ML20038C531

Forwards Revised Response to NRC 801222 Ltr,Section 2.1, Re Control of Heavy Loads,Including Item 2.1-30

ML20038C531
Person / Time
Site:	Fort Calhoun
Issue date:	11/30/1981
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Clark R Office of Nuclear Reactor Regulation
References
REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NUDOCS 8112110194
Download: ML20038C531 (16)

Text

{{#Wiki_filter:V e i . e* *., Omaha Public Power District 1623 HARNEY a O M A H A.

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NEBRASKA 68002 s TELEPHONE 536 4000 AREA CODE 402 November 30, 1981

                                                                   \                   A 6Y       rpr-Mr. Robert A. Clark, Chief U. S. Nuclear Regulatory Commission                   ,Q/ p/((j/*     l        p(g, Office of Nuclear Reactor Regulation                  gi  Og                      C Division of Licensing                                  1

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Operating Reactors Branch No. 3 8 Washington, D.C. 20555 k\/ 74QN[7 [

Reference:

Docket No. 50-285 \hlr s gl-{ r

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Dear Mr. Clark:

The Omaha Public Power District's letter dated June 22, 1981 was submitted in response to Section 2.1 of the Commission's letter dated December 22, 1980 regarding control of heavy loads. The District's June 22, 1981 letter did not address Item 2.1-3d of the Commission's letter due to a requirement for information from one of our vendors. Accordingly, the District submits the attached response to Section 2.1 which has been revised to include information responding to Item 2.1-3d. Sin rely , I l

                                                          ?AO W. C. Jones Divis on Manager Production Operations WCJ/KJM/TLP:jmm Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 P M8waugg, 1 H\ PDR

RESPONSE TO SECTION 2.1 REQUEST FOR ADDITIONAL INFORMATION ON CONTROL OF HEAVY LOADS 2.1 General Requirements for Overhead Handling Systems 2.1 Report the results of your review of plant arrangements to identify all overhead handling systems from which a load drop may result in damage to any system required for plant shutdown or decay heat removal (taking no credit for any interlocks, technical specifications, operating procedures, or detailed structural analysis). RESPONSE 1: The cranes and trolleys identified throughout the plant that handle loads in areas where equipment for shutdown or decay heat removal is located are listed below. CONTAINMENT Polar Crane AUXILIARY BUILDING Auxiliary Building Crane ITEM 2.1-2 Just'ify the exclusion of any overhead handling system from the above category by ver.ifying that there is sufficient physical separation from any load-impact point and any safety-related component to permit

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a determination by inspection that no heavy load drop can result in damage to any system or component required for plant shutdown or decay heat removal. RESPONSE 2: The following cranes and hoists have been excluded from Item 1. a) The turbine building crane was excluded from Item 1 above since no system or component required for plant shutdown or core decay heat removal is located in this building, b) The drumming; area and the maintenance shop crancs also are not listed since there is no safe shutdown or decay heat removal equipment in these areas. c) The two 24-ton monorails in the Diesel Generator Station Area do not have a hoist physically attached to them. The hoist is stored elsewhere, and only used for maint enace on one or the other Diesel Generator, only one generator can be serviced at any given time by this hoist. Thus this crane has been excluded from Item 1. 1 .

