ML20010G328

Forwards Info Describing Results of Review of Controls for Handling Heavy Loads Actions That Will Be Taken & Addl Measures Taken to Meet Intent of NUREG-0612 Guidelines,In Response to NRC 801222 Ltr

ML20010G328
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	09/11/1981
From:	Jackson E VERMONT YANKEE NUCLEAR POWER CORP.
To:	Eisenhut 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 FVY-81-134, NUDOCS 8109150592
Download: ML20010G328 (32)

Text

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VERMONT Y AN KEE NUCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET 2.C.2.1 RUTLAND, VERMONT 05701 FVY 81-134 REPLY TO:

ENGINEERING OFFICE 1671 WORCESTER ROAD FR AMINGH AM. M ASS ACH USETTS 01701 TELEPHON E G17 872-8100 September 11, 1981 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission

[N C6 Washington, D.C. 20555 3 g Attention: Mr. Darrell G. Eisenhut, Direct or + 8 " l.

Divisfor. of Licensing k g('p 'I/$g '

References:

(a) License No. DPR-28 (Docket No. 50-271)

(b) Letter, USNRC to VYNPC, dated February 3, 1 (c) Letter, VYNPC to USNRC, FVY 81-91, dated June p (d) Letter, VYNPC to USNRC, dated December 30, 1975 M (e) Letter, VYNPC to USNRC, dated June 2, 1976 (f) Letter, USNRC to VYNPC, dated January 28, 1977

Subject:

Control of Heavy Loads Reference (b) requested a review of the controls for handling her.vy loads at Vermont Yankee, the implementation of certain recommendations regarding these controls, and the submittal of information to demonstrate that those recommendations have been implemented.

Vermont Yankee has completed the first phase of the requested review of our facility. Tne enclosed informatior describes the results of this review, the actions that will be taken, and the additional measures taken to meet the intent of the general guidelines of Section 5.1.1, NUREG 0612. The information is presented in Attachment 1 as responses to the items in Section 2.1 of Enclosure 3 to your December 22, 1980 letter.

With regard to the implementation of actions determined to be necessary as a result of our review, all procedure revisions will be completed prior to the end of the first quarter of 1982.

As a result Of our review, we have determined that the only over-head load handling system at Vermont Yankee requiring detailed consider-ation with regard to Reference (b) is the reactor building crane. The basis for this determination is presented in Attachment 1. In addition to the considerations presented in this attachment, the reactor building 8109150592 810911 0 PDR ADOCK 05000271 hs g P PDR 1

United States Nuclear Regulatory Commission September 11, 1981 VERMONT YANKEE Nt4 LEAR POWER COMPORATION Page 2 crane and its operation has been previously subjected to close scrutiny by both Vermont Yankee and the NRC. References (d) and (e) submitted detailed information concerning modifications to this crane to make it fully redundant and single-failure proof. The NRC's review and approval of these modifications is documented in the safety evaluation report transmitted by Reference (f).

In light of the results of our review of the overhead handling systems at Vermont Yankee, together with previously documented information regarding the reactor building crane, Vermont Yankee concludes that the actions described in this letter and its attachment are adequate to address all the concerns of Reference (b). Vermont Yankee believes that no further action in this area is warranted.

We trust the information presented above is satistactory; howerrt, should you have further questions, please contact us.

Very truly yours, VERMONT 1/dKEE NUCLEAR POWER C')RPORATION

{Q - A- )

E.W ackson Manager of Operations EWJ/dm (t 2

RESPONSES TO REQUESTS i FOR p It&ORMATION IN SECTION 2.1 OF ENCLOSURE 3 TO DECEMBER 22,1980 LETTER FROM D. EISEtMIT ITEM I: Report the results of your review of plant arrangements to identify all -

overhead nondling 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 struc-tural analysis).

RESPONSE: A review of plant arrangement drawings and on area survey were conducted to determine handling systems of concern; i.e., those handling systems that could carry heavy loads over irradiated fuel in the core, over spent fuel, or over components in systems required for plant shutdown or decay heat removal.

The location of such components was determined from reviews of plant arrange-ment drawings os well as from information contained in the plant fire hazards analysis (which shows location of safe shutdown components). Based on this review, we have tc,und that the only handling system of the Vermont Yonkee facility that must be addressed within the scope of NUREG-0612 is the Reactor Building Crane.

Reactor Building Crone. This crane, designed and fabricated by Whiting Corporation, has a main hoist capacity of l10 tons and an auxiliary hoist of 7 tons. The heavy loads that are handled by the Reactor Building Crane are l listed in Table 2. The crane was modified in 1976 by replacing the original trolley with one that has a dual load path on the main hoist when used for l shipping cask handling operations. When using the hoist for operations other than ,

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l cask handling, the dual load path hook h replaced with the original sister hook l and is used with original lifting devices that are not of dual load path design.

