidelines of Phase I are adequatelyproviding the intended level of protection against load drop accidents.To date we have received Phase II submittals from all licensees. Weinterpret Phase II of NUREG-0612 as an enhancement to Phase I. Thus, priorto undertaking a review of the utilities' Phase II response for all of theoperating reactors, and as a test of the adequacy of the Phase I program,we decided to undertake a pilot program with a limited number of plants.The findings from the pilot program would then provide a basis for adecision on whether to proceed with the review of the Phase II submittalsfor all operating reactors, to reduce the scope of the review, or tototally eliminate the review.The pilot program involved the review of operating reactors at 12 sites, atotal of 20 reactors (eight BWRs and 12 PWRs). Of the 20 reactors, 5 BWRs(Browns Ferry 1, 2 and 3 and Peach Bottom 2 and 3) have single-failure-proofcranes for all heavy load lifts. mSingle-failurt-proofP is used to mean acrane which meets the guidelines of NUREG-0554, aSingle-Failure-Proof Cranesfor Nuclear Power Plants.' Three BWR units (Dresden 2 and 3 and Big RockPoint) have taken credit for a combination of single-failure-proof cranes insome plant areas and load drop analyses in others. Five PWR reactors(Millstone 2, Prairie Island 1 and 2, and Surry 1 and 2) have utilized the loaddrop analysis approach. One plant (Kewaunee) has taken credit for acombination of electrical interlocks in some plant areas and load drop analysesin others. The remaining six reactors (Davis Besse, Indian Point 2, Arkansas 1and 2 and Calvert Cliffs I and 2) chose to take credit for a combination ofadministrative controls, procedures and Technical Specification restrictions inconjunction with some type of load, drop analysis. This approach does not meetthe criteria of Sections 5.1.2 to 5.1.6 of NUREG-0612. Rather, it is anamplification of the quidelines of the Phase I effort, reflecting Section 5.1.1of NUREG-061 It should also be noted that we have completed our review of Phase II for fiveoperating license applicants. Of these, two (WNP-2 and Fermi-2) havesingle-failure-proof cranes. The remaining three (Callaway, Wolf Creek andCatawba.1 and 2) employ a combination of electrical interlocks, i .hanicalstops, limit switches and load drop analyses.In addition to the detailed reviews of the Phase II reports in the pilotprogram and in connection with the five operating license applications,we have performed a sufficient review of all other Phase II reports toflag any outstanding plant-spedific concerns reported.From our pilot program and OL Phase II reviews, together with the above-mentioned reviews of the other Phase II reports we have concluded thatthe risks associated with damage to safe shutdown systems are relativelysmall because:1. nearly all load paths avoid this equipment2. most equipment it protected by an intervening floor3. of the general independence between crane failure probability andsafety-related systems which has been observed4. redundancy of componentsWe did not identify any outstanding plant specific safety concern associatedwith heavy loads handling.Therefore, most of the risk appears to be associated with carrying heavy loadsover or in a location where spent fuel could be damaged. The single mostimportant example of this concerns loads handled over the open reactor vesselduring refueling (such as the reactor vessel head). Howevef, as previouslymentioned, this is limited to the extent practical and where necessary, isperformed with a specifically implemented program in conformance with the PhaseI guidelines.From the pilot program and OL reviews, we noted that nine of the twentyreactors, all PsRS, do not have single-failure-proof cranes. To date, we havenot identified any PWRs with single-failure-proof cranes. Further, sinceelectrical interlocks and mechanical stops are not possible for PWR polar
* 50* *cranes, these reactors would be required to perform costly detailed loaddrop analyses. If satisfactory results could not be demonstrated fromthese analyses, NUREG-0612. would call for installation of a single-failure-proof crane.Based on the above, since a single failure proof crane becomes-theonly solution for satisfying the NUREG-0612 criteria, the cost/benefitshould be examined. Because we are dealing primarily with PWRs, thecost for modification of a polar crane to meet single failure criteria(NUREG-0554) guidelines) is approximately $30 million. This includes,as the dominant cost element, the cost of the extended shutdown which isrequired in order to gain access to containment. On the benefit side,given the improvements obtained from the Phase I implementation and theinformation obtained in the course of the pilot program and OL Phase IIreviews, we cannot perceive a significant enough benefit in conversionto single-failure-proof polar cranes to warrant the high costs. (SeeAttachment I for a cost-benefit analysis.) We believe that the cost/benefit analysis in NUREG-0612 is no longer valid because of thebenefits realized by Phase I implementation.We believe the above assessment is further borne out by the industryexperience with handling of heavy loads over the years. Precautionshave been and are being taken such that no heavy load drop accidentsaffecting any features of the defense-in-depth against severe core-damage accidents have occurred. This determination is also supportedby the recommendation of our contractor for the pilot program reviews(Franklin Research Center) and our benefit-cost analysis suggestingthat we accept other, less strigent but less costly means for Phase IIcompliance as an alternative to the criteria of NUREG-0612 with respectto conversion to single-failure-proof cranes.Conclusion and RecommendationBased on the above, we believe the Phase I implementation has providedsufficient protection such that the risk associated with potential heavy load*There have, however, been recent occurrences of lesser severity. (See forexample, IE informatfon Notice No. 85-12: Recent.Fuel Handling Events LER84-015, Fort Calhoun 1, Load Over the RCS; and LER 84- San nofre , PolarCrane Malfunction). Accordinqly nothing in this determ 7ion should beregarded as a basis for any Be-emphasis of continued attention to thesafe handling of heavy load drops is acceptably small. We further conclude that the objective identifiedin Section 5.1 of HUREG-0612 for providing gmaximum practical defense in depthuis satisfied by the Phase I compliance, and that the Phase II analyses did notindicate the need to require further generic action at this time.lyThis conclusion has been confirmed by the results obtained-from"Die Phase IIpilotprogram and additional Phase II reviews, which identified no residualheavy loads handling concerns of sufficient significance to demand furthergeneric action. All plants have examined their load handling practices againstthe recommendations of Phase II and submitted the Phase II report. In thisway, the utilities were required to identify any unexpected problems to thestaf ATTACHMENT ISUMMARY OF COST-BENEFIT ANALYSIS OF--PWR POLAR CRANE CONVERSION TO SINGLE-FAILURE-PROOF FEATURES'SCOPEThe safety benefit of converting the polar crane in the containment of anoperating or completed or nearly completed PWR to single-failure-prooffeatures and the cost of the conversion were estimated and compared.The safety benefit was estimated in terms of the resulting reduction in therisk of a severe accident, involving major radioactive material release,during the remaining plant life. The risk was expressed as the product ofthe accident probability and the population radiation dose from the release,should the accident occur.The cost estimate included the cost of shutdown (or extension of anon-operating period) needed to accomplish the conversion.ACCIDENT FREQUENCY ESTIMATESCrane Failure FrequencyThere were 32 crane LER events in the approximately 400 reactor-years ofU.S. power-reactor operation in the 10-year period July 1969 to July 1979(NUREG-0612, p. 4-6). None resulted in radioactive release. Of the 32events, 17 (i.e., just over half) were apparently due to hardware design orfabrication causes, the other 15 to human factors. (Navy crane statistics,cited in NUREG-0612, for 40 load-drop or potential load-drop events in1974-77 show 80% of the events to be due to human factors.)


