ML18139C347

Control of Heavy Loads (C-10),Surry Power Station Units 1 & 2, Draft Technical Evaluation Rept

ML18139C347
Person / Time
Site:	Surry
Issue date:	01/14/1983
From:	SARGENT I H, VOSBURY F W FRANKLIN INSTITUTE
To:	NRC
Shared Package
ML18139C346	List: ML18139C347
References
CON-NRC-03-81-130, CON-NRC-3-81-130, REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR TAC-08084, TAC-08085, TAC-8084, TAC-8085, TER-C5506-395-3, TER-C5506-395-396-DR, NUDOCS 8306030446
Download: ML18139C347 (40)

Text

t i (~ R' ---.

• LJ,A~iJ -lcHNICAL EVALUATION RloRT ~~'.SL()SUR[

1 . .... CONTROL OF. HEAVY LOADS . ~1 , VIRGINIA .ELECTRIC AND POHER COMPANY (C-10) SURRY POWER STATION UNITS 1 AND 2 NRC DOCKET NO. 50-280, 50-281 NRC TAC NO. 08084, 08085 NRC CONTRACT NO. NRC-03-81-130 Prepared by Franklin Research Center 20th and Race Streets Philadelphia, PA 19103 Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 FAQ PROJECT C5506 FRC ASSIGNMENT 13 FRCTASKS 395, 396 Author: F. W. Vos bury FRC Group Leader: I. H. Sargent Lead NRC Engineer:

F. Clemenson january 14, 1983 This report was prepared as an-account of work sponsored bian agency of the United States Government.

Neither the United States Gover:nment nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use. of any information, ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights. --'-~------cc::-=-::--:-----\

r----9306030446 830516 : : ~DR ADOCK 05000~!2 ~nklin Research Cent~~ A Division of The F.ranklin Institute The Benjamin Fn1nklin ?ark .. ay, Phi~ .. Pa. 19103 (215) 448-1000 e CONTENTS Section Title l INTRODO:TION.

• 1.1 Purpose of Review 1.2 Generic Background 1.3 Plant-Specific Background 2 EVALUATION 2.1 General Guidelines 2.2 In:terim Protection Measures.

3 CON:LUSION 3.1 General Provisions for Load 3.2 Interim Protection Measures.

REFERENCES iii __ _ f="rar.1'-J:r.

Research Cen:er .'-. :,:-v:s:o:"'

c~ :he F re..,K.!::, !rui::-..i!e Handling e TE.F.-CS506-395/396 l 1 l 2 4 4 17 20 20 21 22 .,,..

' . ( ( e **. TER-C5506-3~5/396 FOREWORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Divisio~ of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions. The techr:ical evaluation was conducted in accordance with criteria established by Y~. F.. *w. Vosbury and Mz::. I. H. Sargent contributed to the technical prepa=a~ion of ~~is report through a subcontract with WESTEC Services, Inc. V ___ . Frankiin Research Center ,A,, :.:V?~10:i c,{ 7°.:":e F~~;.;. ... !r.!:::utt e TER-C5506-395/396

1. INTRODOCTION 1.1 PURPOSE OF REVIEW This technical evaluation report docume~ts an independent

~eview o; general load-handling policy and procedures at Virginia Electric and Power Company's (VEPCO) Surry Power Station Units land 2. This evaluation was performed with the following objectives:

o to assess conformance to the general load handling guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants" [l], Section 5.1.l o to assess conformance to the interim protecti~n measures of NUREG-0612, Section 5.3. 1.2 GENERIC BACKGROUND Generic Technical Activity Task A-36 was established by the Nuclear Regulatory Conunission (NRC) staff to systematically examine staff licensing criteria and the adequacy of measures in effect at operating nuclear power plants to ensure t1e safe handling of heavy loads and to recom.~end necessary changes in these measures.

This activity was initiated by a letter issued by t~e NRC staff on ~..ay 17, 1978 [2] to all power reactor licensees, requesting i:1.for~ation concern~ng t~e control of heavy loads nea= spent fuel. The results of Task A-36 were reported in NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants." The staff's conclusion from this evaluation was t1at existing*

measures to* control the handling of heavy* loads at operating plants, although*

providing protection from certain potential problems, do no.t adequately cover the major causes of .load handling accidents and should be upgraded.

In order to upgrade measures for the control of heavy loads, the staff developed a series of guidelines designed to achieve a two-part ob°jective using an accepted approach or protection philosophy.

The first* portion of the objective, achieved through a set of general guidelines identified in NUREG-0612, Section 5.1.l, is to ensure that all load handling systems at .. .. _ Frcnl*din Research Cent'=r !-. VcY".$:c:, o~ The Fr!nl(.;;:, ln~!.m.ote

, e ** .. TER-CSS06-3S5/396

~clear powe: plants are designed and operated such that t.'leir probability of failure is uniformly s~ll and appropriate for the critical tasks in which t.~ey are employed.

The second portion of the staff's objective, achieved through guidelines identified in NUREG-0612, Sections 5.1.2 thr~ugh 5.1~5, is to ensure that, for load handling systems in areas where their fail~re might result in significant consequences, either (1) features are provided, in addition to those required for all load handling systems, to ensure that the potential for a load drop is extremely small (e.g., a single-failure-proof crane), or (2) conservative evaluations of load handling accidents indicate that the potential consequences of any load drop are acceptably small. Acceptability of accident consequences is quantif1ed in NUREG-0612 into four acciderit analysis evaluation criteria.

A defense-in-depth approach was used to develop t.~e staff-guidelines in order to ensure that all load handling systems are designed and operated so *that their probabilities of failu~e are appropriately small. The intent of the guidelines is to ensure that licensees of all operating nuclear power plants perform t.~e following:

o define safe load travel paths, through procedures and operator training, so t.,at, to the extent practical, heavy loads are not carried over or near irradiated fuel or safe shutdown equipment o provide su:ficient operator training, handling system design, load handling i::st.ruct.ions, and equipment inspection to ensure reliable operatic~

of the handling system. . Staff guidelines resulting from the foregoing are tabulated in Section 5 of NUREG-0612.

Section 6 of NUREG-0612 recommended that a program be initiated to ensure that these guidelines are implemented at operating plants. 1.3 PLANT-SPECIFIC BACKGROUND on December 22, 1980, the NBC issued a letter (3] to VEPCO, the Licensee for Surry Power Station, requesting that the.Licensee review pr~visions for h'andling and control of heavy loads at Surry Units l and 2, evaluate these provi~ions with respect to the guidelines of NtJREG-0612, and provide certain . additional infor~ation to be used for an independent determination of -~-J Frant'Jin Researc:.

Ce:-:,er *"'* Divl.s;on o!lr,~ Fre~.-: 1ru:;:-..:!t

• TER-C5506-395/396 confo=~a~ce to these guidelines.

V"".i:.PCO res~nded to ~~is request on November 16, 1981 [~]°, December 22, 1981 [SJ, and March 22, 1982 [6]. A draft technical evaluation report based upon ~~ese submittals was prepared and informally transmitted to the Licensee for review and comm~nt. On August 12, 1982, a telephone conference call was conducted with tives of the NRC, FRC, and VEPCO to discuss unresolved issues. As a result of this cal.l, additional information was forwarded by VEPCO on September 1, 1982 [7] and O::tober 18, 1982 [SJ and is incorporated into this technical evaluation. ____ rranl-'Jin Research Cer..:er A OMs..::n of The Frarik.!1:i r"ls::"..:tr:

. ' .. e e ... TE.R-C5506-3~5/396

2. EVALUATION Af.."D REC0!-1ME:l\"DATIONS This section presents a point-by-point evaluation of load handling sions at Surry Power Station Units land 2 with respect to NRC staff guidelines provided in NUREG-0612.

Separate subsections are providea for both the general guidelines of NUREG-0612, Section 5.1.l and the interim measures of NUREG-0612, Section 5.3. In each *case, the guideline or interim measure is presented, Licensee-provided information is summarized and evaluated, and a conclusion as to the extent of compliance, including recommended additional action where appropriate, is presented.