d) The Filter Area Crane has also been excluded from Item 1 above since no system or component required for plant shutdown or decay heat removal is located in this area. e) The two concrete slab removal cranes, the waste evaporator equipment handl-ing crane and the deborating demineralizer area crane are excluded since a heavy load dropped from these cranes cannot prevent the plant from achiev-ing hot shutdown. The system that these cranes operate over (the Safety Injection pump room) is not required to ac!.ieve hot shutdown. These cranes are physically separated by two floors from the Safety Injection pump room. The ability of these floors to withstand a heavy load drop will be verified by analysis. f) There are also miscellaneous plant hoists located in the turbine building. These hoists are completely separated from any safe shutdown or decay heat removal equipment. g) The Intake Structure crane has been excluded since a heavy load dropped from this crane cannot prevent the plant from achieving hot shutdown. The system that this crane operates over (the raw water system) is not required to achieve hot shutdown. The crane is separated f rom the raw water system by an intervening floor. The ability of this floor to with-stand a load drop will be verified by analysis. h) There is also a jib crane being installed in Containment. This crane will only be used when the plant is shutdown. It will be installed on el. 1045'0" near the Reactor Vessel Closure llead laydown area. This crane has a capacity of IT. and will be used to work on CEDM's. Since this is not a permanently installed crane, and will only be used during plant shutdown, the District believes it should be excluded from item 1 above. ITEM 2.1-3 With respect to the design and operation of heavy-load-handling systems in the containment and the spent-fuel pool area and those load-handling systems identified in 2.1-1, above, provide your evaluation concerning compliance with the guidelines of NUREG 0612, Section 5.1.1. The following specific information should he included in your reply: ITEM 2.1-3a Drawings or sketches sufficient to clearly identify the location of safe load paths, spent fuel, and safety-related equipment. RESPONSE 3a: The prints listed below are attached: GilDR Drawings: 11405-A-5 el. 989'0" - Primary Plant Basement Level 11405-A-6 1007'0" - Primary Plant Ground Level 11405-A-7 1025'0" - Primary Plant Intermediate Level 11405-A-8 1036'0" - Polar Crane Restricted Areas 11405-A-8 1036'0" - Auxiliary Building' Crane Restricted Areas 2 .

These drawings have load paths for the polar crane and auxiliary building crane clearly marked, and the nearby equipment is also identified. Sate load path information concerning containment and the auxiliary building was also previously submitted to NRC in the District's letter from T. E. Short to Robert W. Reid dated August 9, 1978. ITEM 2.1 - 3b A discussion of measures taken to ensure that load-handling operations remain within safe load paths, including procedures, if any, for deviation from these paths. RESPONSE 3b: Loads moved in the areas defined in Section 5.1.l(1) (Containment and Auxiliary Building Crane) are listed in attached Table 3-1. The procedures governing these loads are also listed. Load numbers 1 through 4 listed in Table 3-1 are covered by maintenance procedures. The paths for the movement of these loads are not explicitly stated in the proce-dures, but the load paths are restricted by operating instructions OI-IIE-1 for the polar crane, and 01-IIE-5 for the Auxiliary Building Crane. These restrictions are as follows: OI-lie-1

1. The polar crane will not be used to carry loads over the reactor coolant system when the reactor coolant systen temperature exceeds 225 F (Technical Specification 2.11(1).

2. The polar crane will not be used to transport any load over the core when the reactor vessel head is removed without Plant Review Committee (PRC) approved procedure.

3. The polar crane will not be used to transport any load over the area bounded by containment columns 10 and 11 and the RC-2B biological shield without a PRC approved precedure pending the results of a load drop analysis.

4. Loads should not be lifted higher than necessary to safely clear obstacles along the load path.

The operating instruction for the Auxiliary Building Crane (OI-IIE-5) will provide the following restriction:

1. The Auxiliary Building Crane will not be operated over the spent fuel pool without a qualified crane stgervisor present and a PRC approved procedure.

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DISCUSSION 3b: The District is of the opinion that the restrictions on the Polar Crane operation given above provide for a safe load path by exclusion. The potential to impact irradiated fuel is minimized by allowing only necessary loads to be transported over the core and by using a PRC approved procedure as indicated in Table 3-1. Ileavy loads are moved with the polar crane only during refueling. These loads are the reactor vessel head, the upper guide structure and the four missile shields. Technical Specification 2.8.5 requires one shutdown coolant pump and one heat exchanger to be in operation during refueling. The pumps used for thutdown cooling are low pressure safety injection pumps. These pumps are located in the auxiliary building rather than in containment as are both shutdown heat exchangers. Associated piping and cabling is located below the level that could be reached by a dropped component. The conclusion is that no heavy load drop can be postulated which would inter-fere with the safe shutdown of the plant since heavy loads are not handled while the plant is operating. While the plant is shutdown there are no loads which would affect the equipment required to be operating, because the required equipment is located away from the area the loads are being handled. If a heavy load drop were to occur over the core, the release of offsite doses can be reduced by rapid containment isolation on a high radiation signal. Also, decay heat removal capability is assured by prohibiting transport of a heavy load over locations where a single load drop could remove both flPSI and LPSI as decay heat removal paths unless an alternative decay heat removal path is avail-able. Safe shutdown and decay heat removal capability is therefore, assured. Movement of the trolley over the core with no loads on the hooks is allowed since only a spontaneous failure of the cable or sheeves could cause a load drop in this mode. The possibility of this type of failure is minimized by the preoperational inspections performed per Item 3e. Load numbers 5 and 6 are governed by maintenance and special procedures. Although the paths for these movements are not stated they are restricted by OI-HE-5. We feel this restriction on the Auxiliary Building Crane provides a safe load path by exclusion. The potential to impact irradiated fuel is minimized by not allowing loads to be carried over irradiated fuel (Technical Specification 2.11(2)). The potential for a load drop in this area, is also minimized by the fact that we are currently installing a new retrofitted