-2 -It may be assumed, as a rough approximation, that Phase I of NRC'sheavy-loads generic program is addressed to all the human factors causes andone-half of the hardware causes and succeeds in reducing the affected partof the failure frequency to a quite small fraction of the frequencyoriginally present. Since human factors and hardware each contribute aboutone-half of the failures, approximately 3/4 of the total crane failures canbe expected to be eliminated by the Phase I program. Single-failure-proof(SFP) cranes should substantially reduce the remaining 1/4 of the failurefrequency, though those failures would not be eliminated altogether, sincethe SFP feature (as. defined in NUREG-0554) does not protect against all typesof possible failure (e.g., the bridge is not SFP and the SFP feature itselfis subject to defeat by some types of human error). On the other hand, theSFP feature would make the cranes more "forgiving" of imperfections in thePhase I implementation. Accordingly, one may reasonably assume that the SFPfeature would have a net effect of eliminating 1/4 of the pre-Phase Ifailure frequency.Frequency of Accidents Involving Radioactive ReleaseNot all LER events involve radioactive release. In over 600 reactor-yearsof U.S. power-reactor operation to date [1982) there have, to our knowledge,been no radioactive releases due to load drops. The 10-year period coveredby the survey in NUREG-0612, which included 32 crane LER events, all withoutrelease, represents about 60% of all U.S. power-reactor operating time todate. An assumption of a pre-fix frequency of some radioactive release oncein 1,000 reactor-years appears consistent with the LER-reflected failureexperience, taken together with the absence of releases to date. With 1/4of these releases averted by an SFP crane feature,,-the pertinent releasefrequency reduction would be 1 in 4,000 RY. For the most part, these can beassumed to be minor releases due to limited fuel damage in the spent-fuelstorage pool or in the reacto Frequency of Accidents Involving Major ReleasesFor a load-drop event to cause a major accident, with major radioactiverelease, special circumstances need to be present -- circumstances thatPhase I is intended to make much less likely to occur. A highly damagingheavy load drop, such as one that could destroy a core cooling featurethrough violation of -- or imperfections in -- Phase I provisions combinedwith other failures, should be unlikely, and very unlikely to lead to majorrelease, because of back-up safety provisions (e.g., independent additionalcore cooling provisions).,Review of typical load paths and associated crane-operation frequenciessuggests that of all load drops in a typical PWR plant that could haveradiological consequences, some 1/4 could involve equipment with a role insafe reactor shutdown, including primary-system piping. If one assumes thatthere is typically a 1% probability that back-up revisions would also fail,then the pertinent major-release frequency is 1 in 1,600,000 reactor-years.Frequency ReductionSingle-failure-proof cranes may reasonably be expected to eliminate most,perhaps 90%, of the residual load-drop probability after the Phase Iimprovements. Thus, the frequency reduction for major release isapproximately 1 in 1,800,000 RY (90% of 1/1,600,000).It should be noted that these estimates are sensitive to plant layout.Plant-specific evaluations could, depending on case specifics, point to amuch higher or lower major-release frequency estimate for a specific case.For example, should layout of a specific plant be such that a particularlyunfortunate load drop could destroy all means of core cooling orincapacitate the control room (possibilities suggested by the situations atMontecello and Arkansas Nuclear 1, respectively, before remedial actions weretaken at those plants), the above generic analysis could be wide of the mark
Hugh L. Thompson, Jr., Director As  SDivision                  of Licensing Enclosure:
-4 -for such a plant. The major-release accident frequency could well be anorder of magnitude higher for such a plant (i.e., of the order of 1 in100,000 reactor-years) -- or even higher, depending on plant and cranefeatures, load paths, and operating practices.CONSEQUENCES ESTIMATEPotential radiological consequences of load-drop accidents encompass a wide.range of possibilities, depending on specific features of plant design,operating practices, and the nature and location of the specific load-dropevent. We assume that some -- though very rough -- indication of theseverity of the load-drop accident-risks may be gained by using in thesesimplified calculations certain selected release categories described inWASH-1400, Appendix VI, pp. 2-1 to 2-4. Category PWR 4 was selected for themajor-release estimates for pressurized water reactors.In PWR 4 core cooling and containment both fail. Core melt occurs. -Thisrelease category is used to explore consequences of a load drop thatincapacitates core cooling (during or promptly after reactor operation),with containment open.The release estimates, stated as resulting public dose, based onrepresentative generic estimates, for a hypothetical site with a projectedYear 2000 mean U.S. power-reactor-site population density, developed byBattelle Pacific Northwest Laboratories (NUREG/CR-2800) is 2,700,000person-rem.COST ESTIMATECosts of change-over to single-failure-proof cranes are subject to wideplant-specific variation, depending on the number of features of thespecific cranes involved and other aspects of plant design and statu Based on advice from the Auxiliary Systems Branch, DSI, and limited vendorand utility contacts.,'we take thelfollowing estimates as representative(as of 1982, when the estimates were made).For future plants, the cost differential for original inclusion of SFPfeatures is estimated at about $250,000 for PWRs (based on information fromEderer Crane Co.).At the pre-operating-license stage, with no startup delay, the costs --including planning, engineering, hardware, installation, and testing -- areestimated at $2 million per plant. This is based on the Monticelloexperience (1.M in 1976, adjusted for inflation). (The Monticelloinformation was obtained from the licensee through the NRC residentinspector.)For operating PWRs the estimated costs are dominated by plant shutdownduring modifications of the polar crane located inside the containmentbuilding. (The shutdown may be an extension of a shutdown for refueling oi4tother purposes.) The cost effect of a startup delay for a completed or nearlycompleted plant would be similar. With a 3-month shutdown and with shutdown..costs taken as determined by the cost of replacement power at $300,000 perday,.representative total change-over costs for operating PWRs are estimatedat about $30 million.RISK REDUCTIONBased on the foregoing frequency and consequences estimates, the "expectedvalue" of the risk subject to being affected by the possible Phase II SFPfeature, i.e., the magnitude of release times the frequency of its II-6-occurrence, integrated for the remaining plant life taken as 20years,'is asfollows:Major release risk 20 x 2,700,000 = 30 person-rem/reactor2,800,000COST-BENEFIT RATIOThe cost-benefit ratio indicated by the foregoing estimates is approximately$1,000,000/person-rem. This. estimate is subject to wide plant-to-plantvariation as well as large uncertainties in the underlying estimates ofaccident frequency and consequences. Nevertheless, it is possible toconclude with reasonable confidence that the benefit-cost ratio for thecrane conversion would fail to meet a $1,000/person-rem worthwhilenesscriterion by a large margin.,..I , .
  As Stated      )
TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:
  *See previous concurrences ORB#1:DL*      ORB#1:DL*    BC-ORB#1:DL*        D/DSI*    AD:OR:DL*    D:DL
  CParrish      JDNeighbors    SVarga            RBernero    GLainas    HThompson
  3/7/85        5/6/85        3/11/85            3/13/85    3/19/85    5/:hd/85 AD/L*      OELD*
  TNovak                                                    8506270M    .
  3/21/85    4/22/85
                                                                                    4{fs


SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEARPOWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )On December 22, 1980, NRC issued a generic letter (unnumbered) which wassupplemented February 3, 1981 (Generic Letter.81-07) regarding NUREG-0612,"Control of Heavy Loads at Nuclear Power Plants". This letter requestedthat you implement certain interim actions and provide the NRC informationrelated to heavy loads at your facilities. Your submittals were requestedin two parts; a six month response (Phase I) and a nine month response(Phase II).All licensees have completed the requirement to perform a review and submita Phase I and a Phase II report. We believe that further action is notrequired based on the improvements in heavy loads handling obtained fromimplementation of NUREG-0612 (Phase I). Therefore, a detailed Phase IIreview of heavy loads is not necessary and Phase II is considered completed.However, while not a requirement, we encourage the implementation of anyactions identified in Phase II regarding the handling of heavy loads.For each plant which has a license condition requiring commitmentsacceptable to the NRC regarding Phase II, an application for licenseamendment may be submitted to the NRC to delete the license condition citingthis letter as the basis, If you have any questions, contact your ProjectManager or Don Neighbors (301) 492-4837.
Enclosure 1 HUREG-0612, NCONTROL OF HEAVY LOADS AT.,
                              NUCLEAR POWER PLANTS'              ,
                                RESOLUTION OF PHASE II
Generic Technical Activity A-36 was established to systematically examine the staff's licensing criteria, adequacy of measures ineffect at operating plants and recommend necessary changes to assure the safe handling of heavy loads.


Sincerely,Hugh L. Thompson, Jr., DirectorDivision of Licensing*See previous white for concurrencesORB#1:DL* ORB#1:DL* BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DLCParrish JDNeighbors;ps SVarga Bernero GLainas HThompson3/7 /85 5/6/85 3/11/85 3/13/85 3/19 /85 5/ /85AD/L* OELD*TNovak3/21/85 4/22/85 TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:
The task involved review of licensee information, evaluation of historical data, performance of accident analyses and criticality calculations, development of guidelines for operating plants,. and.review of licensing criteria. The review indicated that the.major causes of load handling accidents include operator errors, rigging failures, lack of adequate inspec- tLon and inadequate procedures. The results of the review culminated in the issuance of NUREG-0612, Control 'of Heavy Loads at Nuclear Power Plants' in July 1980. NUREG-0612 described a resolution of Task A-36.


SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEPOWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )On December 22, 1980, we issued a generic letter which was sup enentedFebruary 3, 1981 (Generic Letter 81-07) regarding NUREG-0612 'Control ofHeavy Loads at Nuclear Power Plants". This letter request that youImplement certain interim actions and provide the NRC inf ation related toheavy loads at your facilities. Your submittals were t ave been in twoparts; six month response (Phase I) and nine month re onse (Phase II).We have almost completed Phase I of our review and ost licensees havereceived a plant specific letter closing Phase I.As for Phase II, we believe that further NRC ac on is not necessary. Asindicated in the enclosure, we conclude this othe basis of theimprovements in heavy loads handling obtained from implementation ofNUREG-0612 (Phase I), the results of the Pha e II pilot program performedby our contractor, Franklin Research Center which identified nofurther heavy loads handling concerns, ad tional evaluations of Phase IIsubmittals by the staff and cost benefitWe, therefore, consider this portion ( ase II) of our review of heavyloads complete. However, while not a equirement, we encourage theimplementation of any actions identi ed in Phase II regarding the handlingof heavy loads.For each plant which has a licens condition, an application for licenseamendment should be submitted to he NRC to delete the license conditionusing this letter as-the basis. If you have any questions, contact yourProject Manager or Don Neighbor (301) 492-4837.
NUREG-0612 presents an overall philosophy that provides a defense-in-depth approach for controlling the handling of heavy loads. The approach isdirected to preventing load drops. The following summarizes this defense-in-depth approach:
1. Assure that there is a well designed handling system.


Sincerely,Hugh L. Thompson, Jr., Director
2. Provide sufficient operator training, load handling instructions, and equipment inspection to assure reliable operation of the handling system.


===Enclosure:===
3. Define safe load travel paths and procedures and operator training to assure to the extent practical that heavy loads are not carried over or near irradiated fuel or safe shutdown equipment.
Division of LicensingAs stated*See previous white or concurrencesORB#1:DL* ORB BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DLCParrish JDNe ors;ps SVarga Bernero GLainas HThompson3/7 /85 3/11/85 3/13/85 3/19 /85 4/ /85AD/L* OELD%TNovak3/21/85 4/ /85 TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:


SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEARPOWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )On December 22, 1980, we issued a generic letter which was supplementedFebruary 3, 1981 (Generic Letter 81-07) regarding NUREG-0612, "Control ofHeavy Loads at Nuclear Power Plants". This letter requested that youimplement certain interim actions and provide the NRC information related toheavy loads at your facilities. Your submittals were to have been in twoparts; six month response (Phase I) and nine month response (Phase II).We have almost completed Phase I of our review and most licensees havereceived a plant specific letter closing Phase I.As for Phase II, we believe that further NRC action is not necessary. Asindicated in the enclosure, we conclude this on the basis of theimprovements in heavy loads handling obtained from implementation ofNUREG-0612 (Phase I), the results of the Phase II pilot program performedby our contractor, Franklin Research Institute which identified nofurther heavy loads handling concerns, additional evaluations of Phase IIsubmittals by the staff and cost benefit.We, therefore, consider this portion (Phase II) of our review of heavyloads complete.For each plant which has a license condition, an application for licenseamendment should be submitted to the NRC to delete the license conditionusing this letter as the basis. If you have any questions, contact yourProject Manager or Don Neighbors (301) 492-4837.
4.   Provide mechanical stops or electrical interlocks to prevent movement of heavy loads over irradiated fuel or in proximity to equipment associated with redundant shutdown paths.