These conclusions are summarized in Table 2.1. 2. l GENERAL GUIDELINE.S The NRC has established seven general guidelines which must be met in order to provide the defense-in-depth approach for the handling of heavy loads. These

• guidelines consist of the following criteria from Section 5 .l. l of NUREG-0612:

0 Guideline l -Safe Load Paths 0 Guideline 2 -Load Handling Procedures 0 Guideline 3 -Crane Operator Training 0 Guideline 4 -Special Lifting Devices 0 Guideline 5 Lifting Devices {Not Specially Designed)

C Guideline 6 -C=anes {Inspection, Testing, and 1"..a in tenance) 0 Guideline 7 -Crane Design. These seven guidelines should be satisfied by all overhead handling systems and programs in order to handle heavy loads in the vicinity of the r~actor vessel, near spent fuel in the spent fuel pool, or in other areas where a load drop may damage safe shutdown systems. 2.1.l O'~erhead Heavv Load Handling Systems a. Summary of Licensee Statements and Conclusions The Licensee's review of load handling systems a~-Surry station indicates that the following load handling systems are subject to compliance with NUREG-0 612: ____ Franklin Research Center A D:\is,on cf The Fran)(.:;:, lns:.::i.::t I l/1 I Tnble 2.1. f.11,ry l'Ower lltaUon -IIURF.0-0612 Compllanr:o Hntrlx lie avy l.onds I. Renclor Containment rol ar Crantt IIP.lqht or Cnp,,clty (Lonn) 125/15 a. RV llead and 122.5 1.Utlng O,.v Ice b. Upper Internal." "" r.lftlng Rig c. ISi 'l\)ol d. ncr tbtor/ Sling e. RP.actor c .. vlty Inner Seal f. CROH Hlenllo 6hlcld g. Blud Cl!lrrlerft ll"UHI h. Op*H at Ing Floor R~movable rlug 1111, I. Octagonal Floor !'lug I Elev. 10'-4"1 52 Io n 12.2 J6.5 J.6 l] )1.5 Guideline l Snfe Load r11ths C C C C C C C C C Gu ldcllne 2 Procedures C C C C C C C C C Gul,1~1 lnP. Crnne Oper11t.or Tr n In l.n._9 __ R C

• r.lccMP.C action compllen with NUREG-0612 Guideline.

mt np'pllcable.

R

• 1,lcensee h,,n proponcd revlolons/modlflcatlonn de~lqnc,1 lo comply IC* l,lccnnee action In not ln compllance with lnlREG-0612 Gul,lr.llne.

Gu Ide! lne 4 Guideline 5 Gu ldel lne 6 6peclnl 1,ICtlng Cr1111e -'1'1!nt __ D<,~lce_n_.

___ !lllng_n__

""!!....!.~~-Ion IIC IIC C C C C C C C with llllRP.G-Ofil 2 Gu l,te II ne. C Guideline 7 Crnnc ll<!nlgn C Interim Heaoure l Technical 6peclfJcatlonn Inter Im He.tnure 6 fip~cl.,I Mtcn.!:.lon C C C C C C 1'3 lr.1 () l/1 l/1 0 0\ I w <D u, '-... lAJ <D <Tl e *.e

• ~ ' . ii. T~hlr. 2. l (Cont.) s Ill !!' :J 0 .... -:, !.:: !l.::J Weight Inter Im lnl.,.rlm

t

;u "/l) or Gul,lellne l Gu ldellne 2 (:11 l,l,*l lnr. J Gu l,lr,llne 4 Guld,,l lnr, 5 Gu l,lellnr, 6 Guldollno 7 Heaaure 1 M<?.:tnure 6 "'1 UI Capacity Safe J.oad Cr11n" Opcrnlor Spccl n 1 r.lftlng Crane -Tent Technical Speclnl fl) :, Ill neavy 1.01Hls _1!£_'!!!1_

Paths rroccdnreo . Tr,, lnln!) __ __ ll!:!~ lce_n __ ~.!!.-!!"d ln_!!pect!on Cr nrie Dee lgn Specif lea tlonn lltten!.!..~ ., -* (") =-:r j. rolllr Crane 2.4 C C :, tn llotlom Dlock C lb ;; ::, nnd !look '° ., k. Containment 2].l C C C Reclrc. Spcay Cooler l. Regr.nt?ra-2.4 C C C tlvr, !lent Exchanger I m. ruin ExchBn')n

°' 12.D C C C I n. Rim rump 2,4 C C C Hotor o. Rf!clrc. l.J C C C Spray Pump Hotor 2. IC l'.nnulua 5 R C C Honor all II, Hlocelln-5 C C C neoUB Loads ], IC Jlh Crane& 8 ll C C *.e t-3 t<J a. Hlecelln-8 C C C !f neoue IDnde () l.11 l.11 4. llew Fu el Crane 5 ll C C 0 °' ... I w a. I"'!' FUP.l ),] C C IIC C *.o u, Container

'-(Fiil l) l.J \D .. 0\

I -.I I b, Rcmovnble Slnhn 5. Hotor nc Ive Phtlocm and llolet a. fuel rool Ga ten 6, fuel llull,llng Trolley o. Spent n,el Shipping cank Weight or Capacity (tonnL 1.8 1.0 125/10 12,5 (HnxJ b. Dot tom Block nnd nook c. Spent Ree In J,7 Shipping Container nnd cank d. lrra,llnted ll,l Specimen llhlpplng C'Ank 7, Oecon null ln<J 5 Crane a. Hince I la-5 neouo rnndn ',, e. 91x-TOn 6 tlr>norall System Guideline l

• Guideline 2 Safe I.oacl Pa tho C C C C C C C Pcocednreo C C C C C C C r.ul,Jnllnc J Cr,,111? Operator Trnln!.!!9__

T,,hlc 2,1 (Cont.I c;ul,lc,llnc 4 llp~dn I Lifting IIP.v lcco Gul,lcllne 5 C Guideline, 6 Crnne -1"r.nt an,! l!!_!!E~~l 1011 Gul<'IP.llne 7 Crane Design Interim Heanure l Technlcnl 6peclflcatlonn lnt~r 1111 Hr.anurr 6 fip~ctnl l\ltc,nl!!'~

---

~------------------

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R C C C C ----------------------*-

...... ----R C C lk: C C C ,~ C R C C C R C C --------~---~----------~--------~---------------~-------~

e e t--3 t-..1 lJl Ul 0 m I w \D lJl '-w \D m I CD I Weight or Cnp~clly ~!!!L!..~n<IB

-~'!'.!!L

a. Component 2.1 cooling Water rump b. Component

).2 Cooling Water Pump Hotor c. C11arglng l.l rump d. Charging 2.1 rump Hotor e, llemovnhle LS Shh (llul 9. Ten-Ton 10 nlnor111 l Syntem a. Fe movable 0.5 Blab '"""' IO. Fl lter cartridge 2 llcmoval Honor ail a. Hlecelln-2 nnouo l.ondn ll. Unit II 2 Swltchge11r

!loom llonorall

... Motor-2 Gtnerntor Set Hotor Guideline l Gu ldr.l lne 2 S11[e Load r11tha ~£dnr_!:~_

C C C C C C C C C C. C C C C C C Tnhll? 2.1 (Cont.) GuldP.llnP.

l Gu ldnl,lnn 4 Guideline 5 Gul,lellne 6 Crnnr-Opcr11tor llpcc la l l,lftlng Crane -Tent ___ Tc 11_111 lng ----_______ Dev lcen -----'!!!!!9_0

-,!!_nd In npe<":!_Lf?.!l

' C C C C C ll C C R C C R *c C Inter !11 Guideline 7 Heaaure 1 Technical frane Dea lqn Specif lea t lonn C Interim Hcanure 6 r.pcchl l'tl~nt Ion 1--'l !-rJ 1' () U1 U1 0 m *;. I w lo U1 ' w lO 0\ -e