However, all other dual load paths remain in effect for all main hoist lif ts.

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The design of the new trolley has been reviewed and approved by the NRC os I satisfying the staff's criteria for dual load path or " single-follure-proof" crones. i j The staff's SER on evaluation of this crone with a new trolley was transmitted to

! Vermont Yonkee by letter of January 28,1977 that included License Amendment l 1

No. 29. This SER required that prior to cask handling operations, details should i.

be provided to the staff concerning the design of the lifting device to be used in order to verify that this met dual food path criterio. However, for the handling i

of heavy loods other than a shipping cask with the main hoist, provisions have not been mode for the use of dual lood path or high safety factors for the lifting i

devices that would be used. Additionally, certain heavy loads are handled by the ouxiliary hoist which is not of dual load path design.

i f The safety concern when handling loods with the Reactor Building Crone is the movement of loads over or in proximity to irradiated fuel in the core when the l vessel head is removed, irradiated fuel in the spent fuel pool, the reactor vessel l (effects due to o vessi head drop), and safe shutdown equipment at lower

[ elevations (primari!y the suppression pool, equipment in the southeast corner

! room below the reactor building equipment hatch, and equipment below the vessel head loydown oreo such as uninterruptible power supply batteries and I

inverters-- UPS-I A and UPS-18).

The responses to the following items describe how the handling of heavy loods by l

the Reactor Building Crone satisfies the general guidelines (Section 5.1.1) of NUREG 0612.

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ITEM 2: Justify the exclusioa of any overhead handling system from the above category by verifying that there is sufficient physical separation from any lood-impact point and any safety-related component to permit a determination by inspection that no heavy load drop :on result in damage to any system or component required for plant shutdown or core decoy heat removal.

RESPONSE: Table I lists the cranes, hoists, and monorails that have been excluded from consideration within the scope of NUREG 0612. The following provides the bases for excluding these handling systems.

l. Reactor Feedwater Pump Monrails.

Separate 16-ton monorails are located over each feedwater pump for servicing this equipment. There is no safety-related equipment in the feedwater pump area.

2. Condensate Demineralizer Monorail.

This monorail is located in the Turbine Building. There is no safety related equipment in the area served by this monorail.

3. Diesel Geneator Monorails (2).

Each diesel generator unit is located in a separate room. The only equipment in each room is associated with that diesel generator. Separate monorails are located over each diesel generator unit to assist removal and replacement of small components. These monorails may be excluded because a load drop would not cause loss of safe shutdown functions.

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4. CRD Storage and Repair Monorail, and f

5. CRD Storca and Repair Jib Crone These handling systems are located in the CRD repair room.

This roorn contains certain ccble trays and conduit designated as safety related; however, tnese are located above the mono-rail and jib crone so that the cabling could not be impacted during lood handling operations or due to a food drop.

6. HPCI Equipment Monorail (4 ton).

This 4-ton monorail is located above the HPCI pump and motor, ond continues over to the doorway into the southwest corner room, but ends before the doorway. The only equipment in this room is ossociated with the HPCI pump. Based on the above, a load drop from this monorail will not cause loss of safe shutdown functions.

7. HPCl/CRD Pump Room Access Hatch Hoists (2)

There are two 2-ton hoists located at this hatchway at elevo-tion 252 feet. One hoist is on electric driven Peerless /Harring-ton chain hoist. The other is a pneumatic cable hoist by Chicago Pneumatic. These hoists are used for lowering or hoisting equipment between this elevation and elevations 232 feet and 213 feet in the southwest corner room. There is no cabling or equipment in proximity to this hatchway that could be impacted by a load drop from either of these hoiste. The 213 foot elevation is the lowest level in the Reactor Building.

Because of the above, these hoists may be eliminated from consideration under NUREG 0612.

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8. RCIC Equipment Monorail i

This 2-ton monorail is located directly over the RCIC pump and turbine and extends for opproximately 8 feet beyond the RCIC turbine. The only equipment and cabling in this oreo is associated with the RCIC sysfun. Based on the above, o load drop from this monoroll would not cause loss of safe shutdown functions.

9. Reactor Recire. Pump Monorail The 16-ton monorail in the drywell is located over the recircu-lation pumps and motors and connects these areas with the equipment access lock area. This monorail con be used only when the plant is shut down and already on decay heat removal.