Sincerely,Hugh L. Thompson, Jr., DirectorDivision of Licensing*See previous white for concurrences AORB#1:DL* ORB#1:DL BC-ORB#1:DL* D/DSI* AD:OR:DL*13DLCParrish J jbg' bors;ps SVarga Bernero GLainas HThompson3/7 /85 4/4185 3/11/85 3/13/85 3/19 /85 4/ /85AD/L* OELDTNovak3/21/85 4/ /85\ Ao,41 f9 TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:
.2
5. Where mechanical stops or electrical interlocks cannot be provided.


SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT N LEARPOWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )On December 22, 1980, we issued a generic letter which was s plementedFebruary 3, 1981 (Generic Letter 81-07) regarding NUREG-06 , "Control ofHeavy Loads at Nuclear Power Plants". This letter reque ed that youimplement certain interim actions and provide the NRC i ormation related toheavy loads at your facilities. Your submittals were o have been in twoparts; six month response (Phase I) and nine month r ponse (Phase II).We have almost completed Phase I of our review an most licensees havereceived a plant specific letter closing PhaseAs for Phase II, we believe that further NRC ction is not necessary. Asindicated in the enclosure, we conclude this on the basis of theimprovements in heavy loads handling obtai d from implementation ofNUREG-0612 (Phase I), the results of the P ase II pilot program performedby our contractor, Franklin Research Ins tute which identified nofurther heavy loads handling concerns, ditional evaluations of Phase IIsubmittals by the staff and cost benef .We, therefore, consider this portio (Phase II) of our review of heavyloads complete.For those plants which have lice e conditions, this letter resolves therequirements of those condition as far as meeting the generic concerns ofNUREG-0612. If you have any estions, contact your Project Manager orDon Neighbors on 301-492-4837.
provide a single-failure-proof crane or perform load drop analyses to demonstrate that unacceptable consequences will not result.


Sincerely,Hugh L. Thompson, Jr., DirectorDivision of Licensing*See previous Ite for concurrencesORB#1:DL* / 1-5DL BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DLCParrish / ighbors;ps SVarga Bernero GLainas HThompson3/7 /85,/- : tV85 3/11/85 3/13/85 3/197/85 3/ /85-I TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:
.I
By Generic Letters dated December 22, 1980, and February 3, 1981- (Generic Letter 81-07), all utilities were requested to evaluate their plants against the guidance of NUREG-0612 and to provide their submittals in two parts; Phases I (six month response).and Phase !I (nine month response). Phase I responses were to address Section 5.1.1 of NUREG-0612 which covers the following areas:
1.  Definition of safe load paths
2.  Development of load handling procedures
3.  Periodic inspection and testing of cranes
4.  Qualifications, training and specified conduct of operators- L5.  Special lifting devices should satisfy the guidelines of ANSI 114.6 6.


SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY XADS AT NUCLEARPOWER PLANTS" NUREG-0612. (GENERIC LETTER -)On December 22, 1980, we issued a generic letter ich was supplementedFebruary 3, 1981 (Generic Letter 81-07) regardin NUREG-0612, "Control ofHeavy Loads at Nuclear Power Plants". This let r requested that youImplement certain interim actions and provide e NRC information related toheavy loads at your facilities. Your submitt s were to have been in twoparts; six month response (Phase I) and nin month response (Phase II).We have almost completed Phase I of our r lew and most licensees havereceived a plant specific letter closing hase I.As for Phase II, we believe that furth NRC action is not necessary. Asindicated in the enclosure, we conclu e this on the basis of theimprovements in heavy loads handlin obtained from implementation ofNUREG-0612 (Phase I), the results the Phase II pilot program performedby our contractor, Franklin Researh Institute which identified nofurther heavy loads handling con rns, additional evaluations of Phase IIsubmittals by the staff and cos benefit.We, therefore, consider this rtion (Phase II) of our review of heavyloads complete.For those plants which hav license conditions, this letter resolves therequirements of those con tions as far as meeting the generic concerns ofNUREG-0612.
6. Lifting devices that are not specially designed should be installed and used in accordance with the guidelines of ANSI 830.9
7. Design of cranes to ANSI 830.2 or CMAA-70
Phase II responses were to address Sections 5.1.2 thru 5.1.6 of NUREG-0612 which cover the need for electrical interlocks/mechanical stops, or alternatively, single-failure-proof cranes or load drop analyses in the spent fuel pool area (PWR), containment building (PWR), reactor building (BWR), other areas and the specific guidelines for single-failure-proof handling systems.


Sincerely,Hugh L. Thompson, Jr., DirectorDivision of Licensing
We have completed our review of the utilities' submittals for Phase I for nearly all operating reactors. Only one plant still remains to be reviewed.
 
During our review we verified that the seven guidelines listed above were providing the desired level of safety indicated in NUREG-0612. By way of the utilities' responses to the criteria of NUREG-0612, Section 5.1.1 and through discussions with our consultants based on their experiences from the reviews, we have concluded that the Phase I guidelines have provided an increased awareness by the utilities of the importance of heavy load handling.
 
Our review has indicated that satisfaction of the Phase I guidelines assures that the potential for a load drop is extremely small. We have noted
 
d3 improvements in heavy load handling procedures and training and crane and handling tool inspection and testing. These changes have been geared to limiting the handling of heavy loads over safety-related equipment and spent fuel to the extent practical, but where this can not be ivoided, po accomplishing it with the operational and other features of the froaram imDlemented Phase I. We therefore conclude that the in Puidelines                                          of Phase I are adequately providing the intended level of protection against load drop accidents.
 
To date we have received Phase II submittals from all licensees. We interpret Phase II of NUREG-0612 as an enhancement to Phase I. Thus, prior to undertaking a review of the utilities' Phase II response for all of the operating reactors, and as a test of the adequacy of the Phase I program, we decided to undertake a pilot program with a limited number of plants.
 
The findings from the pilot program would then provide a basis for a decision on whether to proceed with the review of the Phase II submittals for all operating reactors, to reduce the scope of the review, or to totally eliminate the review.
 
The pilot program involved the review of operating reactors at 12 sites, a total of 20 reactors (eight BWRs and 12 PWRs). Of the 20 reactors, 5 BWRs (Browns Ferry 1, 2 and 3 and Peach Bottom 2 and 3) have single-failure-proof cranes for all heavy load lifts. mSingle-failurt-proofP is used to mean a crane which meets the guidelines of NUREG-0554, aSingle-Failure-Proof Cranes for Nuclear Power Plants.' Three BWR units (Dresden 2 and 3 and Big Rock Point) have taken credit for a combination of single-failure-proof cranes in some plant areas and load drop analyses in others. Five PWR reactors (Millstone 2, Prairie Island 1 and 2, and Surry 1 and 2) have utilized the load drop analysis approach. One plant (Kewaunee) has taken credit for a combination of electrical interlocks in some plant areas and load drop analyses in others. The remaining six reactors (Davis Besse, Indian Point 2, Arkansas 1 and 2 and Calvert Cliffs I and 2) chose to take credit for a combination of administrative controls, procedures and Technical Specification restrictions in conjunction with some type of load, drop analysis. This approach does not meet the criteria of Sections 5.1.2 to 5.1.6 of NUREG-0612. Rather, it is an amplification of the quidelines of the Phase I effort, reflecting Section 5.1.1 of NUREG-0612.
 
4 five It should also be noted that we have completed our review of Phase II for operating license applicants. Of these, two (WNP-2 and Fermi-2) have single-failure-proof cranes. The remaining three (Callaway, Wolf Creek and Catawba.1 and 2) employ a combination of electrical interlocks, .hanical i
stops, limit switches and load drop analyses.
 
In addition to the detailed reviews of the Phase II reports in the pilot program and in connection with the five operating license applications, we have performed a sufficient review of all other Phase II reports to flag any outstanding plant-spedific concerns reported.
 
From our pilot program and OL Phase II reviews, together with the above- mentioned reviews of the other Phase II reports we have concluded that the risks associated with damage to safe shutdown systems are relatively small because:
  1. nearly all load paths avoid this equipment
  2. most equipment it protected by an intervening floor
  3. of the general independence between crane failure probability and safety-related systems which has been observed
  4. redundancy of components We did not identify any outstanding plant specific safety concern associated with heavy loads handling.
 
loads Therefore, most of the risk appears to be associated with carrying heavy over or in a location where spent fuel could be damaged. The single most important example of this concerns loads handled over the open reactor vessel during refueling (such as the reactor vessel head). Howevef, as previously mentioned, this is limited to the extent practical and where necessary, is Phase performed with a specifically implemented program in conformance with the I guidelines.
 
From the pilot program and OL reviews, we noted that nine of the twenty reactors, all PsRS, do not have single-failure-proof cranes. To date, we have not identified any PWRs with single-failure-proof cranes. Further, since electrical interlocks and mechanical stops are not possible for PWR polar
 
*        50
*          *
  cranes, these reactors would be required to perform costly detailed load drop analyses. If satisfactory results could not be demonstrated from these analyses, NUREG-0612. would call for installation of a single- failure-proof crane.
 