     " single-failure proof" crane in the auxiliary building.

If the analysis requested by the NRC indicates that other controls are appropriate they will be addressed in the report covering Section 2.2 - 2.4. ITEM 2.1 - 3c A tabulation of heavy loads to be handled by each crane which includes the load identification, load weight, its designated lifting device, and verifi-cation that the handling of such load is governed by a written procedure containing, as a minimum, the information identified in NUREG 0612, Section 5.1.l(2). . 4 i 1

RESPONSE 3c: The attached Table 3-2 lists the cranes and the loads normally handled by each. Table 3-1 indicates the written procedures that govern the handling of each load. These procedures include identification of required equipment, inspections, and acceptance criteria required before movement of the load, and steps and proper sequence to be followed in handling the load. These procedures meet the intent of Section 5.1.1(2) of NUREG 0612. Restrictions on loads in the vicinity of spent fuel pool and reactor core are stated in OI-HE-5 and OI-HE-1 respectively. These were addressed in Item 2.1 - 3b. Procedures are also available for spent resin and filter disposal. These pro-cedures do not address load handling since these loads are not carried over or in proximity to irradiated fuel or safe shutdown equipment. Procedures for handling other heavy loads identified in Table 3.1-1 of NUREG 0612 will be written and/or reviewed prior to handling of those heavy loads. Specific load handling devices are identified below: Reactor Vessel Closure Head Lifting Rig Upper Guide Structure Lift Rig ITEM 2.1 - 3d Verification that lifting devices identified in 2.1.3c, above, comply with the requirements of ANSI N14.6-1978, or ANSI B30.9-1971 as appropriate. For lif ting devices where these standards, as supplemented by NUREG 0612, Section 5.1.1(4) or 5.1.1(5), are not met, describe any proposed alternatives and demonstrate their equivalency in terms of load-handling reliability. RESPONSE 3d: The lifting devices identified in 2.1.3.c above, were designed before the ANSI N14.6-1978, ANSI B30.9-1971 codes were developed. These devices were designed according to industrial standards. i) Reactor Vessel Closure Head Lift Rig The Reactor Vessel Closure Head Lift Rig was designed using AISC Standards the 6th edition. A review of the design calculations shows that the lowest ratio of ultimate strength to the stress level resulting from the normal dead weight is found to be 3.7. The load bearing members are capable of lifting 2.1 times the normal dead weight instead of 3 times as specified in ANSI N14.6-1978 with-out exceeding the minimum yield strength. All other elements of the lift rig exceed the 5/1 safety factor. Although the lift rig was not load tested prior to shipment to Fort Calhoun, this rig has been in use for approximately 10 years and this should indicate its adequacy for load handling reliability. 5 .