-TER-CSSOG-395/396 o Reactor containment polar cranes o Reactor containment annulus monorails o Reactor containment jib cranes o New fuel crane (fuel building) o ~tor-driven platform (fuel building) o Fuel building trolley o Decontamination building crane o 6-TOn monorail system*(auxiliary building) o 10-Ton monorail system (auxiliary building) o Fi.lter cartridge removal monorails (auxiliary building) o Unit l switchgear room 2_-ton monorail (service building). ~he Licensee has also identified several other load handling systems ~~at have been excluded from satisfying the criteria of NUREG-0612 due-to physical separation from safe shutdown equipment or irradiated fuel, or insufficient load handling capacity:

o Re actor cav*i ty manipulator er anes o Neutron detector carriages o Drumming room monorails o Eoist area monorail (auxiliary bui~ding) o !*1a.c.~ine shop jib crane o !>2c.11ine shop ::ionorail syste::n o T~rbine building cranes o Condensate polishing building monorail system {elevation 64 feet) o Condensate polishing

• building monorail system (elev-ation 42 feet) o CW intak*e structures trash rakes. b. Evaluation and*Conclusion The Licensee's conclusions regarding the applicability of NUREG-0612 are consistent with general guidelines in Section s.1.1. 2.1.2 Safe Load Paths [Guideline l, NUREG-0612, Section 5.1.1(1)] "Safe load paths should be defined for the movement of heavy loads to minimize potential for _heavy loads, if dropped, to impact irradiated ____ Franklin Research Center >. D1 ... -:5,o:, cf The F~nk.!.~ Inst::.::,

--* ... TER-CSS06-395/396 fuel in the reactor vessel ana in the spent fuel pool, or to impact safe shutdown equipment.

The "path should follow, to the extent practical,

• structural floor members, beams, etc., such that if the load is dropped, the structure is more likely to withstand the impact. These load paths should be defi~ed in procedures, shown on equipment layout drawings, and clearly marked on the floor in the area where the load is to be handled. Deviations from defined load paths should require written alternative procedures approved by the plant safety review committee.*

a. Summary of* Licensee Statements and Conclusions The Licensee has provided safe load paths for the movement of heavy loads at Surry Power Station which follow,. to the extent pra~tical, structural floor members, beams, etc., such that if a load is dropped, the .structure is most likely to withstand the impact. These load paths, in the form of. sketches, a.:.& being incorporated into lifting (operating or mechanical maintenance) procedures and will be incorporated in existing station drawings.

Safe load paths will be clearly marked on the floor in the area where the load is to be handled. Safe load path sketch~s will not be generated for movement of the fuel transfer canal _gates in the fuel pool. Updated fuel pool maps will be used instead. These maps are more accurate than one safe load path sketch. The review requirements for deviations from defined load paths are delineated in VE?CO's Nuclear Power Station Quality Assurance Manual and in Surry Power Station Technical Specifications.

The procedure for deviations to procedures requires revfew by station supervisory personnel with a followup review by the Station Nuclear Safety and Operating Committee.

b. Evaluation and Conclusion A review of the Licensee's safe load path response and drawings indicates that Surry Power Station satisfies the criteria of Section 5.1.1 of NUREG-0612.

Therefore,.

Surry Power Station complies with Guideline 1 of NUREG-0612.

2.1.3 Load Bandlina Procedures

[Guideline 2, NUREG-0612, Section 5.1.1(2)] "Procedures should be developed to cover load handling_

operations fo_-c heavy loads that are or could be handled over or in proximity to irradiated fuel or safe shutdown equipment.

At~ minimum, procedures * ** Franklin Research Center A Dhr.s1on of The: FrenK.:::"'i lnsg:J.!te

-1

--TE.R-C5506-395/396 . should cover handling of those loads listed in Table 3-1 of NUREG-0612.

These procedures should include: identification of required equipment; inspections and acceptance criteria required before movement of load; t..~e steps and proper sequence to be followed in handling the load; defining t..~e safe path; and other special precautions." a. Summary of Licensee Statements and Conclusions The Licensee has stated that Surry* Power Station l.ifting procedures

{mechanical maintenance and operating procedure) are being revised or have been revised to include the general guidance and evaluation requirements of Section 5.1.1(2) of NUREG-0612.

A generic procedure shall be used to control the movement of heavy loads over spent fuel, fuel in the core, or equipment that may be required to achieve safe shutdown and continue decay heat removalr as required by NUREG-0612 and not covered by existing station procedures.

b. Evaluation and Conclusion Procedural control of the movement of heavy loads at Surry Power Station is consistent with Section 5.1.1(2) of NUREG-0612 based on the Licensee's certification that lifting procedures are being, revised or have been revised to include the general guidance and evaluation requirements in NUREG-0612.

Therefore, Surry Power Station complies with Guideline 2 of NUREG-0612.

• 2.1.4 Crane Operator Training [Guideline 3, NUREG-0512, Section 5.1.1(3)) "Crane operators should be trained, qualified, and conduct themselves in accordance with Chapter.2-3 of ANSI B30.2-l976, 'Cr~erhead and Gantry Cranes' [ 9] * " a. Summary of Licensee Statements and Conclusions The Licensee has stated that Surry Power Station crane operators are trained in accordance with ANSI B30.2-1976, which complies with the ments of NUREG-0612.

Crane operators have completed a course in crane and -rigging* operations which provides certification that t..~e crane operators have been trained, qualified, and instructed in proper conduct in accordance with ANSI B30.2-1976.

This course was conducted by an independent contractor.

~..:..... . ____., . *** .: Franklin Research Center A ::>1Vts1on cf The Frenl'..in, ir:.!.tiu.ite

--* .... TER-C5506-3~5/396 By the nex; refueling outage at Surry Power Station, procedures will be developed to provide for future crane operator training that will satisfy the requirements of ANSI B30.2-1976, Clapter 2-3. b. Evaluation and Conclusion Crane operator training, qualification, and conduct are consistent witb the guidance in Section 5.1.1(3) of NUREG-0612, and Surry Power Station complies with Guideline 3 of NUREG-0612.

2.1.5 Special Lifting Devices [Guideline 4, NUREG-0612, Section 5.1.1(4)] "Special lifting devices should satis:y the guidelines of ANSI Nl4.6-1978, 'Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds {4500 kg) or More for Nuclear Materials'

[10]. This standard should apply to all *special lifting devices which carry heavy loads in areas as defined above. For operating plants, certain inspections and load tests may be.-accepted in lieu of certain material requirements in the standard.

In addition, the stress design factor state~ in Section 3.2-.1.l of ANSI Nl4.6 should be based on the combined maximum static and dynamic loads that could be imparted on the handling device based on characteristics of the crane whic.~ will be used. This is st=ess design factor on only the weight (static load) of the load and of the intervening components of the special handling device [NUREG-0612, Guideline 5 .1.1 (4)].

• a. S;..:::..~a:-v a£ Lice!"".see S~a.ter:-:e=-:.ts anC: Con::lusions The Licensee has stated _that the reactor vessel head lifting device, internals lifting rig, and the reactor coolant pump motor sling were designed and fabricated prior to the issuance of ANSI Nl4.6-1978 or ANSI B30.9-1971.

These devices were designed and built to current industry standards using good engineering practices.

The Licensee has contacted the lifting devices supplier, Westinghouse, and has requested verification that these lifting devices conform to the above listed standards.

This information is expected to be available by t.~e end of Marc.'l 1983. The reactor vessel head lifting device and the internals lifting rig are inspected prior to each refueling and at each containment maintenance period if they are needed and have been idle for a period of more than six months or

• Franklin Research Ceriter A DM~on o! 7he: Fni:"11<!;:-.

lns:::-..i:c l

e e TER-C5506-395/396 if over a year has passed since the last inspection.

The reactor coolant pum? motor sling is inspected prior to. each refueling and at each containment maintenance period if it is to be used and more than one month has passed since the last inspection.

Special handling devices used to lift the new fuel containers, irradiated specimens, and spent fuel shipping casks are supplied by the particular cask supplie~.