Based on the above, since a single failure proof crane becomes-the only solution for satisfying the NUREG-0612 criteria, the cost/benefit should be examined. Because we are dealing primarily with PWRs, the cost for modification of a polar crane to meet single failure criteria (NUREG-0554) guidelines) is approximately $30 million. This includes, as the dominant cost element, the cost of the extended shutdown which is required in order to gain access to containment. On the benefit side, given the improvements obtained from the Phase I implementation and the information obtained in the course of the pilot program and OL Phase II
  reviews, we cannot perceive a significant enough benefit in conversion to single-failure-proof polar cranes to warrant the high costs. (See Attachment I for a cost-benefit analysis.) We believe that the cost/
  benefit analysis in NUREG-0612 is no longer valid because of the benefits realized by Phase I implementation.
 
We believe the above assessment is further borne out by the industry experience with handling of heavy loads over the years. Precautions have been and are being taken such that no heavy load drop accidents affecting any features of the defense-in-depth against severe core- damage accidents have occurred. This determination is also supported by the recommendation of our contractor for the pilot program reviews (Franklin Research Center) and our benefit-cost analysis suggesting that we accept other, less strigent but less costly means for Phase II
  compliance as an alternative to the criteria of NUREG-0612 with respect to conversion to single-failure-proof cranes.
 
Conclusion and Recommendation Based on the above, we believe the Phase I implementation has provided sufficient protection such that the risk associated with potential heavy load
  *There have, however, been recent occurrences of lesser severity. (See for example, IE informatfon Notice No. 85-12: Recent.Fuel Handling Events LER
    84-015, Fort Calhoun 1, Load Over the RCS; and LER 84-    San nofre , Polar Crane  Malfunction). Accordinqly nothing in this determ7ion  should be regarded as a basis for any Be-emphasis of continued attention to the safe handling of heavy loads.
 
6 drops is acceptably small. We further conclude that the objective identified in Section 5.1 of HUREG-0612 for providing gmaximum practical defense in depthu is satisfied by the Phase I compliance, and that the Phase II analyses did not indicate the need to require further generic action at this time.ly This conclusion has been confirmed by the results obtained-from"Die Phase II
pilotprogram and additional Phase II reviews, which identified no residual heavy loads handling concerns of sufficient significance to demand further generic action. All plants have examined their load handling practices against the recommendations of Phase II and submitted the Phase II report. In this way, the utilities were required to identify any unexpected problems to the staff.
 
ATTACHMENT I
                    SUMMARY OF COST-BENEFIT ANALYSIS OF--
        PWR POLAR CRANE CONVERSION TO SINGLE-FAILURE-PROOF FEATURES'
SCOPE
The safety benefit of converting the polar crane in the containment of an operating or completed or nearly completed PWR to single-failure-proof features and the cost of the conversion were estimated and compared.
 
The safety benefit was estimated in terms of the resulting reduction in the risk of a severe accident, involving major radioactive material release, during the remaining plant life. The risk was expressed as the product of the accident probability and the population radiation dose from the release, should the accident occur.
 
The cost estimate included the cost of shutdown (or extension of a non-operating period) needed to accomplish the conversion.
 
ACCIDENT FREQUENCY ESTIMATES
Crane Failure Frequency There were 32 crane LER events in the approximately 400 reactor-years of U.S. power-reactor operation in the 10-year period July 1969 to July 1979 (NUREG-0612, p. 4-6). None resulted in radioactive release. Of the 32 events, 17 (i.e., just over half) were apparently due to hardware design or fabrication causes, the other 15 to human factors. (Navy crane statistics, cited in NUREG-0612, for 40 load-drop or potential load-drop events in
1974-77 show 80% of the events to be due to human factors.)
 
- 2 -
It may be assumed, as a rough approximation, that Phase I of NRC's heavy-loads generic program is addressed to all the human factors causes and one-half of the hardware causes and succeeds in reducing the affected part of the failure frequency to a quite small fraction of the frequency originally present. Since human factors and hardware each contribute about one-half of the failures, approximately 3/4 of the total crane failures can be expected to be eliminated by the Phase I program. Single-failure-proof (SFP) cranes should substantially reduce the remaining 1/4 of the failure frequency, though those failures would not be eliminated altogether, since the SFP feature (as. defined in NUREG-0554) does not protect against all types of possible failure (e.g., the bridge is not SFP and the SFP feature itself is subject to defeat by some types of human error). On the other hand, the SFP feature would make the cranes more "forgiving" of imperfections in the Phase I implementation. Accordingly, one may reasonably assume that the SFP
feature would have a net effect of eliminating 1/4 of the pre-Phase I
failure frequency.
 
Frequency of Accidents Involving Radioactive Release Not all LER events involve radioactive release. In over 600 reactor-years of U.S. power-reactor operation to date [1982) there have, to our knowledge, been no radioactive releases due to load drops. The 10-year period covered by the survey in NUREG-0612, which included 32 crane LER events, all without release, represents about 60% of all U.S. power-reactor operating time to date. An assumption of a pre-fix frequency of some radioactive release once in 1,000 reactor-years appears consistent with the LER-reflected failure experience, taken together with the absence of releases to date. With 1/4 of these releases averted by an SFP crane feature,,-the pertinent release frequency reduction would be 1 in 4,000 RY. For the most part, these can be assumed to be minor releases due to limited fuel damage in the spent-fuel storage pool or in the reactor.
 
- 3 -
Frequency of Accidents Involving Major Releases For a load-drop event to cause a major accident, with major radioactive release, special circumstances need to be present -- circumstances that Phase I is intended to make much less likely to occur. A highly damaging heavy load drop, such as one that could destroy a core cooling feature through violation of -- or imperfections in -- Phase I provisions combined with other failures, should be unlikely, and very unlikely to lead to major release, because of back-up safety provisions (e.g., independent additional core cooling provisions).,
Review of typical load paths and associated crane-operation frequencies suggests that of all load drops in a typical PWR plant that could have radiological consequences, some 1/4 could involve equipment with a role in safe reactor shutdown, including primary-system piping. If one assumes that there is typically a 1% probability that back-up revisions would also fail, then the pertinent major-release frequency is 1 in 1,600,000 reactor-years.
 
Frequency Reduction Single-failure-proof cranes may reasonably be expected to eliminate most, perhaps 90%, of the residual load-drop probability after the Phase I
improvements. Thus, the frequency reduction for major release is approximately 1 in 1,800,000 RY (90% of 1/1,600,000).
It should be noted that these estimates are sensitive to plant layout.
 
Plant-specific evaluations could, depending on case specifics, point to a much higher or lower major-release frequency estimate for a specific case.
 
For example, should layout of a specific plant be such that a particularly unfortunate load drop could destroy all means of core cooling or incapacitate the control room (possibilities suggested by the situations at Montecello and Arkansas Nuclear 1, respectively, before remedial actions were taken at those plants), the above generic analysis could be wide of the mark
 
- 4 -
for such a plant. The major-release accident frequency could well be an order of magnitude higher for such a plant (i.e., of the order of 1 in
100,000 reactor-years) -- or even higher, depending on plant and crane features, load paths, and operating practices.
 
CONSEQUENCES ESTIMATE
Potential radiological consequences of load-drop accidents encompass a wide
.range of possibilities, depending on specific features of plant design, operating practices, and the nature and location of the specific load-drop event. We assume that some -- though very rough -- indication of the severity of the load-drop accident-risks may be gained by using in these simplified calculations certain selected release categories described in WASH-1400, Appendix VI, pp. 2-1 to 2-4. Category PWR 4 was selected for the major-release estimates for pressurized water reactors.
 
In PWR 4 core cooling and containment both fail. Core melt occurs. -This release category is used to explore consequences of a load drop that incapacitates core cooling (during or promptly after reactor operation),
with containment open.
 
The release estimates, stated as resulting public dose, based on representative generic estimates, for a hypothetical site with a projected Year 2000 mean U.S. power-reactor-site population density, developed by Battelle Pacific Northwest Laboratories (NUREG/CR-2800) is 2,700,000
person-rem.
 
COST ESTIMATE
Costs of change-over to single-failure-proof cranes are subject to wide plant-specific variation, depending on the number of features of the specific cranes involved and other aspects of plant design and status.
 
- 5 -
Based on advice from the Auxiliary Systems Branch, DSI, and limited vendor and utility contacts.,'we take thelfollowing estimates as representative (as of 1982, when the estimates were made).
For future plants, the cost differential for original inclusion of SFP
features is estimated at about $250,000 for PWRs (based on information from Ederer Crane Co.).
At the pre-operating-license stage, with no startup delay, the costs  --
including planning, engineering, hardware, installation, and testing  --  are estimated at $2 million per plant. This is based on the Monticello experience (1.M in 1976, adjusted for inflation). (The Monticello information was obtained from the licensee through the NRC resident inspector.)
For operating PWRs the estimated costs are dominated by plant shutdown during modifications of the polar crane located inside the containment building.  (The shutdown may be an extension of a shutdown for refueling  oi4t other purposes.) The cost effect of a startup delay for a completed or nearly completed plant would be similar. With a 3-month shutdown and with shutdown..
costs taken as determined by the cost of replacement power at $300,000 per day,.representative total change-over costs for operating PWRs are estimated at about $30 million.
 
RISK REDUCTION
Based on the foregoing frequency and consequences estimates, the "expected value" of the risk subject to being affected by the possible Phase II SFP
feature, i.e., the magnitude of release times the frequency of its
 
I
I
                                      -6- occurrence, integrated for the remaining plant life taken as 20years,'is as follows:
            Major release risk  20 x 2,700,000 = 30 person-rem/reactor
                                      2,800,000
  COST-BENEFIT RATIO
  The cost-benefit ratio indicated by the foregoing estimates is approximately
  $1,000,000/person-rem. This. estimate is subject to wide plant-to-plant variation as well as large uncertainties in the underlying estimates of accident frequency and consequences. Nevertheless, it is possible to conclude with reasonable confidence that the benefit-cost ratio for the crane conversion would fail to meet a $1,000/person-rem worthwhileness criterion by a large margin.
 
7-;-.-'e    ,
                                                              .  . I - , .
 