The structural analysis indicates safe practice was used in the design of this lift rig. Also this rig was designed solely for the purpose of lifting the RV head and will not be used for any other purpose. Considering the factors of safety used in design and past experience _ we feel that we meet the intent of 0612. (ii) Upper Guide Structures Lift Rig The Upper Guide Structure Lift Rig was designed with a 5/1 safety factor. The load bearing members of this lift rig were designed with the capability of lifting twice the normal dead weight. The Upper Guide Structure Lif t Rig was load tested to 125% of the maximum load. The membrane stresses were designed for 20KSI, bending stress 30KSI, shear 12 KSI, and ultimate stress 75KSI. ANSI N14.6-1978 did not exist at the time of Fort Calhoun's design, and we feel that using a design factor of 2 instead of 3 is considered to be adequate. Also load testing the Upper Guide Structure Lift Rig to 125% instead of 150% is con-sidered safe practice. ITEM 2.1 - 3e Verification that ANSI B30.2-1976, Chapter 2-2, has been invoked with respect to crane inspection, testing, and maintenance. Where any exception is taken to this standard, sufficient information should be provided to demonstrate the equivalency of proposed alternatives. RESPONSE 3e: The Auxiliary Building Crane and the Containment Polar Crane will be inspected and maintained in accordance with ANSI B30.2-1976. The Auxiliary Building Crane will be inspected daily or prior to each use (whichever is less frequent) according to 01-HE-5. The daily inspection will include checking operation of the hoist uplimit switches and normal operating controls and a visual inspection of the hook, hook latch and hoist rope of the hooks to be used. A monthly inspection will include checking operation of the spent fuel pool boundary limit switches, and the bridge and trolley travel limit switches and inspection of the hoist rope and end clamps. The Containment Polar Crane will be inspected daily and during use, according to OI-HE-1 (Refueling Outages). The daily inspection will include checking operation of the hoist uplimit switches and normal operating controls and a visual inspection of the hook latch and hoist rope of the hooks to be used. A monthly inspection (HP-HE-1A), performed during refueling, will include checking operation of the trolley travel limit switches and inspection of the hoist rope and end clamps. Additional maintenance and inspections are performed as part of the preventive maintenance program and as prerequisites to specific critical lifts. 6 .

ITEM 2.1 - 3f Verification that crane design complies with the guidelines of CMAA Specification 70 and Chapter 2-1 of ANSI B30.2-1976, including the demonstration of equivalency of actual design requirements for instances where specific compliance with these standards is not provided. RESPONSE 3f:

1. The Containment Polar Crane used at Fort Calhoun was purchased to Gibbs, Hill, Durham and Richardsons' specifications for Hoisting Equipment.

This specification was based on the Electric Overhead Crane Institute, Inc. Specifications and USAS Safety Code B30.2-1967. A comparison of the requirements of G.H.D.&R specs to the CMAA-70-1975 specification is shown in Table 3-3. Tables 3-3, 3-4, 3-5 and the following discussion shows that the Fort Calhoun polar crane procurement specification meets the intent of CMAA-70.

2. The Auxiliary Building Crane is currently being retrofitted. The crane's main hook will be classified as a " single - failure prcof" retrofitted trolly system. The auxiliary hook is being analyzed currently to show compliance to the single-failure proof criteria of NUREG-0612, and NUREG-0554. If it is found that this hook is in non-compliance with single-failure proof guidelines, a load drop analysis will be performed according to NUREG-0612 guidelines. The new crane has been designed to meet ANSI-B30.2-1976 Standards and CMAA Spec. No. 70.

DISCUSSION 3f:

1. Impact Force: The Electric Overhead Crane Institute's (EOCI)

Specification was referenced in the design for the Polar Crane. This specification requires a design force equal to 15% of the rated capacity of the crane. The CMAA #70-1975 specifies that the impact load be 1/2% load x hoist speed in feet per minute and that the impact should not be less than 15% or greater than 50% of the rated capacity. Therefore, the Polar Crane has been procured to a criteria which conforms to the requirements of CMAA specification for hoist speed less than 30 ft/ min. The Polar Crane has a hoist speed of 6ft/ min or less. Therefore, this crane satisfies CMAA-70-75.

2. Compressive Stress: As shown in Tabic 3-3, the allowable compressive stress specified in the Polar Cranc design specifications is identical to those specified by CMAA-70-1975 for members with non-slender com-pressive flange. A comparison of the allowable compressive stress criteria given in the design specifications and CMAA-1975 is shown re 3-1. r the Polar Crane in Fort Calhoun in Figg/c has a ratio of 24.The box girders fg/c ratio,this structural element For this meets the requirements of CMAA 70-1975.