The monorail would only be used for removing and reinstalling recirculation pump motors or pump parts. When on decay heat removal, the equipment in the drywell that is being used is piping for RHR suction and return, and instrument lines asso-1

> ciated with vessel level instrumentation. All instrument lines are located above the elevation of the monorail. Elec trical j

cabling is located along the wall or above the monorail. RHR lines cross over the monorail and then drop down to connect to recirc loop piping. These lines are located such that they would

( not be impacted when handling a load with this monorail or if the load were to be dropped. Based on the above, handling of loads or a load drop would not resuh in loss of safe shutdown or decoy heat removal equipment.

10. Recire. Motor Generator Sets Monorail This monorail extends for opproximately 90 feet over the two motor generator sets. There is no safe shutdown or decoy heat l

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removal equipment located in this area. Since a load drop from this monorail would have no effect on safe shutdown decay heat removal functions, this monorail may be excluded from the scope of the NUREG 0612 criteria.

I 1. Copping and Decon Station Monorail

12. Waste Demin. and Filter Monorail

13. Fuel Pool Filter Demin. Monorail

14. Centrifuge CF-l-I A Monorail

15. Centrifuge CF-l-IB Monorail These monorails are all located in the Radwaste Building.

There is no safe shutdown equipment in the Radwaste Building, and damage to equipment due to a load drop would not result in releases that cpproached Part 100 limits.

16. Main STecm and Feedwater Valve Monorail This 3-ton monorail is located in the main steam tunnel within the Re wtor Building at elevation 252 feet. The monorail is used during shutdown conditions to service MSIVs and feedwater volves in this tunnel. The steam and feedwater lines would not be required for decay heat removal. The only safe shutdown equipment in this area is a cable tray passing through that is routed parallel to the menorail track, but at least 10 feet away at approximately the same elevation.

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17. Suppression Pool Chamber Access Hatch Monorail i

This 3-ton monorail is a short length (approximately 4 foot long ,

track) located in a stairwell area at elevation 252 feet in the Reactor Building. This monorail is only used for removal of the suppression pool occess hatch and for raising or lowering tools ,

and equipment for suppression pool maintenance. Such handling operations would normally take place when the reactor is already shut down.

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18. CRD Pump Menorails (2)

Separate monorails are located over each CRD pump of elevo-tion 232 feet and would only be used to service o CRD pump when that pump has already been removed t:om service. The CRD pumps are separated by approximately 6 feet of open floor j

space, so that a load drop from one monorail would not offect the adjacent pump. There is no other safe shutdown cabling or equipment in close proximity to the CRD pumps. Based on the i

above, these monorails may be excluded from the scope of NUREG 0612 criterio.

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19. Miscellaneous Portable Hoists Used for Access to Corner Rooms There are several portable hoists that would be ottoched to podeyes or special rigging and used for removal of hatches providing access to RHR corner rooms in the Reactor Building and for removol/ replacement or servicing of equipment. Equip-ment serviced could include RHR heat exchangers (tube bundle cleaning or replacement) or removol/repfocement of RHR pumps, RHR Service Water pumps, or RCIC compnents. Loads 7

I e_ - ~ . _ - _ . _ . _ _ , _ _ , . . _ _ _ , _ , _ _ _ _ _ , ___ , __ ,_ _

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would only be handled in the hatchways by these hoists, and then transported on carts. With the exception of the hatches providing access to the RHR heat exchangers, there is no equipnent directly below or in proximity to the hatchways that could be inpacted by a load drop. When servicing an RHR heat exchanger, a load drop would only inpact that heat exchanger that is already out of service for repairs. The only credible load drop for these heat exchangers would be a drop of the tube bundles back into the heat exchanger shell. Based on the above, these hoists-may be excluded from the scope of NUREG M12 criteria.

20. Tbrbine Building Bridge Crane

This crane has a 140 ton main hoist and 25 ton auxiliary hoist and is used for handling heavy loads in the Turbine Building, primarily for noving large turbine generator camponents during maintenance or overhaul. It may also be used to handle plant components in the Tbrbine Building if these are being replaced. There is no safety-related equipnent within the travel limits of this crane, with the exception of a portion of cne diesel generator room located adjacent to the Turbine Building truck loading area. However, in the Turbine Building, this region is designated as a storage area that has a chain link fence around it, and contains small electrical gear. No heavy loads would be carried over this area. Based on the above, this crane may be eliminated from the scope of the NUREG 0612 criteria.

21. Drywell Relief and Safety Valve Monorail This nonorail is located at an elevation of approximately l

i 272 feet in the drywell and is used for servicing safety I

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and relief valves nounted on steam line headers. %ese hoists would only be used when the reactor is shut down and on RHR cooling. Here is no equipment required for decay heat reoval in proximity to these jib cranes.