TO ALL LICENSEES FOR OPERATING REACTORS
Gentlemen:
SUBJECT:    COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEAR
            POWER PLANTS" NUREG-0612. (GENERIC LETTER 85-    )
On December 22, 1980, NRC issued a generic letter (unnumbered) which was supplemented February 3, 1981 (Generic Letter.81-07) regarding NUREG-0612,
"Control of Heavy Loads at Nuclear Power Plants". This letter requested that you implement certain interim actions and provide the NRC information related to heavy loads at your facilities. Your submittals were requested in two parts; a six month response (Phase I) and a nine month response (Phase II).
All licensees have completed the requirement to perform a review and submit a Phase I and a Phase II report. We believe that further action is not required based on the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I). Therefore, a detailed Phase II
review of heavy loads is not necessary and Phase II is considered completed.
 
However, while not a requirement, we encourage the implementation of any actions identified in Phase II regarding the handling of heavy loads.
 
For each plant which has a license condition requiring commitments acceptable to the NRC regarding Phase II, an application for license amendment may be submitted to the NRC to delete the license condition citing this letter as the basis, If you have any questions, contact your Project Manager or Don Neighbors (301) 492-4837.
 
Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing
*See previous white for concurrences ORB#1:DL*        ORB#1:DL*      BC-ORB#1:DL*    D/DSI*  AD:OR:DL* D:DL
CParrish          JDNeighbors;ps SVarga          Bernero  GLainas  HThompson
3/7 /85          5/6/85        3/11/85        3/13/85  3/19 /85 5/ /85 AD/L*      OELD*
TNovak
3/21/85    4/22/85
 
TO ALL LICENSEES FOR OPERATING REACTORS
Gentlemen:
SUBJECT:    COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLE
            POWER PLANTS" NUREG-0612. (GENERIC LETTER 85-    )
On December 22, 1980, we issued a generic letter which was sup enented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612 'Control of Heavy Loads at Nuclear Power Plants". This letter request        that you Implement certain interim actions and provide the NRC inf ation related to heavy loads at your facilities. Your submittals were t ave been in two parts; six month response (Phase I) and nine month re onse (Phase II).
We have almost completed Phase I of our review and      ost licensees have received a plant specific letter closing Phase I.
 
As for Phase II, we believe that further NRC ac on is not necessary. As indicated in the enclosure, we conclude this othe basis of the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I), the results of the Pha e II pilot program performed by our contractor, Franklin Research Center which identified no further heavy loads handling concerns, ad tional evaluations of Phase II
submittals by the staff and cost benefit We, therefore, consider this portion ( ase II) of our review of heavy loads complete. However, while not a equirement, we encourage the implementation of any actions identi ed in Phase II regarding the handling of heavy loads.
 
For each plant which has a licens condition, an application for license amendment should be submitted to he NRC to delete the license condition using this letter as-the basis. If you have any questions, contact your Project Manager or Don Neighbor (301) 492-4837.
 
Sincerely, Hugh L. Thompson, Jr., Director Enclosure:                          Division of Licensing As stated
*See previous white    or concurrences ORB#1:DL*        ORB          BC-ORB#1:DL*    D/DSI*    AD:OR:DL* D:DL
  CParrish        JDNe  ors;ps SVarga          Bernero    GLainas  HThompson
  3/7 /85                        3/11/85        3/13/85    3/19 /85 4/ /85 AD/L*      OELD%
  TNovak
  3/21/85    4/ /85
 
TO ALL LICENSEES FOR OPERATING REACTORS
Gentlemen:
SUBJECT:  COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEAR
          POWER PLANTS" NUREG-0612. (GENERIC LETTER 85-      )
On December 22, 1980, we issued a generic letter which was supplemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants". This letter requested that you implement certain interim actions and provide the NRC information related to heavy loads at your facilities. Your submittals were to have been in two parts; six month response (Phase I) and nine month response (Phase II).
We have almost completed Phase I of our review and most licensees have received a plant specific letter closing Phase I.
 
As for Phase II, we believe that further NRC action is not necessary. As indicated in the enclosure, we conclude this on the basis of the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I), the results of the Phase II pilot program performed by our contractor, Franklin Research Institute which identified no further heavy loads handling concerns, additional evaluations of Phase II
submittals by the staff and cost benefit.
 
We, therefore, consider this portion (Phase II) of our review of heavy loads complete.
 
For each plant which has a license condition, an application for license amendment should be submitted to the NRC to delete the license condition using this letter as the basis. If you have any questions, contact your Project Manager or Don Neighbors (301) 492-4837.
 
Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing
*See previous white for concurrences                                  A
ORB#1:DL*        ORB#1:DL        BC-ORB#1:DL*    D/DSI*  AD:OR:DL*13DL
  CParrish        J jbg' bors;ps SVarga          Bernero  GLainas  HThompson
  3/7 /85        4/4185          3/11/85        3/13/85  3/19 /85 4/ /85 AD/L*    OELD
  TNovak
  3/21/85  4/ /85
                \ Ao,41        f9
 
tm- TO ALL LICENSEES FOR OPERATING REACTORS
Gentlemen:
SUBJECT:  COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT N LEAR
          POWER PLANTS" NUREG-0612. (GENERIC LETTER 85-    )
On December 22, 1980, we issued a generic letter which was s plemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-06 , "Control of Heavy Loads at Nuclear Power Plants". This letter reque ed that you implement certain interim actions and provide the NRC i ormation related to heavy loads at your facilities. Your submittals were o have been in two parts; six month response (Phase I) and nine month r ponse (Phase II).
We have almost completed Phase I of our review an most licensees have received a plant specific letter closing Phase As for Phase II, we believe that further NRC ction is not necessary. As indicated in the enclosure, we conclude this on the basis of the improvements in heavy loads handling obtai d from implementation of NUREG-0612 (Phase I), the results of the P ase II pilot program performed by our contractor, Franklin Research Ins tute which identified no further heavy loads handling concerns, ditional evaluations of Phase II
submittals by the staff and cost benef .
We, therefore, consider this portio    (Phase II) of our review of heavy loads complete.
 
For those plants which have lice e conditions, this letter resolves the requirements of those condition as far as meeting the generic concerns of NUREG-0612. If you have any    estions, contact your Project Manager or Don Neighbors on 301-492-4837.
 
Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing
*See previous    Ite for concurrences ORB#1:DL*    /    1-5DL      BC-ORB#1:DL*    D/DSI*    AD:OR:DL* D:DL
CParrish    /    ighbors;ps SVarga            Bernero  GLainas  HThompson
3/7 /85,/-      :tV85          3/11/85        3/13/85    3/197/85 3/ /85
        - I
 
TO ALL LICENSEES FOR OPERATING REACTORS
Gentlemen:
SUBJECT:  COMPLETION OF PHASE II OF "CONTROL OF HEAVY XADS AT NUCLEAR
          POWER PLANTS" NUREG-0612. (GENERIC LETTER      -    )
On December 22, 1980, we issued a generic letter        ich was supplemented February 3, 1981 (Generic Letter 81-07) regardin NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants". This let r requested that you Implement certain interim actions and provide e NRC information related to heavy loads at your facilities. Your submitt s were to have been in two parts; six month response (Phase I) and nin month response (Phase II).
We have almost completed Phase I of our r lew and most licensees have received a plant specific letter closing hase I.
 
As for Phase II, we believe that furth      NRC action is not necessary. As indicated in the enclosure, we conclu e this on the basis of the improvements in heavy loads handlin obtained from implementation of NUREG-0612 (Phase I), the results      the Phase II pilot program performed by our contractor, Franklin Researh Institute which identified no further heavy loads handling con rns, additional evaluations of Phase II
submittals by the staff and cos benefit.
 
We, therefore, consider this    rtion (Phase II) of our review of heavy loads complete.
 
For those plants which hav license conditions, this letter resolves the requirements of those con tions as far as meeting the generic concerns of NUREG-0612.
 
Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing  


==CONTACT==
==CONTACT==
:J. D. NeighborX24837ORB#l:DL* *See previous white for concurrenceCParrish> .3/7/857 OR 1 )8 fiB#1:DL A d AH A X :DL D:DLJDt Ihbors; SY a D4Arnero GL s HThompson3 J 8 31/5/85 3 /85 3/ /85 TO ALL LICENSEES FOR OPERATING REACTORSGentlemen:
:
J. D. Neighbor X24837 ORB#l:DL*       *See previous white for concurrence CParrish>.
  3/7/85
              7  OR           )8       1 fiB#1:DL       A dA    AHX  :DL D:DL
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SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOAD AT NUCLEARPOWER PLANTS" NUREG-0612. (GENERIC LETTER 85-On December 22, 1980, we issued a generic letter which As supplementedFebruary 3, 1981 (Generic Letter 81-07) regarding NUR -0612, "Control ofHeavy Loads at Nuclear Power Plants". This letter r uested that youimplement certain interim actions and provide the C information related toheavy loads at your facilities. Your submittals re to have been in twoparts; six month response (Phase I) and nine mon response (Phase II).We have almost completed Phase I of our revie and most licensees havereceived a letter closing Phase I. Only a f plants remain to be reviewed.As for Phase II, we believe that further C action is not necessary. Asindicated in the enclosure, we conclude is on the basis of theimprovements in heavy loads handling ob ained from implementation ofNUREG-0612 (Phase I), the results of e Phase II pilot program performedby our contractor, Franklin Research nstitute which identified nofurther heavy loads handling concer additional evaluations of Phase IIsubmittals by the staff and cost b nefit.We, therefore, consider this po ion (Phase II) of our review of heavyloads complete. TlHowever, this ction is not intended to preclude licenseesfrom making improvements in t Ir load handling systems which they feel arenecessary for safe load hand ing.)For those plants which hay license conditions, this letter resolves therequirements of those co itions as far as meeting the generic concerns ofNUREG-0612.
TO ALL LICENSEES FOR OPERATING REACTORS
Gentlemen:
SUBJECT:   COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOAD AT NUCLEAR
            POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- On December 22, 1980, we issued a generic letter which As supplemented February 3, 1981 (Generic Letter 81-07) regarding NUR -0612, "Control of Heavy Loads at Nuclear Power Plants". This letter r uested that you implement certain interim actions and provide the C information related to heavy loads at your facilities. Your submittals       re to have been in two parts; six month response (Phase I) and nine mon       response (Phase II).
We have almost completed Phase I of our revie and most licensees have received a letter closing Phase I. Only a f plants remain to be reviewed.


