ML20080F990

Forwards Responses to Draft Technical Evaluation Rept Open Items Re Control of Heavy Loads,Per .Crane Operators Trained Per ANSI B30.2-1976 Requirements. Installation of New Fuel Storage Racks in Progress

ML20080F990
Person / Time
Site:	Brunswick
Issue date:	02/03/1984
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR NLS-84-002, NLS-84-2, NUDOCS 8402130228
Download: ML20080F990 (10)

Text

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• g CD&L Carolina Power & Light Company SERIAL: NLS-84-002 FEB 0 31984 Director of Nuclear Reactor Regulation Attention: ik. D. B. Vassallo, Chief

' Operating Reactors Branch No. 2 Division of Licensing

-United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO THE TECHNICAL EVALUATION REPORT OPEN ITEMS CONCERNING CONTROL OF HEAVY LOADS

Dear-Mr. Vassallo:

In a letter dated November 3,1983, Carolina Power & Light Company

.(CP&L) received a copy of the draft Technical Evaluation Report (IER) concerning the Control of Heavy Loads issue at the Brunswick Steam Electric Plant (BSEP) Units 1 and 2.. As part of the above letter, CP&L was asked to respond to the open issues discussed in the TER.

Please find enclosed our responses to the open issues. Should you have any questions concerning this letter, please do not hesitate to contact a member of our licensing ctaff.

Yours very truly, I

I immerman S. .

Manager

-Nuclear Licensing Section

.PPC/cfr (9218PPC) cc: Mr' .'D.I O. Myers (NRO-PSEP)

Mr. J. P.'O'Reilly (NRC-RII)

Mr. M. Grotenhuis (NRC) 8402130229 840203 PDR ADDCK 05000324 j 1

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RESPONSE

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- PART I. TECHNICAL _ EVALUATION.R._EPORT L

FOR

'NUREG-0612 CONTROL.OF HEAVY LOADS h

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- TER Page 9, Section 2.1.2, Item C.1

" provide suitable' visual aids to operators t'o ens;re movement of loads along established load path" Re sponse

. As previously stated in the November 16,1982. submittal, safe load paths are -

indicated inl drawings and are referenced in varf ous ' plant. operating p rocedures.- . Die procedures refer maintenance and operations personnel to the

. applicable load path drawing. The load paths follow the safest and shortest routes.with consideration given to going around fuel and safety-related equipment.. During crane operator training and requalification,' crane operators are instructed regarding these . load paths. The work is performed in '

accordance.with the written approved procedures by experienced personnel and supervised by competent f oremen. . Prior to initiating the work activities in the procedure, the foreman critiques the procedure with his men to assure each one knows the correct methods to be followed. Electrical interlocks, as well as.w"itten instructions in the plant procedures, prevent loads from being handled over the spent fuel and reactor except during specific operations.

' In addition, to provide-suitable alternatives to the permanent marking of load paths, CP&L will:

1. L Revise the appropriate operations and maintenance procedures to not only

, reference the applicable load path drawing but to include a copy of the drawing.

!2. : Revise MP-06 to require that the signalman and operator review the load

' path prior to a load movement .and talk the designated load path to the extent physically. possible.

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. , TER Page 9, Se ction 2.1. 2, Item C-2

" verify that deviations f rom established load paths require written alternatives which are approved by the plant safety review committee"

, Re sponse Plant procedures will be revised to include a precautionary statement thut any movement requiring a deviation from the established load path must be done

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under a Special Procedure prepared by the BSEP Engineering staff. Special Procedures (temporary changes to procedures) are reviewed in accordance with Technical Specification 6.5.

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- TER Page 10, Section 2.1.3, Item C

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!~ ~ "upon completion of procedures for replacement of the fuel storage racks, these' procedures should be readily available~for review by the NRC staff."

Re sponse

. The installation of the new fuel storage racks is currently in progress.

Movements of the new and existing racks are conducted in accordance with approved procedures. These procedures are available for your review at the

- Brunswick site.

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-TER Page 10, Section 2.1.4, It em C

" provisions should be made to monitor crane operator conduct in accordance

.with~ ANSI B30.2-1976." '

Re sponse As1previously = stated in the November 16, 1982 submittal, crane operators are

trained in accordance with the requirements of ANSI B30.2-1976.

A Crane operators are required to receive classroem instruction and gain

practical operating experience under the direction of other qualified

. operators for each crane on which.they are to become qualified. In-addition to a - physical examination by a medical ' doctor, each operator trainee must pass a written examination. . Crane operators are required to requalify annually.

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-The crane operator training program plays an important part in assuring safe handling of the loads at BSEP and, therefore, is carefully administered by the maintenance supervisor or~his designee.

Carolina Power.& Light Company believes that the qualification'and requalification programs at Brunswick provide adequate monitoring of operator conduct. In addition, it is the responsibility of the crane operator's and signalman's immediate supervisor to ensure that he conducts himself in an appropriate manner in accordance with applicable standards and procedures.

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TER Page 15, Section 2.1.5, Item C.1

" Demonstrate that programs exist -for lif ting device acceptance testing, maintenance, and. continued compliance'for the spent fuel cask yoke and the shielded personnel lif ting apparatus."