Based on this, the nonorail in the drywell may be e-liminated frce the scope of NUREG 0612 criteria.

22. Refueling Floor Jib Crane

23. Refueling Platform Hoist Both of these handling systems are located at the 345 foot elevation of the Reactor Building and are used for handling various loads over the spent fuel pool or over the reactor. Rese may be used to handle fuel channels, control rod blades, LPRMs, or various tools such as LPRM cutters or the G.E. " CHAMS" channel inspection tool. No loads greater than the weight of a fuel as-sembly were identified that are routinely handled by these hoists. However, since these hoists are rated at 1,000 lbs. , they could be allowed to handle loads greater than the weight of a fuel assembly which is approximaely 700 lbs. Because of this, these hoists

! are being derated so that they are clearly marked to i not handle loads greater than 700 lbs. If it becomes necessary to lift a load greater than 700 lbs, but less than 1,000 lbs., a safety evaluation will be prepared l to assure that the criteria of NUREG 0612 are satisfied l

for the lift. his is not expected to be necessary, however, since the Reactor Buildirg Crane auxiliary hook could be used for such a lift. Wese hoists may be excluded from the NUREG 0612 criteria since they will not be allowed to handle loads greater than 700 lbs.

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TABLEI o

HANDLING SYSTEMS EXCLUDED FROM NUREG 0612 CRITERIA i

Handling System Location .

l. Reactor Feedwater Pump Monorails (16 ton) Turbine Building

2. Condensate Demineralizer Monorail Turbine Building l

3. Diesel Generator Monorolls - 2 Turbine Building I

4. CRD Storage and Repair Moncroll Reactor Building

5. CRD Storge and Repair Jib Hoist Reactor Building l

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6. HPCI Equipment Monorail (4 ton) HPCI Equipment Room

7. HPC1/CRD Pump Room Access Hatch Hoists - (2 fon) Reactor Building

8. RCIC Equipment Monorail (2 ton) Reactor Building

9. Reactor Recirc. Pump Monorail (16 ton) Drywell

10. Recirc. Motor Generator Sets Monorail Reactor Building i 1. Copping and Decontamination Station Rodwoste Building Monorail (5 ton)

12. Weste Demineralizer and Filter Monorail Rodwoste Building

13. Fuel Pool Filter Demineralizer Monorail Radwaste Building

14. Centrifuge CF-l-I A Monorail (3 tor.) Rodwoste Building

15. Centrifuge CF-l-IB Monorail (3 ton) Radwaste Building

16. Main Steam and Feedwater Valve Monorail (3 ton) Reactor Building

17. Suppression Pool Chamber Access Hatch Reactor Building Monorail (3 ton)

18. CRD Pump Monorci!3 - 2 (4 ton) Reactor Building l

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1 TABLEi (continued)

Handling System Location

19. Miscellaneous Portable Hoists for Corner Reactor Building -

Rooms Access and Servicing

20. Turbine Building Bridge Crone (140/25 ton) Turbine Building

21. Drywell Relief and Safety Volve Monorail Drywell

22. Refueling Floor Jib Crone Reactor Building

23. Refueling Pictform Hoist (h ton) Reactor Building ii

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ITEM 3: With respect to the design and operation of heavy lood-handling systems in the containment and spent-fuel-pool area and those lood-handling systems identified in I, above, provide your evaluation concerning compliance with the guidelines of NUREG 0612, Section 5.l.i. The following specific information should be included in your reply:

ITEM 3.a Drawings and sketches sufficient to clearly identify the location of safe lood paths, spent fuel, and safety-related equipment.

RESPONSE: It is Vermont Yankee's position that our present plant policy of handling heavy loads with the Reactor Building Crane is sufficient. Loads are lifted and moved directly to their intended destinations carefully and expedi-tiously so os to minimize handling time. In addition, pick heights are kept within reasonable limits. See Figure I for lay down areas of major components.

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ITEM 3.b A discussion of measures taken to ensure that food-handling operations remain within safe load paths, including procedures, if any, for i deviation from these paths.  ;

i RESPONSE: It is Vermont Yonkee's position that our present plant policy of i

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handling heavy loods with the Reactor Building Crone is sufficient. Loads are lif ted and moved directly to their intended destinations carefully and expedi-tiously so os to minimize handling time. In addition, pick heights are kept within reasonable limits. See Figure I for lay down oreos of major comoonents.

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FIGURE I LAYDOWN AREAS FOR MAJOR COMPONENTS

ITEM 3.c. A tabulation of heavy loads to be handled by each crane which includes the load identification, load weights, its designated lif ting device, and i verification that the handling of such loads is governed by a written procedure containing, as a minimum, the information identified in NUREG 0612, Section 5.1.l(2).