The Licensee will verify the conformance of these lifting-devices to ANSI Nl4.6-l978 and ANSI B30.8-l97l with equipment suppliers.

b. E:v al ua tion Insufficient information has been provided by the Licensee to evaluate compliance wi~~ Guideline 4 of NUREG-0612 although a com.~itment has been made to obtain verification from Westinghouse that these lifting devices conform to* ANSI Nl4. 6-197 8. In evaluating .the information obtained from Westinghouse, the Licensee -should address the imposition of static and dynamic loads when assessing design stresses.

The intent of Guideline 4, in addition to determining that special lifting devices have been designed and fabricated in a ~~nner consistent wi~~ high reliability, is also to ensure that appropriate steps are taken to ensure ~-i.a t .these devices are inspected, tested, and maintained t'o ensure continued reliability.

Guidance for a program to support this goal is contained in Section 5 of ANSI Nl4.6. c. Conclusion and Recommendations Surry Power Statio*n does not satisfy the requirements of Guideline 4 of NUREG-0612.

'lhe Licensee should implement an acceptance and continuing compliance testing program in accordance with Section 5 of ANSI Nl4.6-l978 prior to the next use of these devices. Further, the Licensee.

should provid~ a design comparison of the special lifting 0 device designs relative to the criteria in ANSI Nl4.6-1978. *: --

Fran;,Jin Research Center A Crv!.s,o:, of~, Frenk!in lr"::!t:Utt e* .... TER-CSSO 6-39.5/396

2. l. 6 Lifting Devices (Not Soeciallv Desianed)

[Guideline 5, NuREG-0 612, Section 5.1.1(5)) "Lifting devices that are not specially designed should be installed and used in accordance with the guidelines of ANSI B30.9-1971, 'Slings' [11). However, in selecting the proper _sling, the load us~d shoul~ be the sum of the static and maximum dynamic load. 'll'le*rating identified on the s'ling should be in terms of the 'static load' that produces the maximum static and dynamic load. Where this restricts slings to use on only certain cranes, the slings should be clearly marked as to the cranes with which they may be used.* a. Sum.~arv of Licensee Statements and Conclusions The Licensee has stated that lifting devices which are not specially designed (slings) are marked,. maintained, stored, and inspected in accordance~

with ANSI B30.9-1971.

Lifting procedures are reviewed prior to approval and implementation for proper selection of size, length, capacity, and rigging configuration of slings in order to meet all requirements of ANSI B3Q..9-1971.

With regard to sling selection, the Licensee determined that the maximum dynamic load experienced by a sling would be not more than 10% of the rated load and t~erefore could be ignored in the selection of slings since the slings were designed with a safety factor of 5. In addition, the Licensee stated t~at none of the slings in use were restricted to certain cranes. b. Evaluation and Conclusion Surry Units 1 and 2 compiy with Guideline

5. Surry Power Station satisfies the requirements of this guideline on* the basis that slings are inspected and used in accordance with ANSI B30.9-1971.

In addition, since the maximum dynamic load experienced by these slings is less than 10%, it is a reasonably small percentage of the static load and therefore may be disregarded.

2.1.7 Cranes (Insoection, Testing, and Maintenance)

[Guideline 6, NUREG-0612, Section 5.1.1(6))

~'Ibe crane should be inspected, tested and maintained in accordance with Chapter 2-2 of ANSI B30.2-1976, 1 0"verhead and Gantry Cranes,' with exception that tests and inspections should be perfor~ed prior to use --~~ Franklin Research Center A :):vi .. on of Tne Frank!,~ br.a::.::e e e T.ER-CSS06-395/396 when it is not practical to meet the frequencies of ANSI B30.2 for perioaic inspection and test, or where frequency of crane use is less t.'lan t.'le specified inspection and test frequency (e.g., the polar* crane inside a PWR containment may only be used every 12 to 18 months during ref:.:ieling operations and is generally not accessible during power tion. ANSI B30.2, however, calls for certain inspections to be pe~formed daily or monthly. For such cranes having limited usage, the inspections, tests, and maintenance should be performed prior to their use).* a. Su:minary of Licensee Statements and Conclusions The Licensee has stated that Surry Power Station cranes, both inside and outside of the containment, are inspected, tested, and maintained in accordance with station maintenance procedures MMP-P-CR-015 or MMP-P-CR-017.

These procedures were revised in 1977 to incorporate ANSI B30.2-1976.

In addition to the above stated station maintenance procedures, the fuel

• handling system is visually inspected and performance tested in accordance with station procedure PT 20.1 prior to refueling.

• Prior to initial use, all new, reinstalled, altered, extensively repaired, or modified cranes shall be operationally tested and rated load tested in accordance with ANSI B30 .2-197 6. Crane test procedures shall be written, as required, to ensure that crane~ are in compliance with ANSI B30.2-l9i6.

b. Evaluation The Surry Power Station satisfies the requirements of this guideline on the basis t.~at existing procedures have been revised to comply with ANSI B3 O. 2-19 76. c. Conclusion Surry Power Station complies with Guideline

6. 2.1.8 Crane Desian [Guideline 7, NUREG-0612, Section 5.1.1(7)] "The crane should be designed to meet the applicable criteria and guidelines of C.~apter 2-1 of ANSI B30.2-l976, 'overhead and Gantry Cranes,' and of CMAA-70, 'Specifications for Electri~ overhead Travelling .**. Franklin Research Center* .A. C:vis..cn of The F"ren~r: lr\S:::~te e* ... TER-CS506-395/396 Cranes' [12). An altern~tive to a specification in ANSI B30.2 or CMAA-70 may be accepted in lieu of specific compliance if the intent of the specification.is satisfied." a. Summary of Licensee Statements and Conclusions The Licensee has stated that CMAA-70 and ANSI B30.2-1976 apply.to the reactor containment polar cranes, fuel building trolley, and the new fuel crane. These cranes were designed and fabricated prior to the issuance of the above *referenced stanc';ards r in accordance with Electric overhead Crane Specification

1. 61 [13]. The License~ has provided the results of a review of existing crane designs with the reconunendations c_ontained in CMAA-70 and Chapter 2-1 of ANSI B30.2-1976.

The reactor containment jib cranes were designed and fabricated in accordance with ANSI B30.l6-1973 and ANSI B30.ll-l973.

The reactor containment annulus monorails, 6-ton and 10-ton monorail systems, decontamination building crane, new fuel crane, and_motor-driven platform and hoists were designed in accordance with EOCI 61. These cranes and monorails meet the requirements of ANSI E30.ll and ANS! B30.16. b. :SValuation Tje Licensee 1 s analysis of the crane cesi~n =or the reactor containment polar cranes,* the fuel building*

trolley, and the new fuel crane indicates that *the design of these cranes is consistent with the guidance in Section S.l.1(7) of t-."UR..."t:'G-0612.

Since CMAA-70 applies to top running bridge and gantry type multiple girder electric overhead traveling cranes, verification of compliance to ANSI B30.ll [14] and ANSI B30.16 [15] for the remaining load handling systems meets the *intent of NUREG-0612 for crane design. Co Conclusion Surry Power Station complies with Guideline

7. .. ~~nkiin Reseuch Center A Dm!.10:, o! The Fre.ntc.:;:"'.

lns'::.'!\.:te:

---

,----------;------~

-, --------. ---------------* e TER-C5506-395/396 2.2 ::,TE?..:E

?ROTECTION MEASURES Tie t2~ has established six interim protection measures to be implemented at ope:ating nuclear power plants to provide reasonable assurance that no heavy loads will be handled over the spent fuel pool and that measures exist to reduce the potential for accidental load drops to impact on fuel in the core or spent fuel pool. Four of the six interim measures of the report consist *of Guideline 1, Safe Load Paths; Guideline 2, Load Handling Procedures; Guideline 3, Crane Operator Training; and Guideline 6, ~ranes (Inspectio~, Testing, and Maintenance).