Response

The acceptance testing and maintenance program for the spent fuel cask is in compliance:with Section 5 of ANSI N14.6-1978; however, exception is taken to

~t he visual-inspection f requency of Section 5.3.7 due to infrequent usage. The

-spent fuel cask. yoke is inspected by maintenance personnel prior to use.

The acceptance testing'and maintenance program for the shielded personnel lif ting apparatus is in compliance with Section 5 of ANSI N14.6-1978 with the exception of the deficiency in the requirements for the load testing, which states that a'600 lbs. load be raised one foot off the floor and lowered again in a controlled manner. In order to achieve compliance with ANSI N14.6-1978, Section 5, the weight of the test load will be increased and the time the test load is suspended will be specified. Exception is also taken to the inspection frequency of Section 5.3.7 due to infrequent usage. The shielded personnel lif ting apparatus is inspected by maintenance personnel prior to use.

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. i TER Page '15, Se ction 2.1.5, Item C.2

" Evaluate the head strongback, dryer separator sling, stud tensioner frame, and invessel service platform strongback~1n accordance with criteria identified in the evaluation of ANSI N14.6-1978 or demonstrate that a failure analysis-indicates that these devices have a load-handling reliability equivalent to that provided by compliance with ANSI N14.6."

5 Response Evaluation of the Head Strongback, Dryer Separator Sling, Stud Tensioner Frame and the.Invessel Service Platform Strongback was provided in Revision 1, Section 2.1(3)d of our Part I report and in our Part 11 response to 2.2.(1),

(2), and (3). Table 3-2 (included with our Part II response) supports CP&L's conclusion that the 'above lif ting devices have sufficient design safety

-factors to meet the requirements of ANSI-N14.6 and provide a load handling

. reliability ' equivalent to that provided in ANSI N14.6.

However,-the acceptance testing and maintenance program presently in effect at BSEP for these special lif ting devices does not comply with ANSI d14.6-1978.

.In order to achieve compliance with Section 5 of ANSI N14.6-1978, a program will tus developed for the above equipment to include the requirements of Section 5.3.1, 5.3.2, 5.3.3, 5.3.4, and 5.3.5. The requirement of Section 5.3.6-(visual' inspection prior to use) is satisfied at BSEP.

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TER Page 16, Se ction 2.1.6, Item C

. 1. base. sling' selection upon the sum' of the static and maximum dynamic loads

- 2.: mark slings with the " static load".which produces the maximum static and

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maximum dynamic loads .

3.- clearly mark slings restricted in use to only_ certain cranes.

. Response

1. The safe working load shall be reduced by 15% to account for maximum dynamic loading.

2. Slings shall be marked with the reduced value identified in 1 above to show the maximum safe working load for that sling.

3.' Presently, there are no restrictions on sling to crane connection.

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RESPONSE TO T.E.R.

T.E.R. Page 20, Item - 2.2.3 - "Special Revi'ew f or Heavy Loads Handled Over Core r

[ Interim Protection Measure 6, NUREG-0612, Section 5.3(6)]

-(6)1n addition to the above, . special attention should be given to

- . procedures, equipment, and personnel for the handling of heavy loads over

'the core, such as vessel internals or vessel inspection tools. This special review should include the.following f or these loads:

(1) review of procedures for installation of rigging of lifting devices and movement of the load to assure that sufficient detail is provided and that r _ _ ' instructions are clear and' concise; (2) visual inspections of load bearing components.of cranes, slings, and special lif ting devices to identify _

. flaws.or deficiencies that could lead to failure of the component; (3) appropriate repair and replacement of defective components; and (4) verify

. - thatf erane operators have been properly trained and are familiar with -

~ < specific procedures used in handling these loads, e.g. hand signals,

< conduct of operaticas, and content of procedures."

Re sponse:

' " Interim Actions. f or Control of. Heavy Loads" as identified in Enclosure 2 of the NRC Request for Information dated December 22, 1980 were implemented by CP&L.at the Brunswick Steam Electric Plant in May of 1981.

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-:An " Interim Action" report.was prepared in accordance with Enclosure 2 of the NRC pequest;for:information. The report identifies- the actions taken to determine.the extent of compliance to NUREG-0612 and provides

. recommended changes to procedures and-drawings;necessary to implement the requirements:of-Enclosure 2.--Item 5 of_ Enclosure 2 corresponds to Interim y Protection Measure -(6) _ of NUREG-0612.

A review of BSEP procedures was performed and checklists used to document '

the results.- Minor revisions were made to plant procedures for

inclusion of and/or _ reference to load paths, inspection of lif ting devices, use of trained-and qualified operators, repair and replacement of defective components with approved replacement parts and procedures.

Carolina Power & Light Company's BSEP procedures conform to the requirements' of. NUREG-0612 and Standards' referenced therein.

The " Interim Action"' report in on file and available for review in CP&L's Nuclear. Plant -Engineering Department. The report responds to all of the questions included in Enclosure 2 of the December 22,-1980 request for

-information.

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