RESPONSE: The requested information is provided in Table 2. Handling Procedures O.P.1200, O.P.1201, and 0.P. 2200 at present include precautions; prerequisites; identification of proper handling equipment; training and qualifi-cation requirements for crane operators; sling selection criteria; required crane inspection by operator prior to load handling; supervision of lift by a designated individual; and steps in order to perform the lif t. Vermont Yankee's position on defined load paths is stated in item 3A. However, with regards to NUREG 0612, Section 5.1.l(2), we feel it is prudent to incorporate verification that inspections have been performed into the appropriate procedures. Fur.. er, we will revise other procedures such that the particular items mentioned above are more explicit.

TABLE 2 I

REACTOR BUILDING CRANE HEAVY LOADS APPLICABLE LIFTING WEIGHT OPERATING EQUIPMgNT/

( LOAD (TONS) PROCEDURES HOIST 54 O.P.1200/3 Head Strongback/M Reactor Vessel Head

' O.P. I201 44 O.P.1200/3 Head Strongback/M Drywell Head O.P.1201 22 0.P.1200/3 Dryer & Separator i Dryer Sling /M O.P.1201 Shroud Head / Steam Separator 33 0.P.1200/3 Dryer & Separator

' O.P.1201 Sling /M

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TABLE 2 (continued)

APPLICABLE LIFTING WEIGHT OPERATING EQUIPMgNT/

LOAD (TONS) PROCEDURES HOIST 4 Slings and l Shield Blocks (6) 64-71.S 0.P. (200/3 0.P.1201 Shockles/M 6

i Vessel Service Plotform 5 R.P. 2200 Service Plotform 6

New Fuel Storage Vault 3 eo. R.P. 2200 Slings /A Plugs (3)

Fuel Pool Gate i O.P.1200/3 bII"95/A O.P.I200 Refueling Slot Plugs (4) 6 eo. O.P.1200/3 b""98 "

O.P.1201 Shockles/A Vessel Head Insulation 4.5 0.P.1200/3 Slings /A

' O.P.1201 6

Spent Fuel Shipping Cask 35 to i10 R.P. 2200 Associated Cask Yoke /M 6

Filter-Demineralizer Hatch 8 eo. R.P. 2200 Slings /M l

RWCU (2) 6 Contom. Equipment Storage 2.5 eo. R.P. 2200 Slings /A Area Hatches (2)

Head Strongbock 4 0.P.1200/3 Main Hook /M O.P.I201 Dryer / Separator Sling 1.5 0.P.1200/3 Main Hook /M Assembly O.P.1201 Stud Tensioner Monorail 3.S O.P.1200/3 Am.H k/A O.P.1201 l

Cattle Chute l4 0.P.1200/3 4-Port Sling /M i

O.P.1201 l

15 s ,

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TABLE 2

, (continued)

APPLICABLE LIFTING WEIGHT OPERATING EQUIPMgNT/

LOAD (TONS) PROCEDURES HOIST 2

Dryer / Separator Storage 28/43.5 0.P.1200/3  ?/M Pool Plugs (4) O.P.1201 6

Load Block & Hook 6 R.P. 2200 Main Hoist /M 6

High-Pressure Water Blaster 2.S R.P. 2200 Slings /A (Decon. Machine)

Misc. Plant Equipment (less thon) R.P. 2200 6 Slings /A 20 i

1 NUREG 0612 defines a heavy load as one that weighs more than the combined weight of a single spent fuel assembly and its associated handling tool. For reference, the weight of a spent fuel ossembly and its handling tool et Vermont Yankee is opproximately 800 lbs.

2 Three Storage Pool Plugs weigh 28 fons each; one weighs 43.5 tons.

3 0.P.1200," Preparation of the Reactor Vessel for Refueling" O.P.1201," Assembly of the Reactor and Drywell Systems" 4 Two Shield Blocks are 71.5 tons each; two are 67 tons each, and two are 64 tons each.

5 M - Reactor Building Crone main hoist, i10 ton capacity.

A - Reactor Building Crone auxiliary hoist,7 ton capacity.

6 R.P. 2200, " Operation of the Reactor Building and Turbine Building Bridge Cranes."

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ITEM 3.d Verification that lif ting devices identified in 2.l.3-3, above, comply j with the requirements of ANS! NI4.6-1978 or ANSI B30.9-1971 os appropriate.  !

For lif ting devices where these standards, as supplemented by NUREG 0612, Section 5.1.l(4) or 5.1.l(5), are not met, describe any proposed alternatives and demonstrate their equivalency in terms of load-handling reliability.