The two remaining interim measures cover :allowing criteria:

1. Eeavy load tec.~nical specifications 2, Special review for heavy loads handled over the core. Licensee implementation and evaluation of these interim protection measures are contained in the succeeding paragraphs of this section. 2.2.l Tec.'mical Soecifications

[Interim Protection Measure 1, NURE:G-0612, Section 5.3(1)] "~icenses for all operating reactors not having a single-failure-proof o*:erhead crane in the fuel storage pool area should be revised to include a speci=ication comparable to Standard Technical Specification 3.9.7, '::ane T:avel -Spent FU el Storage Building, 1 for :?WR I s and Standard Technical Specification -3.9.6 .* 2, 'Crane Travel, 1 for BWR's, to prohibit . h~~dling of heavy loads over fuel in storage pool until tion of measures which satisfy guidelines of Section 5.1 [of N"..iRJ::.~-0 612 J

• a. Sun:nary of Licensee Statements and Conclusions The Licensee has stated that Surry Technical Specification 3.10 prohibits the movement of heavy loads exceedi-ng__ll0%-of the weight of a fuel assembly (not i~cluding fuel handling tools) over spent fuel. b. Evaluation N"~REG-0612 defines a heavy load as any load ~hose weight is greater than t~e cor::iined weight of a single spent fuel assembly and its, handling tool. ____ F~anklin Research Center A :):--r.s.*o~

cf Tne Frank.:m 1n.s.::ute 1

-.... TER-CS506-395/396 Consice=ing t.~e typical weight of spent fuel asserr~lies and handling tools, designa~ion of 110% of the weight of a fuel assembly as a heavy load is consistent wit.~ t.~e guidance in NUP.EG-0612.

c. Conclusion Surry Power Station complies with Interim Protection Measure l. 2.2.2 Administrative Controls [Interim Protection Measures 2, 3, 4, and 5, ~UREG-0612, Sections 5.3(2)-5.3(5)]

"?rocedural or administrative measures [including safe load paths, load handling procedures, crane operator training, and crane inspection]

• • • can be accomplished in a short time period and need not be delayed for cc~pletion of evaluations and modifications to satisfy t.~e guidelines of Section 5.1 [of NUREG-0612)

." a. Evaluation Th~ specific requirements for load handling administrative controls are contained in ~ru::EGG-0612, Section 5.1.l, Guidelines 1, 2, 3, and 6. The Licensee's compliance with these guidelines has been evaluated in Sections 2.-1.2, 2.1.3, 2.1.4, and 2.1.7, respectively, of this report~ Cc~=:~~ions and Reccr.~e~dations Conclusions and recormnenda tions concerning the Licensee's compliance with bese. administrative controls are contained in Sections 2.1.2, 2.1.3, 2.1.4, and 2.1.7 of this report. 2.2.3 Soecial Review for Heavy Loads Handled over the Core [Interim Protection Measure 6, NUREG-0612, Section 5.3(6)) --" *** special attention should be given to procedures, equipment, and personnel for the handling of heavy loads over the core,* such* as vessel i~te:~als or vessel inspection tools. This special review should include tbe following for these loads: (1) review of procedures for installation of rigging or lifting devices and movement of the load to assure that sufficient detail is provided and that instructions are clear and -* aoncise; (2) visual inspections of load bearing components of cranes, slings, and special lifting devices to identify flaws or deficiencies t:.at could lead to failure of the component; (3) appropriate repair and *

• __ * :=.ar:kJ:r.

~esearch Center ,.. :*~-:s:::, cf 7:-ie FrantiUn lns.:.tu:e i

a. * -TER-CSSOG-395/396 replacement of defective components; and (4) verify ~~at the crane operatbrs have been properly trained and are familiar with specific procedures used in handling these loads, e.g., hand signals, conduct of operation, and content of procedures." Summary of Licensee Statements and Conclusions For Surry Unit 2, the Licensee has stated that the oniy heavy loads carried over the reactor when the reactor is fueled are the reactor components.

Each heavy load is covered by its own unique procedure.

The crane load block does not have a lift procedure since it is an integral.

portion of the crane; however, it has been identified as a potential heavy load drop. To ensure that the c~ane load block is not dropped, the existing redundant limit switches will be performance-tested prior to use. In accordance with Surry Power Station preventative maintenance procedure MMP-P-CR-015, the containment cranes and the reactor head and internals lifting rigs are inspected prior to each refueling and at each containment .maintenance period if they are to be used and have been idle for a period of more than six mon~~s or if the last inspection has been over one year. The reactor coolant pump motor lifting rig and wire rope slings are inspected prior to each refueling and at each containment maintenance period if they are to be used and the last inspection has been over one month. This check ensures that each device will receive an inspection pr*ior to use. If any components are found to be defective, ~riey are-replaced, or repair.ed, and reinspected before use. The one-time*

inspection required will be performed prior to the next refueling in accordance with the above procedure

• . .. .. Surry c;:rane operators recently passed a two-week course on crane operations.

b. Evaluation and Conclusion Contingent upon completion of the one-time inspection to be performed prior to the next refueling, Surry Power Station will comply with Interim-**

Protection Measure 6. Franklin Research Center A :iMs1on of The Fran)(.!:n ins:~1e e ... TER-CSSO 6-3.95/39 6 3. C01'iCLUSI0N This su..."'TII!lary is provided to consolidate t,e results of the evaluation contained in Section 2 concerning individual NRC staff guidelines into an . -overall evaluation of heavy load handling at Surry Power *station Units land 2. Overall conclusions and recommended Licensee actions, where appropriate, are provided with respect to both general provisions for load handling (NUREG-0612, Section 5.l.l) and completion of the staff recommendations for

• interim protection (NUREG-0612, Section 5.3). 3.1 GENERAL PROVISIONS FOR LOAD HANDLING The NRC staff has established seven guidelines concerning provisions for handling heavy loads in the area of the reactor vessel, near stored spent fuel, or in ot~er areas where an accidental load drop could damage equipment re~uired for ~afe shutdown or decay heat removal. The intent of these guidelines is twofold. A -plant conforming to these guidelines will have developed and implemented, t~rough procecures and operator training, safe load t=avel paths such that, to the maximum extent practical, heavy loads are not car=iec over or near irradiated fuel or safe shutdown equip~ent.

A plant con:crming to these guidelines will also have provided sufficient operator ~raining, ha~d:ing syste~ design, load handling instructions, and equip~ent ins?ection to ensure. reliable operation of the* handling system. .'A.s detailed in Section 2, it has been found that load handling operations at Surry Station can be expected to be conducted in a highly reliable manner consistent with the staff's objectives as expressed in these guidelines.

A need for further Licensee action was identified in the following areas~ o VEPCO should develop a program consistent with Section 5 of ANSI Nl4.6-1978 to maintain the assurance of reliability of special lifting devices. o VEPCO should complete the assessmen~

of the design-of ~pecial lifting devices in comparison with sections of ANSI Nl4.6-1978 affecting device load handling reliability. (VEPCO has committed to conduct this evaluati~n) . ---20-~. -~ Fra:;~;;in Research Center A OM!.,*:.-.

cf 7'he: Fre!'\i<.!.n lru.:;!u:e e e TER-C5506-395/396 3.2 !~TERL~ ?RO'.!'E~TION MEASURES The N3C staff has established (NUREG-0612, Section 5.3) that certain measures should be initiated to provide reasonable assurance that handling of heavy loads will be performed in a safe manner until final implementation of the general guidelines of NUREG-0612, Section 5.1 is complete.