Sincerely,Hugh L. Thompson, Jr., DirectorDivision of Licensing
As for Phase II, we believe that further      C action is not necessary. As indicated in the enclosure, we conclude    is on the basis of the improvements in heavy loads handling ob ained from implementation of NUREG-0612 (Phase I), the results of e Phase II pilot program performed by our contractor, Franklin Research nstitute which identified no further heavy loads handling concer      additional evaluations of Phase II
submittals by the staff and cost b nefit.
 
We, therefore, consider this po ion (Phase II) of our review of heavy loads complete. TlHowever, this ction is not intended to preclude licensees from making improvements in t Ir load handling systems which they feel are necessary for safe load hand ing.)
For those plants which hay license conditions, this letter resolves the requirements of those co itions as far as meeting the generic concerns of NUREG-0612.
 
Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing  


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Latest revision as of 02:43, 24 November 2019

NRC Generic Letter 1985-011: Completion of Phase II of Control of Heavy Loads at Nuclear Power Plants NUREG-0612
ML031150689
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill, Crane
Issue date: 06/28/1985
From: Thompson H
Office of Nuclear Reactor Regulation
To:
References
NUREG-0612 GL-85-011, NUDOCS 8506270216
Download: ML031150689 (20)


TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEAR

POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- 11)

On December 22, 1980, NRC issued a generic letter (unnumbered) which was supplemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612,

"Control of Heavy Loads at Nuclear Power Plants". This letter requested that you implement certain interim actions and provide the NRC information related to heavy loads at your facilities. Your submittals were requested in two parts; a six month response (Phase I) and a nine month response (Phase II).

All licensees have completed the requirement to perform a review and submit a Phase I and a Phase II report. Based on the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I), further action is not required to reduce the risks associated with the handling of heavy loads (See enclosed NUREG-0612 Phase II). Therefore, a detailed Phase II

review of heavy loads is not necessary and Phase II is considered completed.

However, while not a requirement, we encourage the implementation of any actions you identified in Phase II regarding the handling of heavy loads that you consider appropriate.

For each plant which has a license condition requiring commitments acceptable to the NRC regarding Phase II, an application for license F amendment may be submitted to the NRC to delete the license condition citing this letter as the basis. If you have any questions, contact your Project Manager or Don Neighbors (301) 492-4837.

Sincerely, Original Signed by Huah L.Thompson, Jr.

Hugh L. Thompson, Jr., Director As SDivision of Licensing Enclosure:

As Stated )

  • See previous concurrences ORB#1:DL* ORB#1:DL* BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DL

CParrish JDNeighbors SVarga RBernero GLainas HThompson

3/7/85 5/6/85 3/11/85 3/13/85 3/19/85 5/:hd/85 AD/L* OELD*

TNovak 8506270M .

3/21/85 4/22/85

4{fs

Enclosure 1 HUREG-0612, NCONTROL OF HEAVY LOADS AT.,

NUCLEAR POWER PLANTS' ,

RESOLUTION OF PHASE II

Generic Technical Activity A-36 was established to systematically examine the staff's licensing criteria, adequacy of measures ineffect at operating plants and recommend necessary changes to assure the safe handling of heavy loads.

The task involved review of licensee information, evaluation of historical data, performance of accident analyses and criticality calculations, development of guidelines for operating plants,. and.review of licensing criteria. The review indicated that the.major causes of load handling accidents include operator errors, rigging failures, lack of adequate inspec- tLon and inadequate procedures. The results of the review culminated in the issuance of NUREG-0612, Control 'of Heavy Loads at Nuclear Power Plants' in July 1980. NUREG-0612 described a resolution of Task A-36.

NUREG-0612 presents an overall philosophy that provides a defense-in-depth approach for controlling the handling of heavy loads. The approach isdirected to preventing load drops. The following summarizes this defense-in-depth approach:

1. Assure that there is a well designed handling system.

2. Provide sufficient operator training, load handling instructions, and equipment inspection to assure reliable operation of the handling system.

3. Define safe load travel paths and procedures and operator training to assure to the extent practical that heavy loads are not carried over or near irradiated fuel or safe shutdown equipment.

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

.2

5. Where mechanical stops or electrical interlocks cannot be provided.

provide a single-failure-proof crane or perform load drop analyses to demonstrate that unacceptable consequences will not result.

.I

By Generic Letters dated December 22, 1980, and February 3, 1981- (Generic Letter 81-07), all utilities were requested to evaluate their plants against the guidance of NUREG-0612 and to provide their submittals in two parts; Phases I (six month response).and Phase !I (nine month response). Phase I responses were to address Section 5.1.1 of NUREG-0612 which covers the following areas:

1. Definition of safe load paths

2. Development of load handling procedures

3. Periodic inspection and testing of cranes

4. Qualifications, training and specified conduct of operators- L5. Special lifting devices should satisfy the guidelines of ANSI 114.6 6.

6. Lifting devices that are not specially designed should be installed and used in accordance with the guidelines of ANSI 830.9

7Property "ANSI code" (as page type) with input value "ANSI 830.9</br></br>7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.. Design of cranes to ANSI 830.2 or CMAA-70

Phase II responses were to address Sections 5.1.2 thru 5.1.6 of NUREG-0612 which cover the need for electrical interlocks/mechanical stops, or alternatively, single-failure-proof cranes or load drop analyses in the spent fuel pool area (PWR), containment building (PWR), reactor building (BWR), other areas and the specific guidelines for single-failure-proof handling systems.

We have completed our review of the utilities' submittals for Phase I for nearly all operating reactors. Only one plant still remains to be reviewed.

During our review we verified that the seven guidelines listed above were providing the desired level of safety indicated in NUREG-0612. By way of the utilities' responses to the criteria of NUREG-0612, Section 5.1.1 and through discussions with our consultants based on their experiences from the reviews, we have concluded that the Phase I guidelines have provided an increased awareness by the utilities of the importance of heavy load handling.

Our review has indicated that satisfaction of the Phase I guidelines assures that the potential for a load drop is extremely small. We have noted

d3 improvements in heavy load handling procedures and training and crane and handling tool inspection and testing. These changes have been geared to limiting the handling of heavy loads over safety-related equipment and spent fuel to the extent practical, but where this can not be ivoided, po accomplishing it with the operational and other features of the froaram imDlemented Phase I. We therefore conclude that the in Puidelines of Phase I are adequately providing the intended level of protection against load drop accidents.

To date we have received Phase II submittals from all licensees. We interpret Phase II of NUREG-0612 as an enhancement to Phase I. Thus, prior to undertaking a review of the utilities' Phase II response for all of the operating reactors, and as a test of the adequacy of the Phase I program, we decided to undertake a pilot program with a limited number of plants.

The findings from the pilot program would then provide a basis for a decision on whether to proceed with the review of the Phase II submittals for all operating reactors, to reduce the scope of the review, or to totally eliminate the review.

The pilot program involved the review of operating reactors at 12 sites, a total of 20 reactors (eight BWRs and 12 PWRs). Of the 20 reactors, 5 BWRs (Browns Ferry 1, 2 and 3 and Peach Bottom 2 and 3) have single-failure-proof cranes for all heavy load lifts. mSingle-failurt-proofP is used to mean a crane which meets the guidelines of NUREG-0554, aSingle-Failure-Proof Cranes for Nuclear Power Plants.' Three BWR units (Dresden 2 and 3 and Big Rock Point) have taken credit for a combination of single-failure-proof cranes in some plant areas and load drop analyses in others. Five PWR reactors (Millstone 2, Prairie Island 1 and 2, and Surry 1 and 2) have utilized the load drop analysis approach. One plant (Kewaunee) has taken credit for a combination of electrical interlocks in some plant areas and load drop analyses in others. The remaining six reactors (Davis Besse, Indian Point 2, Arkansas 1 and 2 and Calvert Cliffs I and 2) chose to take credit for a combination of administrative controls, procedures and Technical Specification restrictions in conjunction with some type of load, drop analysis. This approach does not meet the criteria of Sections 5.1.2 to 5.1.6 of NUREG-0612. Rather, it is an amplification of the quidelines of the Phase I effort, reflecting Section 5.1.1 of NUREG-0612.

4 five It should also be noted that we have completed our review of Phase II for operating license applicants. Of these, two (WNP-2 and Fermi-2) have single-failure-proof cranes. The remaining three (Callaway, Wolf Creek and Catawba.1 and 2) employ a combination of electrical interlocks, .hanical i

stops, limit switches and load drop analyses.

In addition to the detailed reviews of the Phase II reports in the pilot program and in connection with the five operating license applications, we have performed a sufficient review of all other Phase II reports to flag any outstanding plant-spedific concerns reported.

From our pilot program and OL Phase II reviews, together with the above- mentioned reviews of the other Phase II reports we have concluded that the risks associated with damage to safe shutdown systems are relatively small because:

1. nearly all load paths avoid this equipment

2. most equipment it protected by an intervening floor

3. of the general independence between crane failure probability and safety-related systems which has been observed

4. redundancy of components We did not identify any outstanding plant specific safety concern associated with heavy loads handling.

loads Therefore, most of the risk appears to be associated with carrying heavy over or in a location where spent fuel could be damaged. The single most important example of this concerns loads handled over the open reactor vessel during refueling (such as the reactor vessel head). Howevef, as previously mentioned, this is limited to the extent practical and where necessary, is Phase performed with a specifically implemented program in conformance with the I guidelines.