RESPONSE: With regard to special lif ting devices, there are thrce identified in item 3.c above that are used in lif ts over an open reactor vessel. These special lif ting devices are:

1) Dryer and Separator Sling Assembly

2) Head Strongback

3) Service Plotform Sling The only other special lif ting device of concern are lifting yokes for spent fuel shipping casks. As required by license amendment 29, Vermont Yankee must submit to the NRC details on cask yoke lifting device design prior to any cask l handling operations.

Description of Dryer and Separator Sling The dryer and separator sling is used te remove and install the dryer and the steam separator assembly. The device is a cruciform steel frame attached to a hook box by f

four wire ropes with turnbuckles. The four ends of the

! cruciform frame are each fitted into a bell-shaped housing which is open and flored at the bottom. A hole posses through

two sides of the housing for ine lif ting pin travei. Each lif ting pin is actuated by a double-acting air piston. The lifting pin,in turn, actuates on air volve at the end of th~e pin's travel. This air volve gives positive indication by way of a pressure gauge l

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that the lif ting pin is fully inserted into the dryer cnd separator lif ting lug. A lif ting eye, located on top of each I-beam, is I connected to o turnbuckle and a wire rope. The wire ropes are attached to the hook box by spelter sockets and pins. The book box contains a slot at the top which is sized to occommodate the double hook of the crane. Two hook pins pass through the hook box to engage the double hook of the crone.

Description of the Head Strongback The head strongback is used to hoist the drywell head and the reactor vessel head. The device consists of four lif ting arms mounted at right ongels between top and bottom four-point stor plates. The top plate has a slot through which the double hook of the crone posses to engage the two hook pins. The strongback is attached to lif ting lugs on the drystell head and reactor vessel head, and to lif ting lugs at the end of each arm of the strongback, by turnbuckles and anchor shock-les.

Description of the Service Platform Sling The service platform sling is used to hoist the service platform into place over the reactor vessel flonge. The sling is a three-leg wire rope sling with a turnbuckle in one of the legs. The three legs a e gathered to a master link. A load hook is fostened to each end of the three legs for attachment to three lif ting brackets on the service plotform.

The dryer / separator sling assemtiy and the ead strongback were evoluoted against ANSI N14.6. The service platform sling was compared to ANSI B30.9.

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Other special and general purpose slings are covered by criteria odded to load I

handling procedures that meet the intent of ANSI B30.9 for sling selection and use os well as inspection and maintenance. The evoluotion of the service platform sling design, inspection, and maintenance found that it complied with ANSI B30.9 with no deviations or exceptions.

For the reasons listed below, the detailed comparison of the dryer / separator sling assembly and the head strongback to ANSI N14.6-1978 was limited to Sections 3.2 and 5 of the standard.

1) These devices were designed by General Electric Company prior to the existene of ANSI N14.6-1978. In this regard, there are o number of sections in the standard that are difficult to apply in retrospect. These are the sections entitled, Designer's Responsibilities (Section 3.1);

Design Considerations (Section 3.3); Fabricator's Respon-sibilities (Section 4.1); Inspector's Responsibilities (Sec-tion 4.2); and Fabrication Considerations (Section 4.3).

Because documentation is not available to assure that all of the subparts of these sections were met, they have not been addressed item by item for the purpose of identify-ing and justifying exceptions. However, information on the drawings kdicate that sound engineering practices were placed on the fabricator and inspector by the designer for the purpose of assuring that the designer's intent was accomplished. On this basis, there is reason-able assurance that the intent of the sections of the standard listed above was, in fact, accomplished in the design, fabrication, inspection, and testing of these devices.

2) Section 1.0, Scope; Section 2.0, Definitions; Section 3.4, Design Considerations to Minimize Decontamination l

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Effects ia Special Lifting Device Use; Section 3.5, Coatings; and Section 6, Lubricants are not pertinent to load handling reliability of the devices and, there-fore, have not been addressed for the purpose of identi-fying and justifying exceptions.

3) Section 6, Special Lifted Devices for Critical Ioads, is applicable to critical loads. A critical load is d dined in the standard as:

"Any lifted load whose uncontrolled novement or release could adversely affect any safety related system when such system is required for unit safety or could result _in potential offsite exposures conparable to the guideline -

exposures outlined in Code of Federal Regula-tions, Title 10, Part 100."

None of the loads lifted by the devices identified above have as yet been determined to be a critical load. Such f a determination dd require an analysis of the conse-quences of various load drop scenarios. Since such analyses have not been performed, this information cannot be provided, and, accordingly, applied to Section 6 of ANSI 14.6-1978 of their designated lifting devices.

