ML18051A311

Submits Recommendations & Formalized Commitments Re Draft Technical Evaluation Rept, Control of Heavy Loads. Procedure Will Be Implemented to Cover Deviations from Safe Load Paths

ML18051A311
Person / Time
Site:	Palisades
Issue date:	02/18/1983
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield 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 NUDOCS 8302230380
Download: ML18051A311 (5)

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General Offices: 212 West Michigan Avenue, Jeck10n, Ml 49201 * (617) 788-0660 February 18, 1983 Dennis M Crutchfield,, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO DRAFT TER C5257-439, HEAVY LOADS PALISADES A draft Technical Evalution Report (TER) entitled "Control of Heavy Loads" was received by Consumers Power Company March 16, 1982. This draft TER is the evaluation of Consumers Power Companys submittals dated May 15, 1981 and July 6, 1981 on Response to the Interim Action Requirements and the Six Month Response 'to the December 22, 1980 NRC letter concerning NUREG-0612 respectively. A telephone* conference with the NRC staff and Franklin Research Center resulted in a discussion of the recommendations made in the draft TER, which would enable the Palisades Plant to comply with the requirements of Enclosure 2 and Section 2.1 of Enclosure 3 of the December 22, 1980 NRC letter, and in verbal commitments by Consumers Power Company to perform certain actions. The draft TER recommendations and Consumers Power Companys' formalized commitments are presented below:

I. RE: Draft TER - FRC Project C5257, Task 439, pages 25-27.

Recommendations to comply with Section 5.1.l of NUREG 0612.

1. Guideline 1 l,a. For the fuel pool building, verify that (1) deviations from defined load paths require written alternative procedures approved by the plant safety review committee, (2) load paths are shown on equipment layout drawings, and (3) load paths are clearly marked or suitable alternatives are used.

Response

(1) A procedure will be implemented to cover deviations from the safe load paths required by Procedure No. FHS-M-23.

The new procedure will require that deviations from safe load paths be approved by both the Reactor Engineer and the Shift Supervisor.. FHS-M-23 will refer to the new procedure.

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DMCrutchfield, Chief 2 Palisades Plant RESPONSE TO DRAFT TER - HEAVY LOADS February llj, 1983 (2) Load paths are marked on an equipment layout drawing included in Procedure No. FHS-M-23.

(3) FHS-M-23 will be revised to include the requirements that the crane operator will take movement signals from another individual who has knowledge of safe load paths and procedures, for handling heavy loads.

l.b. Develop safe load paths in the containment building similar to those in the fuel pool building for all heavy loads or substan-tiate the statement that no decay heat removal or safety-related equipment can be damaged outside of the 38-ft-diameter circle over the reactor vessel, without taking credit for intervening structures, system redundancy, or electrical and mechanical interlocks.

Response

Safe load paths for heavy loads will be marked on equipment drawings of the containment. The drawings will be made a part of Procedure FHS-M-24 along with instructions for the manner with which the safe load paths will be followed.

2. Guideline 2 Consumers Power will comply when appropriate load paths are incorpo-rated into procedures for all heavy loads in the reactor building.

3. Guideline 3 Consumers Power complies with this Guideline.

4. Guideline 4 4.a. Identify and evaluate all special lifting devices in accordance with the specific criteria identified in FRC's evaluation.

Response

The Core Barrel lifting device, the upper Guide Structure Lifting Device, the Reactor Head lifting device, and the Missile Shield lifting device are the. only special lifting devices used for lifting heavy loads at Palisades. The suppliers of those devices will be asked to compare the standards used in designing, manufacturing and testing the devices to those recommended by ANSI Nl4.6-1978. Evalu-ation of the comparison will be made by CPCo engineers and if modifi-cations are required, they will be completed.

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DMCrutchfield, Chief 3 Palisades Plant RESPONSE TO DRAFT TER - HEAVY LOADS February 18, 1983 4.b. For the spent fuel cask lifting device, commit to perform the evaluation of those items identified in FRC's evaluation prior to use of the lifting device.

Response

Before the spent fuel cask lifting device is used, CPCo will compare and evaluate the manufacturing, testing and design standards used for that device to those recommended by ANSI 14.6-1978.

5. Guideline 5 Verify that selection and marking of slings are based upon the maximum static and dynamic loads.

Response

a. Those slings which are used exclusively on the main hoist of either the reactor building crane or fuel pool crane will be marked as to their limited used and rated for static load only. The maximum hoist speed of 4 fpm on the fuel pool crane and 6 fpm on the reactor building crane do not permit dynamic loads of any consequence.

b. Slings which are used with the auxilliary hooks (both cranes are capable of up to 35 fpm) will be analyzed for both static and dynamic loading. If the dynamic load is greater than 10% of the presently rated static load, the combined dynamic and static load will be used to rate the sling.

6 *. Guideline 6 Identify those items for which the required frequency of inspection and testing is not satisfied due to impracticality and explain the rational for selecting these items.

Response

With the exception of the daily limit switch test, which is performed monthly by plant electricians, Section 2-2 of ANSI B30.2.0-1976 is being complied with. Each operator has a different interpretation of how to test the limit switches. Therefore, limit switch testing is included in the monthly maintenance inspections.

7. Guideline 7 Evaluate applicable cranes in accordance with the specific criteria identified in FRC's evaluation.

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DMCrutchf ield, Chief 4 Palisades Plant RESPONSE TO DRAFT TER - HEAVY LOADS February 1e, 1983

Response

CPCo is in the process of evaluating the Palisades fuel pool crane and the reactor building crane against the specific CMAA-70 criteria.

The crane manufacturer (DRESSER) will be requested to perform the evaluation and to state their opinion as to the equivalency of the criteria used to design, manufacture and test the cranes and the specific criteria of CMAA-70. Modifications to the cranes will be completed if equivalency does not exist.

II. RE: Interim Protection Measures - Recommendations, page 28 of TER-C5257-439.

1. Interim Measure No. 1 "Implement the technical specification identified in this interim proteciton measure."

Response

Palisades Procedure FHS-M-23 prohibits movement of heavy loads over the fuel pool. Therefore, implementation of Standard Tech Spec 3.9.7 would be superfluous.

2. Interim Measure No. 2 and No. 3 "Implement the recommendations of Guidelines 1 and 2 identified in Section 3 .1."

Response

Compliance with Guidelines 1 and 2 as per the recommendations identi-fied in Section 3.1 will be complete on or before May 1, 1983.

3. Interim Measure No. 4 and No. 5

Response

CPCo complies with these interim measures.

4. Interim Measure No. 6 "Perform the recommended review of this interim protection measure."

Response

The CPCo letter, dated May 15, 1981, to DMCrutchfield of the NRC committed Palisades to total implementation of the recommended Interim Actions (Enclosure 2 of the December 22, 1980 NRC letter and Section 5.3 of NUREG 0612) before the 1981 refueling outage. At that time a special revue for handling heavy loads over the core was made in compliance with Section 5.3, Interim Protection (6) of NUREG 0612 and Interim Action (5) of Enclosure.

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DMCrutchf ield, Chief 5 Palisades Plarit RESPONSE TO DRAFT TER - HEAVY LOADS February l8, 1983 III. RE: Request made by Mr Sargent during the January 13, 1983 conference call between Mr. Clemenson of the NRC, Mr. Sargent of FRC and Mssrs Johnson, Engle, and Smedley of CPCo, to have CPCo mark the fuel building Jib crane and the reactor building Jib crane so as to limit their loading to 1300 lbs.

Response

The fuel building Jib crane and the reactor building Jib crane will be marked "1300lb max load".

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0283-0014B-NL02