ITEM 2.1 - 3g: Exceptions, if any, taken to ANSI B30.2-1976 with respect to operator training, qualification, and conduct. 7

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RESPONSE 3g: It has been determined that our standing order M-8 " Control of Crane Operations" does comply with ANSI B30.2-1976. This order requires operators, signalmen and supervisors of the Containment Polar Crane and the Auxiliary Building Crane to be trained and qualified, in accordance with ANSI B30.2-1976. Quality Control administers qualification exercises and retains certifications. Current 1 f, qualified crane operators, signalmen and supervisors will be advised of new requirements resulting from NUREG 0612, 8 .

TABLE 3-1 Load Procedure

1. Reactor Vessel Closure MP-RC-6-1 Head and Lifting Rig " Removal of Reactor Vessel Closure Head" MP-RC-6-2

                                      " Inspection and Replacement of Reactor Vessel Closure Head"

2. Reactor Upper Internals SP-RC-6-2 and Lifting Rig " Upper Guide Structure Lift Rig and ICI Plate Removal and Installation" MP-RC-7-2-A

                                      " Upper Guide Structure and ICI Plate Removal" MP-RC-7-2-B
                                      " Upper Guide Structure and ICI Plate Installation"

3. Missile Shields MP-AE-4-1

                                      " Missile Shield Removal" MP-AE-4-2
                                      " Missile Shield Replacement"

4. Spent Fueld Pool Gates MP-FH-16-1

                                      " Removal of Spent Fuel Pool Gates" MP-FH-16-2
                                      " Installation of Spent Fuel Pool Gates"

5. New Fuel SP-NFR-2

                                      " Fuel Receipt Procedures"

6. Spent Fuel No procedure now. Will be Shipping Cask developed when needed.

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TABLE 3-2 Crane /lloi s_t Location Load Weight Load Path Polar Crane Containment Missile 10T each See Figure 1A 130T Main Hook elev. 1095'-1/2" Shields Diagrams A-1, A-2 10T 4.ux. Hook A-3, in 8-9-78 Reactor Vessel 120T letter Closure Head (including studs) Upper Guide 40T Also refer to Structure (including OI-HE-1 lifting rig) Auxiliary Bldg. Auxiliary Bldg. Spent Fuel IT. OI-HE-5 Crane Crane Pool Gates 75T Main Hook elev. 1065'-0" 10T Aux. Hook New Fuel 1.51. SP-NFR-2 Receipt Spent Fuel 30T No procedure Shipping Cask now. Will be developed when needed. 10

• TABLE 3-3 OVERHEAD AND GANTRY CRANES COMPARISON OF STRUCTURAL DESIGN CRITERIA FORT CALHOUN STATION UNIT 1 Allowable Stresses Hoisting (2)

Structural Structural (ksi) Rope Non-Structural

   -Requirements                Design Forces           Steel                    (1)                   Related   Load Bearing Specification         Impact =I      Lateral       Material Tension     Compression Shear Bearing    Cap      Capacity CMAA Spec.        1. 1/2% Load       2-1/2% of     ASTM-A36   17.6      17.6 for    13.2   26.4      20%      20%
    #70 Copyright         x (Hoist       (live Load                         b/c $ 38                   Breaking Fultimate-1975                  Speed in       + Bridge)                                                     Strength Class Al              ft/ min (Standby          2. 15% $I $50%

Service) of rated capacity

  % Fort Calhoun          I=15%          5% of         (3)        16.0                  12.0   21.6 Polar Crane           of the rated   (Live Load    ASTM-A36 f6.0for                      20%       20%
                                                                             /c $ 41                  Breaking   Fultimate EOCI                   capacity       + Bridge)                                                    Strength Spec. #61 NOTES:

1. b= distance between web plates (inches).

c= thickness of top cover plate (inches).