The detailed comparison of the dryer / separator sling and head strong-back to Section 5 of ANSI N14.6-1978, as supplemented by NUREG 0612, Section 5.1.l(4), has been completed. This cmparison found that cer-tain changes to Vermont Yankee procedures were required in order to meet the intent of the inspection and test requirenente of iGI N14.6.

With regard to verifying continuing empliance, Section 5.3 of ANSI N14.6-1978 requires load testing to 1507. of the maxinum load followed by a visual 20

examination for defects and on inspection for permanent deformation; or, os on alternative, the load testing may be omitted, and dimensional testing, visual inspection, and nondestructive inspection and major iood-corrying welds and critical areas shall suffice.

Load testing to !50% of,the maximum load may not be practical for on operating plant. Therefore, o detailed program of inspections and examinations has been prepared. The component parts, including weldments, that will be inspected or examined are shown on Tables 3 through 5. These examinations and inspections will be conducted on a one-time basis prior to our 1983 refueling outage.

Following that inspection, our program will be adjusted accordingly. !n addition, operating personnel shall conduct a thorough visual examination of the devices prior to each use for indications for domoge or deformation.

If major repairs or offerations are performed, then the device will be subjected to the 150% load test followed by visual examinations for defects cnd on inspection for permanent deformation as specified in Section 5.3.2 of ANSI N 14.6- 1978. -

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TABLE 3 TESTING TO VERIFY CONTINUING COMPLIANCE DRYER AND SEPARATOR SLING Port Type of Examination

1. Hook Box I Visual examination of ports and welds.

2. MT of welds, sling attachment lugs, and area around hook pin holes.

3. Visual examinution of pin holes and picte area around pin holes.

i. Hook Pins 1. Visual examination.

2. UT

3. Wire Rope Slings I. Visual examihation (see Note 4 below for acceptance criteria).

2. MT of open spelter sockets and socket pins, and M.T. of tapered sleeve end and end thimble.

3. Visual examination of socket.

4. Turnbuckles 1. Visual examination.

2. MT of turnbuckle body, threaded jaw end fittings, and bolts.

3. Vismi examinati.>n of jou ends, bolts, and body of turnbuckle.

S. Cross I-Beams I. Visual examination, including all welds.

2. MT of welds.

3. Visual examination of specing between lif ting lugs, center to center.

6. Lif ting Eye at End of Each I-Beam 1. Visual examination, including weldment to I-Beam.

2. MT of lif ting eye and welds.

TABLE 3 (continued)

Port Type of Examination

7. Bell-Shaped Housing 1. Visual examination, including welds.

2. MT of welds of lif ting pin plates.

3. Visual examination of pin plates.

8. Lif ting Pins 1. Visual examination.

2. UT (or MT).

3. Functional test of entire air-operated mechanisms.

9. Litting Bar on Steam Dryer / Separator I. Visual examination.

NOTES

1. Visual examination s"Il be o thorough inspection for deterioration, corrosion, or deformation.

2. Visual examination of pins shall be for warpage.

3. Visual examination of plates, socket ends, lugs, eyes, and turnbuckles shall be for circularity of pin holes and for reduction in cross-sectional arco around pin holes.

4. Visual examination of wire rope slings shall be made to determine if there are any broken wires; worn or scraped outside wires; evidence of heat domoge, corrosion of rope or end ottochments; deformed or twisted hooks; kinking, crushing, bird enging, or other domoge resulting in distortion of the rope structure.

5. Functional test of lif ting pins shall be mode to verify full travel of pins and operation of air relay volve and pressure gauge.

TABLE 4 TESTING TO VERIFY CONTINUING COMPLIANCE HEAD STRONGBACK Pact Type of Examination

1. Hook Box 1. Visual examination of ports, including welds.

2. MT of centerplates and weldments to lif ting arms.

3. Visual examination of plates and pin holes.

2. Hook Pins I. Visual examination.

2. UT.

3. Lif ting Arms 1. Visual examination, including all weldments.

2. MT of all weldments of top, bottom, and center plates; otso, MT of entire surface of lifting lugs.

3. Visual examination of lif ting lugs and pin holes in lugs.

4. Anchor Shockles 1. Visual examination.

2. MT.

3. Visual examination of shackle pin hole and cross-sectional area around the pin hole.

, 5. Turnbuckles I. Visual excmination.

2. MT, including body of turnbuckle and Breaded jaw ends.

3. Visual examination of pin holes in jaw eid, body of turnbuckle, and threaded shanks.

6. Shockle Pins (all) or Bolts I. Visual examination.

2. UT.

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TABLE 4 (continued)

Part Type of Examination

7. Drywell Head Lif ting Lugs and I. Visual examination, including welds.

Reactor Vessel Head Lif ting Lugs 2. MT of logs and welds.