Specified measures include the implementation of a technical specification to prohibit the hand.ling of heavy loads over fuel in the storage pool; compliance-with Guidelines l, 2, 3, and 6 of NUREG-0612, Section 5.1.l; a review of load handling procedures and operator training; and a visual inspection program, including component repair or replacement as necessary of cranes, slings, and special lifting devices to eliminate deficiencies that could lead to component failure. Evaluation of information provided by the Licensee indicates that measures--which ensure compliance with the staff's measures for interim *protection have been properly implemented at the Surry Power Station. -* -. :=-ra:,klin Research Center A, ~s,on o~ Th! Fr~r:tr..!:r.

i:is::::ute ..

e e* **. TER-CSSOG-395/396

4. REFERENCES

1. NRC "Contr.ol of He_avy Loads at Nuclear Power Plants" July 1980 NUREG-0612

2. v. Stello, Jr. (NRC) Letter to all Licensees

Subject:

Request for Additional Information on Control of Heavy Loads Near Spent Fuel 17-May-78

3. D. G. Eisenhut (NRC) Letter. to all operating reactors

Subject:

Control of Heavy Loads 22-Dec-80

4. R. E. Leasburg (VEPCO) Letter ~o s. A. Varga (NRC)

Subject:

Control of Heavy Loads, Surry Power Station Unit 2 16-Nov-81

5. R.H. Leasburg (VEPCO) Letter to D. G. Eisenhut (NRC)

Subject:

Control of Heavy Loads 22-Dec-82

6. R. E. Leasburg (VEPCO) Letter to D. G. Eisenhut (NRC) Subj~ct: Cont=ol of Eeavy Loads 22-Mar-82

7. R.H. Leasburg (VEPCO) Letter to H. R. Denton (NRR)

Subject:

NUREG-0612

-Control of Heavy Loads September l, 1982 a. D. L. Stewart (VEPCO) Letter to H. R. Denton (NRC)

Subject:

NUREG-0612 Control of Heavy Loads October 18, 1982 9. American National Standards Institute "overhead and Gantry Cranes* ANSI B30.2-1976 ,:1:--22-*

Franklin Research Center .A. D",:,,o:, o/ The Fn,nk;;n lnsctute

• e e TE.~-C5506-395/396

10. American National Standards Institute "Standard for Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More for Nuclear Materials" ANSI Nl4.6-l978

11. American National Standards Institute "Slings" ANSI B30.9-l97l

12. Crane Manufacturers Association of America "Specifications for Electric Overhead Travelling Cranes* Pittsburgh, PA CM..i:..n.-70

13. Electric Overhead Crane Institute, 1961 "Specification for Electric Overhead Traveling Cranes" EOCI 61 14. American National Standards Institute "Honor ails* and Under hung Cranes" ANSI B3 0 .11 15. American National Standards Institute "O'verhead Hoists (Underhung)" ANSI B30.16 ~J F,anklin Research Center A CTw'l!1on of The Frenfl'.!in 11".s:.tute l

... TE..~-C5506-3~5/396 ADDITIONAL INFORMATION REQUIRED PROM SURRY NO::::LE;..R STATION a. RECOMMENDATION/OPEN ITEM Virginia Electric Power Company (VEPCO) should assess special lifting devices at Surry Onits 1 and 2 to determine compliance with t..~e requirements of ~SI Nl4.6-1978.

Such an assessment should include verification of design adequacy as well as implementation of programs that ensure continuing.

compliance with the criteria of ANSI Nl4.6-1978, Section 5. b. EVALUATION CRITERIA The general guidelines of NUREG-0612 specify that special lifting devices used to cru:ry heavy loads should satisfy the requirements of ANSI Nl4.6-1978.

In order to determine if the devices are in compliance or whether equivalence with the standard may be established, the licensee, as a minimu::i, should

• demonstrate that the following issues have been adequately addressed for each device identified:

o adequacy of design {i.e., stress design factors, quality assurance, fabrication controls) o proof of workmanship and mechanical*

integrity

{initial load test) o programs to ensure continuing compliance (a test and ins?ection program whic..~ coreplies with l-.NSI Nl4,6-1978, Secticn 5). c. DISCUSSION VEPCO has identified three special lifting devices to be subject to the requirements of NUREG-0612 and ANSI Nl4.6-1978:

the reactor vessel head lifting device, the internals lifting rig, and the reactor coolant pump motor sling. .,. The Licensee states that these lifting devices were built a.~d fabricated prior to the issuance of both ANSI Nl4.6-1978 and ANSI B30.9-197l.

However, the supplier of these devices has been contacted by VEPCO to perform a cation that the devices conform to the above standards.

When this inform!ition has been provided, the Licensee should evaluate the results and m:,dify the ~-w~uU Franklin Research Center A D:v1~1on o! The Franic1n IMtCJte e -TER-CS506-395/396 devices or provide s~itable rationale which justifies the Licensee's.position that the existing device provides a degree of reliability consistent with NU?.EG-0612 and ANSI Nl4.6-l978.

In add.ition, VEE'CO states that the devices .,(. undergo routine periodic maintenance;

~nsufficient information has been provided to verify whether the inspection program conforms to ANSI Nl4.5-l978, Section 5. The intent of the NUREG-0612 guidelines, -in addition to determining that special lifting devices have been designed and fabricated in a man.~er consistent with high_reliability, is also to ensure that appropriate steps are taken to ensure that these devices are inspected, tested, and maintained for continued reliability..

Therefore, the Licensee should verify ~~at existing programs comply with the guidance of ANSI Nl4.6-l978, Sections. *, :.~~J Franklin"Research Center A OMsion ol ,ne F'1IMJI" ins:::,.,,.e l

• -ENCLOSURE 3 ... SYNOPSIS OF ISSUES ASSOCIATED WITH NUREG 0612 The following information is provided to identify exceptions or interpretations related to verbatim compliance with NUREG 0612 Guidelines that have occurred during the course of this review. For each of the major Guidelines specific exceptions are identified, a discussion concerning the underlying objective of that Guideline is provided, and approaches felt to be consistent and inconsistent with that guideline are identified.

While each such exception has been handled on a case by case basis, and has been considered in light of overall compliance with NUREG 0612 at a particular plant, the topics are of a nature general enough to be of interest to other plantso l .,.

l l ; GUIDELINE l SAFE LOI PATHS Exception l In the opinion of the licensee:

development of individual load paths is impractical since there are a significant number of loads for which the pickup* and laydown areas vary from outage to outage. Further, in some cases the location of safety related" equipment combined with the design of the floor over which heavy loads are carried indicates that for a number of lifts there is no preferred load path. Discussion The purpose of this portion of Guideline l is to ensure that the paths over which heavy loads are carried have been developed and approved in advance of the lift and are based on considerations of safety. In particular it is provided to avoid the ad hoc selection of load paths by maintenance personnel since such a situation could result in the use of a load path which has been established by a process wherein considerations other than safety have taken precedence.

It'is recognized that there are a class-of loads which, although in excess of the weight specified for classification as a heavy load, are actually eous or maintenance related loads for which it is impractical to identify a specific Iaydown area which can be fixed from outage to outage. Conversely there are a number of loads for which specific laydown areas have been allocated in the original plant design and which should reasonably be expected to be carried over the same load paths -during every outage. A tabulation of loads in this latter category, generally applicable to PWR's and BWR's, was provided in NUREG 0612 as Table 3-1.

• A fundamental principal of NUREG 0612 is protection through defense in depth. Specifically, the first line of protection from an accident which could result in damage to spent fuel or equipment required for safe shutdown or decay heat removal is to avoid or minimize the exposure of such equipment to crane borne loads overhead.

Where such exposure is minimized, rather than avoided, a second line of defense can then be provided by intervening barriers such as floors or the provision of additional lifting device redundancy or safety factors. Considering the foregoing, the use of exclusion areas, rather than safe load paths, is consistent with this guideline only under circumstances where there is no safety related equipment located beneath the area accessible to the crane hook but outside of the exclusion area. This situation has beer:i found in buildings such as the turbine hall or screen house where safety related equipment is concentrated in a specific area within the crane p_ath. It is unlikely to occur within containment due to the numerous safety related piping and electrical systems provided to support decay heat removal. Approaches Consistent With This Guideline , Specific safe load paths are prepared and approved.

for major components for which hazardcus areas are well established.

For miscellaneous lifts load corridors are established such that any movement within that corridor cannot result in carrying a heavy load over spent fuel or systems required for safe shutdown or decay heat removal (regardless of intervening floors). Movement within these corridors is at the discretion of the load handling party. Specific safe load paths are prepared and approved for major components for which hazardous areas are well established.

For miscellaneous lifts detailed ions are prepared and approved for developing safe load paths which include floor plans showing the location of safety related equipment and instructions to av*oid such equipment.