2. Fult = published average utlimate stress of mat.erial.

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3. We specified ASTM-A36 steel, instead of ASTM-A7 as. published in EOCI #61 O

TABLE 3-4 COMPARISON OF E0CI AND CMAA DESIGN STRESS CRITERIA EOCI #61 CMAA #70 Design stress of load carrying Shall not exceed Shall not exceed 20% of parts except structural members, 20% of the assumed the published average gearing and hoisting ropes average ultimate ultimate strength of the strength of the material material Hoisting rope selection The rated capacity The rated load capacity plus load divided by the the bottom block divided by number of parts of the number of parts of rope rope shall not exceed shall not exceed 20% of the 20% of the published published breaking strength breaking strength of of the rope the rope Structural Materials Selection ASTM-A7 or Suitable ASTM-A36 or Suitable alternate alternate Basic allowable stresses for Tension =16,000 psi Tension =17,600 psi Bridge Girder Compression =16,000 psi Compression =17,600 psi Shear =12,000 psi Shear =13,200 psi Basic allowable stresses for Shall not exceed 20% Tension =14,400 psi End trucks of the assumed average Compression =14,400 psi ultimate strength of the Shear =10,800 psi material Basic allowable stresses for Shall not exceed 20% Tension =14,400 psi Trolley Frames of the assumed average Compression =14,400 psi ultimate strength of Shear =10,800 psi the material Gear strength Shall be such that the Shall be per the American stress in the material Gear Mfrs. Assoc. (AGMA) does not exceed 20% of Standard the assumed average ultimate strength of the material l t I 12 l

TABLE 3-5 COMPARISON OF USAS B30.2.0 and ANSI B30.2.0 USAS B30.2.0 - 1967 ANSI B30.2.0 - 1976 Clearances from Specified as 3" overhead Does not specify specific Obstructions 2" laterally clearance dimensions Welding Per AWS D 2.0-66 Per AWS D14.1 Girders Reqaired to be of To be designed to either adequate design CHAA, AISC or AISE Cab clearances Specified as 3" from Does not specify a specific all fixed structures clearance dimensions Toeboards & Handrails Per USAS A 12-1932 Per latest issue of ANSI A 12.1 Ladders Per USAS A 14.3-1956 Per latest addition of ANSI 14.3, which requires cages on ladders greater than 20 ft. Egress from Operator's No mention of egress Recommends a means of egress Cab for emergencies Bridge & Trolley Bumper Recommends the use of Recommends the use of Bumper, Bumper or other automatic means pro-viding equivalent effect Bridge & Trolley Brakes Specifies a size require- Specifies a deceleration re-ments for deceleration quirement for the brakes in addition to size requirements Electrical Equipnent Per Article 610 of Per latest issue of NFPA 70, USAS CI-1965 Article 610, which requires a 30" walkway width in front of electrical enclosures 13 .

TABLE 3-5 (Cont'd) USAS B30.20.0 - 1967 ANSI B30.3.0 - 1976 Hoisting Ropes Requires selection con- Requires selection con-sidering the rated load sidering the rated load only plus the load block Fooks Does not address safety Requires safety latches unless latches the application makes the use of the latch impractical Rated Load Test Does not specify the extent Requires traversing the bridge of traversing for the bridge the full length of the runway, and trolley end the trolley the full lengtl

                                                 .af the bridge 14

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ATTACHMENT Summary of Review of Load Handling Operations at Fort Calhoun With Respect To Section 5.1.1 of NUREG-0612 A review of Section 5.1.1 of NUREG-0612 has shown that the Fort Calhoun Station is substantially in compliance. ( ) points of deviation are discernable and these are itemized below. These points are expanded upon in the specific ques-tion area of this response.

1) In item one of paragraph 5.1.1 of NUREG 0612, Safe Load Paths, a require-ment is made for clearly marking load paths on the floor in the area where the load is to be handled.

2) Also, deviation from defined load paths should require alternative pro-cedures approved by the plant safety review committee.

DISCUSSION: L> ids are moved by the safest and shortest paths. Containment load paths have been previously submitted in T.E. short's letter to Robert W. Reid, 8-9-78, the drawing showing paths are 1A, Diagrams A-1, A-2, A-3. The District is of the opinion that it is not apparent that marking load paths on the floor is feasible or would contribute to reactor safety. As to alternative procedures for deviation from defined load paths, we feel that the restrictions placed on the Polar Crane operation provide for a safe load path by exclusion as discussed in response to 2.1-3b. Thus no alternative procedures will be required. Should the analysis of Fort Calhoun Station's for compliance to paragraphs 5.1.2, 5.1.3, 5.1.5, (due 9-22-81), show additional area specific non-compliance, we will be prepared to revise our procedures to ensure that they are in complete compliance. i l l 15 .

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