3. Visual examination of pin hole and area around pin hole.

NOTES:

1. Visual examination of ports shall be a thorough inspection for deterioration, corrosion, oral deformation.

2. Visual examination of pins shall be for warpage.

3. Visual examination of plates, lugs, and shackles shall be for circularity of pin holes and reduction in cross-sectional area around pin holes.

TABLE 5 i

TESTING TO VERIFY CONTINUING COMPLIANCE SERVICE PLATFORM LIFTING SLING Port Type of Examination

1. Service olatform 1. Visual examination of all attached parts such as guard rails, drive wheel assemblies, idler wheel, etc. for looseness.

2. Service Plotform Sling I. Visual examination. (See Note 3 below for acceptance criteria).

2. MT of end ottochments, shackles, books, shackle pins, and turnbuckle. .

3. Visual examination of end ottochments, shackles, books, shockle pins, and turnbuckle.

3. Lif ting Brockets on Service Plotform 1. Visual examination.

2. MT of lif ting brackets and weldment to plotform beams.

3. Visual examination of brackets for deformaticsn.

NOTES:

1. Visual examination shall be o thorough inspection of port (s) for deterioration, corrosion, and deformation.

2. Visual examination of pins shall be for worpage. Dimensional examination of shockles and hooks shall be for circularity of pin holes and for reduction of cross-sectional area around pin hoics.

3. Visual examination of wire rope slings shall be made to determine if there are any broken wires; worn or scraped outside wires; evidence of heat domoge; corrosion of rope or end ottochments; deformed or twisted hooks; kinking, crushing, bird coging, or other domoge resulting in distortion of the rope structure.

ITEM 3.e. Verification that ANS! B30.2-1976, Chapter 2-2, has been involted with respect to crane inspection, testing, and maintenance. Where any exception is taken to this standard, sufficient information should be provided to demon-strate the equivalency of proposed alternatives.

RESPONSE: A new procedure for inspection, testing, and maintenance of the reactor building crane has been developed. This procedure is " Maintenance and Inspection Procedure for the Reactor Guilding Crone." In addition, minor modifications were made to the crane operation procedure, R.P. 2200, " Opera-tion of the Reactor r uilding and Turbine Building Bridge Cranes," to include further oppropriate operator inspections prior to load movement. With the revisions and modifications, the procedures meet the intent of the criterio in ANSI B30.2-1976, Chapter 2-2.

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ITEM 3.f. Verification thct crane design complies with the guidelines of CMAA '

Specification 70 and Chapter 2-I of ANSI B30.2-1976, including the demonstro-tion of equivalency of actual design requirements for instances where specific compliance with these standards is not provided.

RESPONSE: The Reactor Building Crane was modified in 1976 to satisfy the requirernents of APCSB BTP 9-I which subsequently become NUREG 0554. The modifications included replacement of the trolley with one that has dual lood paths on the main hoist. The criteria in BTP 9-1 colled for the crone to be designed and fabricated to a number of industry ctandards, including ANSI B30.2 and CMAA-70. On December 301975, Vermont Yankee submitted to the NRC o report entitled, " Reactor Buildin; Crane Modification," that described how the criteria of BTP 9-1 were satisfied fo- this crone. This information was reviewed and opproved by the NRC, as described in the staff's safety evoluotion report transmitted by letter of January 28,1977 from R. Reid (NRC) to R. Groce (Yonkee Atomic). Based on this previous review, we believe that for the Vermont Yankee Reactor Building Crone it is not necessary to reevoluote the crane design since conformance with the criteria of ANSI B30.2, CMAA-70, and other provisions of BTP 9-1 was addressed in the previws review.

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

RESPONSE: Certain general criteria for the qualification and training Reactor Building of crane operators are contained in R.P. 2200, " Operation of the-Reactor Building and Turbine. Building Bridge Cranes." These criteria are supplemented by guidance provided in on internal memorandum listing topics to be covered in the crone operator training course. These topics uce essentially identical to the provisions of ANSI B30.2-1976, Chapter 2-3. This general directive is being implemented at Vermont Yonkee, although it is not in the form of on opproved porocedure. This training and examination of prospective l

operatort is performed by the Maintenance Supervisor or his designated alter-note.

The current procedures were reviewed against the provisions of ANSI B30.2-l 1976, Chapter 2-3, and a number of mi; or changes were found necessary in order for the current program to satisfy ANSI B30.2, Chapter 2-3 requirements. In addition, a new procedure with qualification records has been developed in order to formalize the program for crone operator training.

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