From the pilot program and OL reviews, we noted that nine of the twenty reactors, all PsRS, do not have single-failure-proof cranes. To date, we have not identified any PWRs with single-failure-proof cranes. Further, since electrical interlocks and mechanical stops are not possible for PWR polar

  • 50
  • *

cranes, these reactors would be required to perform costly detailed load drop analyses. If satisfactory results could not be demonstrated from these analyses, NUREG-0612. would call for installation of a single- failure-proof crane.

Based on the above, since a single failure proof crane becomes-the only solution for satisfying the NUREG-0612 criteria, the cost/benefit should be examined. Because we are dealing primarily with PWRs, the cost for modification of a polar crane to meet single failure criteria (NUREG-0554) guidelines) is approximately $30 million. This includes, as the dominant cost element, the cost of the extended shutdown which is required in order to gain access to containment. On the benefit side, given the improvements obtained from the Phase I implementation and the information obtained in the course of the pilot program and OL Phase II

reviews, we cannot perceive a significant enough benefit in conversion to single-failure-proof polar cranes to warrant the high costs. (See Attachment I for a cost-benefit analysis.) We believe that the cost/

benefit analysis in NUREG-0612 is no longer valid because of the benefits realized by Phase I implementation.

We believe the above assessment is further borne out by the industry experience with handling of heavy loads over the years. Precautions have been and are being taken such that no heavy load drop accidents affecting any features of the defense-in-depth against severe core- damage accidents have occurred. This determination is also supported by the recommendation of our contractor for the pilot program reviews (Franklin Research Center) and our benefit-cost analysis suggesting that we accept other, less strigent but less costly means for Phase II

compliance as an alternative to the criteria of NUREG-0612 with respect to conversion to single-failure-proof cranes.

Conclusion and Recommendation Based on the above, we believe the Phase I implementation has provided sufficient protection such that the risk associated with potential heavy load

  • There have, however, been recent occurrences of lesser severity. (See for example, IE informatfon Notice No. 85-12: Recent.Fuel Handling Events LER

84-015, Fort Calhoun 1, Load Over the RCS; and LER 84- San nofre , Polar Crane Malfunction). Accordinqly nothing in this determ7ion should be regarded as a basis for any Be-emphasis of continued attention to the safe handling of heavy loads.

6 drops is acceptably small. We further conclude that the objective identified in Section 5.1 of HUREG-0612 for providing gmaximum practical defense in depthu is satisfied by the Phase I compliance, and that the Phase II analyses did not indicate the need to require further generic action at this time.ly This conclusion has been confirmed by the results obtained-from"Die Phase II

pilotprogram and additional Phase II reviews, which identified no residual heavy loads handling concerns of sufficient significance to demand further generic action. All plants have examined their load handling practices against the recommendations of Phase II and submitted the Phase II report. In this way, the utilities were required to identify any unexpected problems to the staff.

ATTACHMENT I

SUMMARY OF COST-BENEFIT ANALYSIS OF--

PWR POLAR CRANE CONVERSION TO SINGLE-FAILURE-PROOF FEATURES'

SCOPE

The safety benefit of converting the polar crane in the containment of an operating or completed or nearly completed PWR to single-failure-proof features and the cost of the conversion were estimated and compared.

The safety benefit was estimated in terms of the resulting reduction in the risk of a severe accident, involving major radioactive material release, during the remaining plant life. The risk was expressed as the product of the accident probability and the population radiation dose from the release, should the accident occur.

The cost estimate included the cost of shutdown (or extension of a non-operating period) needed to accomplish the conversion.

ACCIDENT FREQUENCY ESTIMATES

Crane Failure Frequency There were 32 crane LER events in the approximately 400 reactor-years of U.S. power-reactor operation in the 10-year period July 1969 to July 1979 (NUREG-0612, p. 4-6). None resulted in radioactive release. Of the 32 events, 17 (i.e., just over half) were apparently due to hardware design or fabrication causes, the other 15 to human factors. (Navy crane statistics, cited in NUREG-0612, for 40 load-drop or potential load-drop events in

1974-77 show 80% of the events to be due to human factors.)

- 2 -

It may be assumed, as a rough approximation, that Phase I of NRC's heavy-loads generic program is addressed to all the human factors causes and one-half of the hardware causes and succeeds in reducing the affected part of the failure frequency to a quite small fraction of the frequency originally present. Since human factors and hardware each contribute about one-half of the failures, approximately 3/4 of the total crane failures can be expected to be eliminated by the Phase I program. Single-failure-proof (SFP) cranes should substantially reduce the remaining 1/4 of the failure frequency, though those failures would not be eliminated altogether, since the SFP feature (as. defined in NUREG-0554) does not protect against all types of possible failure (e.g., the bridge is not SFP and the SFP feature itself is subject to defeat by some types of human error). On the other hand, the SFP feature would make the cranes more "forgiving" of imperfections in the Phase I implementation. Accordingly, one may reasonably assume that the SFP

feature would have a net effect of eliminating 1/4 of the pre-Phase I

failure frequency.

Frequency of Accidents Involving Radioactive Release Not all LER events involve radioactive release. In over 600 reactor-years of U.S. power-reactor operation to date [1982) there have, to our knowledge, been no radioactive releases due to load drops. The 10-year period covered by the survey in NUREG-0612, which included 32 crane LER events, all without release, represents about 60% of all U.S. power-reactor operating time to date. An assumption of a pre-fix frequency of some radioactive release once in 1,000 reactor-years appears consistent with the LER-reflected failure experience, taken together with the absence of releases to date. With 1/4 of these releases averted by an SFP crane feature,,-the pertinent release frequency reduction would be 1 in 4,000 RY. For the most part, these can be assumed to be minor releases due to limited fuel damage in the spent-fuel storage pool or in the reactor.

- 3 -

Frequency of Accidents Involving Major Releases For a load-drop event to cause a major accident, with major radioactive release, special circumstances need to be present -- circumstances that Phase I is intended to make much less likely to occur. A highly damaging heavy load drop, such as one that could destroy a core cooling feature through violation of -- or imperfections in -- Phase I provisions combined with other failures, should be unlikely, and very unlikely to lead to major release, because of back-up safety provisions (e.g., independent additional core cooling provisions).,

Review of typical load paths and associated crane-operation frequencies suggests that of all load drops in a typical PWR plant that could have radiological consequences, some 1/4 could involve equipment with a role in safe reactor shutdown, including primary-system piping. If one assumes that there is typically a 1% probability that back-up revisions would also fail, then the pertinent major-release frequency is 1 in 1,600,000 reactor-years.

Frequency Reduction Single-failure-proof cranes may reasonably be expected to eliminate most, perhaps 90%, of the residual load-drop probability after the Phase I

improvements. Thus, the frequency reduction for major release is approximately 1 in 1,800,000 RY (90% of 1/1,600,000).

It should be noted that these estimates are sensitive to plant layout.

Plant-specific evaluations could, depending on case specifics, point to a much higher or lower major-release frequency estimate for a specific case.

For example, should layout of a specific plant be such that a particularly unfortunate load drop could destroy all means of core cooling or incapacitate the control room (possibilities suggested by the situations at Montecello and Arkansas Nuclear 1, respectively, before remedial actions were taken at those plants), the above generic analysis could be wide of the mark

- 4 -

for such a plant. The major-release accident frequency could well be an order of magnitude higher for such a plant (i.e., of the order of 1 in

100,000 reactor-years) -- or even higher, depending on plant and crane features, load paths, and operating practices.

CONSEQUENCES ESTIMATE

Potential radiological consequences of load-drop accidents encompass a wide

.range of possibilities, depending on specific features of plant design, operating practices, and the nature and location of the specific load-drop event. We assume that some -- though very rough -- indication of the severity of the load-drop accident-risks may be gained by using in these simplified calculations certain selected release categories described in WASH-1400, Appendix VI, pp. 2-1 to 2-4. Category PWR 4 was selected for the major-release estimates for pressurized water reactors.

In PWR 4 core cooling and containment both fail. Core melt occurs. -This release category is used to explore consequences of a load drop that incapacitates core cooling (during or promptly after reactor operation),

with containment open.

The release estimates, stated as resulting public dose, based on representative generic estimates, for a hypothetical site with a projected Year 2000 mean U.S. power-reactor-site population density, developed by Battelle Pacific Northwest Laboratories (NUREG/CR-2800) is 2,700,000

person-rem.

COST ESTIMATE

Costs of change-over to single-failure-proof cranes are subject to wide plant-specific variation, depending on the number of features of the specific cranes involved and other aspects of plant design and status.

- 5 -

Based on advice from the Auxiliary Systems Branch, DSI, and limited vendor and utility contacts.,'we take thelfollowing estimates as representative (as of 1982, when the estimates were made).

For future plants, the cost differential for original inclusion of SFP

features is estimated at about $250,000 for PWRs (based on information from Ederer Crane Co.).

At the pre-operating-license stage, with no startup delay, the costs --

including planning, engineering, hardware, installation, and testing -- are estimated at $2 million per plant. This is based on the Monticello experience (1.M in 1976, adjusted for inflation). (The Monticello information was obtained from the licensee through the NRC resident inspector.)

For operating PWRs the estimated costs are dominated by plant shutdown during modifications of the polar crane located inside the containment building. (The shutdown may be an extension of a shutdown for refueling oi4t other purposes.) The cost effect of a startup delay for a completed or nearly completed plant would be similar. With a 3-month shutdown and with shutdown..

costs taken as determined by the cost of replacement power at $300,000 per day,.representative total change-over costs for operating PWRs are estimated at about $30 million.