Specific safe load paths are then prepared each time a miscellaneous lift qualifying as a heavy load is made. These individual load paths are temporary and may change from outage to outage. 2

.

. e e Approaches Inconsistent With this Guideline.

• • .. µse of limited exclusion areas in containment which merely prohibited the carrying of heavy loads directly over the core or specific components and allow

• full load handling party discretion in other areas. E.xception 2 In the opinion of the licensee marking of load paths on the floor is impractical.

This may be caused by the general use of temporary floor coverings which would cover the load path markings, or, due to the number of loads involved, a requirement for multiple markings which could confuse the crane operator * . Discussion . The purpose of this feature of Guideline 1 is to provide visual aids to assist the operator and supervisor in ens.uring that designated safe load paths are actually followed.

In the case of the operator it has the additional function of avoiding undesirable distractions while handling suspended loads (e.g., trying to read procedural steps or drawings while controlling the crane). This feature should also be seen as a provision necessary to complete a plan for the implementation of safe load paths. Specifically it provides some additional assurance that, having spent the tlme and effort to develop safe load paths, those paths will be followed.

Approaches Consistent With this Guideline Rather than mark load paths a second member of the load handling party (that is, o.th~r than the crane operator) is made responsible for assuring that the designated safe load path is followed.

Thfs second person, a signalman is typically used ~n cab operated cranes, checks out the safe load path prior to the lift to ensure . that it is clear, refers to the safe load path guidance during the lift and provides ion to the operator and that the load path is followed.

To support this approach the duties and responsibilities of each member of the load handling party should be clearly defined. Prior to a lff t the appropriate load path ls temporarily marked (rope, pylons, etc.) to provide a visual reference for the crane operator.

In cases where the load pa th cannot be marked (e.g., transfer of the upper internals in a PWR) temporary or permanent match marks can be employed to assist ln positioning the bridge and/or trolley during the lift. In either case reasonable engineering judgement would indicate that in certain specific !if ts marking of safe load paths is unnecessary due to physical constraints en the load handling operation (e.g., simple hoists, monorails, or very short lifts where movement is limited to one coordinate axis in addition to the vertical).

Approaches Inconsistent With this Guideline.

Positions which in effect do not recognize the need for realistically providing visual aids to the crane operator and imply that, for all lifts, the operator will remember the load path from review of procedures or by reference to a drawing. Exception 3 Obtaining written alternative procedures approved by the plant safety review committee for any deviations from a safe load path is considered too cumbersome to accommodate the handling of maintenance loads where laydown areas may have to change or load paths altered as a result of unanticipated maintenance requirements.

3

.... _, Discussion e e The purpo~e of this portion of this guideline is to ensure that deviations from established safe load paths receive a level of review appropr1ate to their safety significance.

In general it is highly desirable that once safe load paths are established they are retained and kept clear of interference rather -than routinely deviated from. It ls recognized, however, that issues associated with plant safety are the responsibility of an individual licensee plant safety review committee (or equivalent)

• and the details of their excercizing this responsibility should be within their jurisdiction.

Approach Consistent With this Guideline . . A plant safety review committee (or equivalent) delegates the sibility for approving temporary changes to safe load paths to a person, who may or may not be a member of -that committee, with appropriate training and education in the area of plant safety. Such changes are reviewed by the safety review committee in the normal course of events. Any permanent alteration to a safe load path is approved*

by the plant safety review committee.

Approach Inconsistent With this Guideline Activities which in effect allow decisions as to deviations from safe load paths to be made by persons not specifically designated by the plant safety review committee.

4 GUiDELINE 2 LO~D HAN.NG PROCEDUR~~

e ... No significant exceptions to this guideline have been encountered.

• Occasionally a question arises concerning the need :for individual procedures for each !if t. In general, it was not the purpose of this guideline to require separate procedures for each lift. A reasonable approach is to provide separate procedures for each major lift (e.g., RV )'lead, core internals, fuel cask) and use a general procedure for handling other heavy loads as long as load specific details (e.g., load paths, equipment requirements) are provided in an attachments or enclosures.

5 -*

..--------------~-------------c--~------

--e -GUIDELINE 3 CRANE OPERA TOR TRAINING Exception The only exception occassionally encountered with respect to.this Guideline other than fairly minor, site unique, exceptions has been a desire to deviate from the requirement of ANSI B30.2".'3.l.7 .o for testing of all controls before beginning a new shift. In some cases a licensee has qualified a commitment in this area by noting that only crane controls "necessary for crane operation" will be tested at the start of a shift. Discussion This requirement (ie. not a recommendation) of ANSI B30.2 is important since crane control system failures are relatively significant contributors to load handling incidents.

The only reason that can be seen for an exception in this area is a general aversion to the word "all". Specifically, it appears that some licensees fear that a commitment to this requirement will force them to test all control type devices (eg. motor overloads, load cells, emergency brakes) rather than just those features generally known as controls (ie. hoist, bridge, and trolley motion controllers).

Approaches Consistent With this Guideline Exceptions that clearly indicate that all normal controls (hoist, bridge, and trolley motion controllers) will be tested at the start of each shift and that the purpose of not committing to "all" controls is to avoid a misunderstanding concerning other control devices. Approaches Inconsistent With This Guideline A response that implies that a decision to test or not test a normal control will be made by the crane operator on the basis of what type of lift or direction of motion he expects :for the forthcoming shift. 6 I ! .,.. l GUIDELIN°E 4 SPECIA1'FTING

~EVICES e ... Exception 1 . Some licensees have indicated that their special lifting devices were designed and procured prior to the publication of ANSI N14.6 and therefore are not designed in accordance with that standard.

This fact ls sometimes combined with a reference to the title of that standard to reach a conclusion that the standard is not applicable.

Discussion The purpose of this section is to ensure that special lifting devices were designed and constructed under controlled conditions and that sufficient ation is available to establish existing design stress margins and support future ance and repair requirements.

ANSI NI4.6 is an existing standard that provides ments supporting this goal for lifting device applications where the consequence of a failure could be similar to that which could be expected in the. event of the failure of a special lifting device carrying a load within the jurisdiction of NURE.G 0612. Consequently it seems appropriate that for special lifting devices subject. to NUREG 0612 it should be able to be demonstrated that, from a design standpoint, they are as reliable as a device for which ANSI N 14.6 was developed.

Approaches Consistent With This Guideline Although not originally specified to be designed in accordance with ANSI N 14.6 the special !if ting device in question was provided by a reactor vendor, in accordance with appropriate quality assurance and quality control procedures, for a specific application associated with power plant components provided by that vendor. Based on either the review of 'f:he original stress report or, if such a stress report is unavailable, the preparation

• of a new stress report, the licensee has determined that margins to material yielq and ultimate strength are comparable to those specified in ANSI N 14.6. Al though not required of the lifting device vendor, the licensee has reviewed the design of the lifting device and prepared a list of critical components whose repair or replacement should be performed under controlied conditions.

Approaches Inconsistent With This Guideline No information is available concerning the original design but it is probably allright because the device has been used for ten years and never failed. The device was.built before the publication of ANSI Nl4.6, does not carry shipping containers of nuclear material weighing mor~ than 1'0,000 pounds," and thus need not comply with ANSI N14.6. Exception 2

• No 15096 overload test has been performed and, in the opinion of ~he licensee, such a test is impractical.

Discussion The performance of a load test in excess of the load subject to NUREG 0612 is an important contributor to the ability to assess the overall reliability

_of a device. Such a test supplements design reliability by demonstrating that the device was properly fabricated or assembled and that a portion of the design safety margin has been demonstrated.

Such proof of workmanship is particularly important .for a fairly complicated device. It is recognized, however, that the specification of a 150% overload test is somewhat arbitrary and that, in some cases, the nature of the device is such that the liklihood of workmanship shortcomings is remote. 7

'-1 , I , , .. .e e Approaches Consistent With This Guideline The licensee has evaluated the lifting device in question and has determined that design stress margins are substantial.

Further it has been established that the device itself is uncomplicated and principally put together with mechanical joints such that an assembly error is highly unlikely.

The use of welded joints is sever!y limited and where employed were performed in accordance with substantial quality controls (eg AWS Dl.1) including NDE. The device has been tested to 100% of rated load. Although a 150% overload test has not been performed the lifting device has been subjected to a manufacturer recommended overload to demonstrate proof of workmanship (typically 120-125%).

Approaches Inconsistent With This Guideline See this topic for Exception 1 above. Exception 3 The requirement of ANSI N14.6 for an annual ISO% load test or full NDE is excessive.

Both the load test (due to the inability to make the test lift within containment) and the NOE (due to the need to remove protective coatings) are impractical and not justified by the infrequent use of these devices. Discussion . . A continuing inspection program to assure the continued maintenance of safety margins incorporated in the original design of the device is important to demonstrate the reliability of special lifting devices. It is recognized, however,_that some devices empioyed ln a nuclear power plant, particularly those associated with refueling, are used un~er conditions of control and at frequencies of use that are ially less severe than that possible for the type of lifting device for which ANSI N 14.6 was originally prepared.

Consequently a reasonable relaxation of the inspection interval seems appropriate.

• Approaches Consistent With This Guideline Overload tests will be conducted but at a longer interval, 5 years, between tests to be consistent with the number of operational lifts required.

NDE of load bearing welds will be conducted at 5 year intervals or, alte:-;-,2.tively, load bearing welds will be examined through a p:-ogram that ensur~s that all welds will be examined over *a normal inservice inspection interval of 10 years in a manner similar to that specified in the B&PV Code for Class 2 Component Supportsc Aoproach Inconsistent With This Guideline Continuing inspection will be limited to an annual visual examination of the device. 8

' ' , , . . .GUIDELINE 5 LIFTING DE.ES NOT SPECIALLY

~ESIGNiD e .... Exceotion Licensees have taken exception to the requirement to select slings in accordance with the maximum working load tables of ANSI B30.9 considering the sum of static and dynamic loads. Most commonly it is the licensees position that the approximate factor of safety of five on rope breaking strength inherent in these tables adequately accomodates dynamk loading. Discussion .

• The intent of this portion of this Guideline, which also applies to special lifting devices under Guideline 4, is to reserve the ANSI B30.9 safety factors for accomodating sling wear and unanticipated overloads and avoid a reduction of this safety factor as a result of the routine dynamic loads inherent in hook/load eration and deceleration.

While it is acknowledged that, for operating characteristics typical of cranes employed at nuclear power plants, these dynamic loads are unlikely to be substantial, such a determination cannot be made generically.

Typically the actual dynamic load due to hook/load acceleration or deceleration is a function of design hook speeds and the type of hoist control system employed.

It should also be recalled that ANSI B30.9 is a general industrial standard which applies to all load handling devices and does not in itself provide for any additional conservatism in consid-. eration of the potential consequences of a load handling accident at a nuclear power plant. Based on this, it is considered reasonable that individ;.ial licensees evaluate the potential contribution of dynamic loading in their operations and if such dynamic loading is indeed significant accomodate it in their procedures for sling selection.

A pp roach Consistent With This Guideline The licensee has evaluated the potential routine dynamic loading for lifting devices not specially designed and found them to be a relatively small fraction (typically 5-15%) of static load. This estimate has been made on the basis of either caiculated acceleration and deceleration rates or through use of the industrial standard for impact loading of cranes specified in CMAA-70. In ei:her case having v.erified that routine dynamic loading of a specific hoist is indeed small the licensee has drawn the conclusion that revised selection criteria to accomoda te such minor additional loads will not have a substantial effect on overall Joad handling reliability.

Approach Inconsistent With This Guideline Statement to the effect that dynamic l~ac:'5 a:-e accomodated in the tables of ANSI B30.9 with no indic;ation that the licensee has asses.sed the actual dynamic loading imposed on cranes subject to NUREG 0612. 9

' e. e GUIDELINE 6 CRANE INSPECTION TESTING AND MAINTENANCE.

Exception . The only exception occasionally encountered with respect to this Guideline other than fairly minor and site-unique exceptions has been a desire to deviate from the requirement of ANSI B30.2-l.l.2.a.2 and 3.2.4 for testing of hoist limit devices before beginning a new shift. In some cases a licensee has qualified a commitment in this area by noting that this limit switch will be tested only if operations in the vicinity of the limit switch are anticipated.

Discussion While this issue is treated somewhat ambigously in ANSI B30.2 (it is a recommendation in article 1.1.2 and a requirement in article 3.2.4) it is important since two-blocking incidents are relatively significant contributors to load handling incidents.

Further it should be noted that this test has been incorporated as a ment of*OSHA in 29 CFR 1910.179.(n).(4).(i).

It is recognized, however, that there may be circumstances where such a test is not prudent. First, such a test clearly should not be made with the hook under load. Consequently if a shift change is made with the hook loaded (this, by the way, is not a desireable practice and could be ed through strict compliance with ANSI B30.2-3.2.3.j) a hoist limit switch test should not be performed.

Second, there may be circumstances where the nature of forthcoming load handling operations indicates that the time (and minor risk) associated with this test is not justified.

In particular if it is known that a hoist will not be used or used only in an area substantially removed from the upper travel limit, it would seem able to defer the* limit switch test until the start of the next shift. If such an approach is taken, however, it should be approached with care. Requirements for deferring an upper limit switch test should accomodate the uncertainty associated with maintenance plans and establish unambiguous criteria concerning what operations can be determined to be remote from upper travel limits. Such criteria should recognize that the need for upper travel limit switch protection may be preceeded by a control system failure and consequently should conservatively allow for operater response time and potential delays associated with emergency shutdown of the crane. Approach Consistent With This Guideline

• General compliance with this requirement.

Certain specific provisions made for deferring upper limit switch testing under conditions that are not subject to operater interpretation.

• Approaches Inconsistent With This Guideline An approach that implies that a decision to test or not is left to the discretion of the operator or implies that such a test will be required only if ions are planned in close proximity to the hook upper travel limit. 10

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• GUIDELINE 7 CRANE DESIGN ... Exception Occasionally a licensee has indicated that the overhead electric travelling cranes employed at a site were purchased prior to the publication of CMAA-70 or ANSI BJ0.2-1976 and thus these standards should not be applied. Discussion The purpose of this Guideline is to ensure that all cranes carrying heavy loads in nuclear power plants meet certain minimum criteria in their design and, consequently, can be assumed to provide an acceptable standard of mechanical, electrical, and structural reliability.

It is also recognized, however, that cranes in operating plants may have been designed and procured prior to the publication of current standards and, tf1us, not strictly comply with some details of these standards.

In general, though, current standards have evolved from predecesor standards in existence at the time of crane procurement (EOCI 61, ANSI B30.2-1967) and, since the later standards are not. revolutionary, it is likely that cranes at nuclear power plants will provide a degree* cf reliability equivalent to that provided by the current standards.

Such a general determination canot be made, however, by the staff since nuclear power plant cranes are usually unique and provided with site specific design features.

It is up to the licensee then to make a systematic comparison of their crane design with the requirements of current standards and determine if additional design features are appropriate.

Approach Consistent With This Guideline The licensee has compared original crane procurement specifications or existing crane designs with the requirements of the referenced standards in areas effecting load handling reliability.

In instances where the current standard provides additional protection against the consequences of operater error or component failure the licensee has proposed modifications which will result in a degree of load handling reliability similar to that provided in the current standard.

Approach Inconsistent With This Guideline Positions to the effect that the cranes satisfied standards in existence at the time of procurement and what was good enough then is good enough now. 11

, .. Cooper Crystal River 3 D. C. Cook 1 & 2 Dresden 2 & 3 Ft. Calho'un Haddam Neck Maine Yankee Monticello Palisades

• • ENCLOSURE 2 North Annal & 2 Rancho Seco Surry 1 & 2 Trojan Turkey Point 3 & 4 Vermont Yankee McGuire l & 2 Zion l & 2 Duane* Arnold *