RISK REDUCTION

Based on the foregoing frequency and consequences estimates, the "expected value" of the risk subject to being affected by the possible Phase II SFP

feature, i.e., the magnitude of release times the frequency of its

I

I

-6- occurrence, integrated for the remaining plant life taken as 20years,'is as follows:

Major release risk 20 x 2,700,000 = 30 person-rem/reactor

2,800,000

COST-BENEFIT RATIO

The cost-benefit ratio indicated by the foregoing estimates is approximately

$1,000,000/person-rem. This. estimate is subject to wide plant-to-plant variation as well as large uncertainties in the underlying estimates of accident frequency and consequences. Nevertheless, it is possible to conclude with reasonable confidence that the benefit-cost ratio for the crane conversion would fail to meet a $1,000/person-rem worthwhileness criterion by a large margin.

7-;-.-'e ,

. . I - , .

TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEAR

POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )

On December 22, 1980, NRC issued a generic letter (unnumbered) which was supplemented February 3, 1981 (Generic Letter.81-07) regarding NUREG-0612,

"Control of Heavy Loads at Nuclear Power Plants". This letter requested that you implement certain interim actions and provide the NRC information related to heavy loads at your facilities. Your submittals were requested in two parts; a six month response (Phase I) and a nine month response (Phase II).

All licensees have completed the requirement to perform a review and submit a Phase I and a Phase II report. We believe that further action is not required based on the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I). Therefore, a detailed Phase II

review of heavy loads is not necessary and Phase II is considered completed.

However, while not a requirement, we encourage the implementation of any actions identified in Phase II regarding the handling of heavy loads.

For each plant which has a license condition requiring commitments acceptable to the NRC regarding Phase II, an application for license amendment may be submitted to the NRC to delete the license condition citing this letter as the basis, If you have any questions, contact your Project Manager or Don Neighbors (301) 492-4837.

Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing

  • See previous white for concurrences ORB#1:DL* ORB#1:DL* BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DL

CParrish JDNeighbors;ps SVarga Bernero GLainas HThompson

3/7 /85 5/6/85 3/11/85 3/13/85 3/19 /85 5/ /85 AD/L* OELD*

TNovak

3/21/85 4/22/85

TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLE

POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )

On December 22, 1980, we issued a generic letter which was sup enented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612 'Control of Heavy Loads at Nuclear Power Plants". This letter request that you Implement certain interim actions and provide the NRC inf ation related to heavy loads at your facilities. Your submittals were t ave been in two parts; six month response (Phase I) and nine month re onse (Phase II).

We have almost completed Phase I of our review and ost licensees have received a plant specific letter closing Phase I.

As for Phase II, we believe that further NRC ac on is not necessary. As indicated in the enclosure, we conclude this othe basis of the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I), the results of the Pha e II pilot program performed by our contractor, Franklin Research Center which identified no further heavy loads handling concerns, ad tional evaluations of Phase II

submittals by the staff and cost benefit We, therefore, consider this portion ( ase II) of our review of heavy loads complete. However, while not a equirement, we encourage the implementation of any actions identi ed in Phase II regarding the handling of heavy loads.

For each plant which has a licens condition, an application for license amendment should be submitted to he NRC to delete the license condition using this letter as-the basis. If you have any questions, contact your Project Manager or Don Neighbor (301) 492-4837.

Sincerely, Hugh L. Thompson, Jr., Director Enclosure: Division of Licensing As stated

  • See previous white or concurrences ORB#1:DL* ORB BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DL

CParrish JDNe ors;ps SVarga Bernero GLainas HThompson

3/7 /85 3/11/85 3/13/85 3/19 /85 4/ /85 AD/L* OELD%

TNovak

3/21/85 4/ /85

TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT NUCLEAR

POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )

On December 22, 1980, we issued a generic letter which was supplemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants". This letter requested that you implement certain interim actions and provide the NRC information related to heavy loads at your facilities. Your submittals were to have been in two parts; six month response (Phase I) and nine month response (Phase II).

We have almost completed Phase I of our review and most licensees have received a plant specific letter closing Phase I.

As for Phase II, we believe that further NRC action is not necessary. As indicated in the enclosure, we conclude this on the basis of the improvements in heavy loads handling obtained from implementation of NUREG-0612 (Phase I), the results of the Phase II pilot program performed by our contractor, Franklin Research Institute which identified no further heavy loads handling concerns, additional evaluations of Phase II

submittals by the staff and cost benefit.

We, therefore, consider this portion (Phase II) of our review of heavy loads complete.

For each plant which has a license condition, an application for license amendment should be submitted to the NRC to delete the license condition using this letter as the basis. If you have any questions, contact your Project Manager or Don Neighbors (301) 492-4837.

Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing

  • See previous white for concurrences A

ORB#1:DL* ORB#1:DL BC-ORB#1:DL* D/DSI* AD:OR:DL*13DL

CParrish J jbg' bors;ps SVarga Bernero GLainas HThompson

3/7 /85 4/4185 3/11/85 3/13/85 3/19 /85 4/ /85 AD/L* OELD

TNovak

3/21/85 4/ /85

\ Ao,41 f9

tm- TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOADS AT N LEAR

POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- )

On December 22, 1980, we issued a generic letter which was s plemented February 3, 1981 (Generic Letter 81-07) regarding NUREG-06 , "Control of Heavy Loads at Nuclear Power Plants". This letter reque ed that you implement certain interim actions and provide the NRC i ormation related to heavy loads at your facilities. Your submittals were o have been in two parts; six month response (Phase I) and nine month r ponse (Phase II).

We have almost completed Phase I of our review an most licensees have received a plant specific letter closing Phase As for Phase II, we believe that further NRC ction is not necessary. As indicated in the enclosure, we conclude this on the basis of the improvements in heavy loads handling obtai d from implementation of NUREG-0612 (Phase I), the results of the P ase II pilot program performed by our contractor, Franklin Research Ins tute which identified no further heavy loads handling concerns, ditional evaluations of Phase II

submittals by the staff and cost benef .

We, therefore, consider this portio (Phase II) of our review of heavy loads complete.

For those plants which have lice e conditions, this letter resolves the requirements of those condition as far as meeting the generic concerns of NUREG-0612. If you have any estions, contact your Project Manager or Don Neighbors on 301-492-4837.

Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing

  • See previous Ite for concurrences ORB#1:DL* / 1-5DL BC-ORB#1:DL* D/DSI* AD:OR:DL* D:DL

CParrish / ighbors;ps SVarga Bernero GLainas HThompson

3/7 /85,/- :tV85 3/11/85 3/13/85 3/197/85 3/ /85

- I

TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY XADS AT NUCLEAR

POWER PLANTS" NUREG-0612. (GENERIC LETTER - )

On December 22, 1980, we issued a generic letter ich was supplemented February 3, 1981 (Generic Letter 81-07) regardin NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants". This let r requested that you Implement certain interim actions and provide e NRC information related to heavy loads at your facilities. Your submitt s were to have been in two parts; six month response (Phase I) and nin month response (Phase II).

We have almost completed Phase I of our r lew and most licensees have received a plant specific letter closing hase I.

As for Phase II, we believe that furth NRC action is not necessary. As indicated in the enclosure, we conclu e this on the basis of the improvements in heavy loads handlin obtained from implementation of NUREG-0612 (Phase I), the results the Phase II pilot program performed by our contractor, Franklin Researh Institute which identified no further heavy loads handling con rns, additional evaluations of Phase II

submittals by the staff and cos benefit.

We, therefore, consider this rtion (Phase II) of our review of heavy loads complete.

For those plants which hav license conditions, this letter resolves the requirements of those con tions as far as meeting the generic concerns of NUREG-0612.

Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing

CONTACT

J. D. Neighbor X24837 ORB#l:DL* *See previous white for concurrence CParrish>.

3/7/85

7 OR )8 1 fiB#1:DL A dA AHX :DL D:DL

JDt Ihbors; SY a D4Arnero GL s HThompson

3 J 8 31/5/85 3 /85 3/ /85

TO ALL LICENSEES FOR OPERATING REACTORS

Gentlemen:

SUBJECT: COMPLETION OF PHASE II OF "CONTROL OF HEAVY LOAD AT NUCLEAR

POWER PLANTS" NUREG-0612. (GENERIC LETTER 85- On December 22, 1980, we issued a generic letter which As supplemented February 3, 1981 (Generic Letter 81-07) regarding NUR -0612, "Control of Heavy Loads at Nuclear Power Plants". This letter r uested that you implement certain interim actions and provide the C information related to heavy loads at your facilities. Your submittals re to have been in two parts; six month response (Phase I) and nine mon response (Phase II).

We have almost completed Phase I of our revie and most licensees have received a letter closing Phase I. Only a f plants remain to be reviewed.

As for Phase II, we believe that further C action is not necessary. As indicated in the enclosure, we conclude is on the basis of the improvements in heavy loads handling ob ained from implementation of NUREG-0612 (Phase I), the results of e Phase II pilot program performed by our contractor, Franklin Research nstitute which identified no further heavy loads handling concer additional evaluations of Phase II

submittals by the staff and cost b nefit.

We, therefore, consider this po ion (Phase II) of our review of heavy loads complete. TlHowever, this ction is not intended to preclude licensees from making improvements in t Ir load handling systems which they feel are necessary for safe load hand ing.)

For those plants which hay license conditions, this letter resolves the requirements of those co itions as far as meeting the generic concerns of NUREG-0612.

Sincerely, Hugh L. Thompson, Jr., Director Division of Licensing

CONTACT

J. D. Neighbor X24837 ORB#1:DL ORB BC-ORB#1:DL D/DSI AD:OR:DL D:DL

CParrish ' JDN hbors;ps SVarga Bernero GLainas HThompson

3/4 /85 M 3 3/ /85 3/ /85 3/ /85 3/ /85

. I

DISTRIBUTION

Central File CParrish JDNeighbors SVarga GLainas Bernero HThompson ORB#1:Rdg Memo File TNovak

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