- , - . - - . . - - . - - - . . - - . . . . _, ' .' Northeast 107 seiden street, Berlin, cr 06037 Utilities System yo,,3,,, Utuitw service company . , P.O. Box 270 llartford, CT 06141-0270.- (203) 665-5000 i MAY l 01996 i- I Docket Nos. 50-213 50-245 50-336 50-423 i 50-443 * l B15682 : i U. S. Nuclear Regulatory Commission ! EAttention: Document Control Desk Washington, DC 20555-0001 ' , Haddam Neck Plant ; Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3 Seabrook Station ; Response to Bulletin 96-02 ; i 1 , Connecticut Yankee Atomic Power Company (CYAPCO) on behalf of the i , Haddam Neck Plant, Northeast Nuclear Energy Company (NNECO) on i behalf of Millstone Nuclear Power Station Unit Nos. 1, 2, and 3, and North Atlantic Energy Service Corporation (North Atlantic) on behalf of Seabrook required response to NRC Bulletin 96-02, gation hereby provide" Movement of Heavy Loads Over Spent F 4 over Fuel in the Reactor Core, or Over Safety-Related Equipment." NRC Bulletin 96-02 was issued on April 11, 1996, to provide ' notification of the importance of complying with existing j regulatory guidelines associated with the control and handling of , i heavy loads at nuclear power plants while the plant is operating (in all modes other than cold shutdown, refueling, and defueled) ! and remind licensees of their responsibilities for ensuring that i heavy load activities . carried out under their license are , performed safely and within the requirements specified under Title 10 of the Code of Federal Regulations. Additionally, the L Bulletin. requested licensees to review their plans and capabilities for handling heavy loads (e.g., spent fuel dry storage casks,. reactor cavity biological shield blocks) in . accordance mith~ existing regulatory guidelines (specifically . ! NUREG-0612 (Phase I) and Generic Letter 85-11) and within their .U.S. -Nuclear Regulatory Commission Bulletin 96-02 to |- M Addressees, " Movement of Heavy Loads Over Spend Fuel, Over . Fuel in the Reactor Core, or Over Safety-Related Equipment," ' i datedLApril 11, 1996., 9605140274 960510 PDR ADOCK 05000213 O PDR _" 140087 , p e s
Transcript
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'
.' Northeast 107 seiden street, Berlin, cr 06037
Utilities System yo,,3,,, Utuitw service company. ,
P.O. Box 270llartford, CT 06141-0270.-
(203) 665-5000
i MAY l 01996i-I Docket Nos. 50-213
50-24550-33650-423
i 50-443 *
l B15682:
iU. S. Nuclear Regulatory Commission
! EAttention: Document Control DeskWashington, DC 20555-0001
'
,
Haddam Neck Plant ;
Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3Seabrook Station ;
Response to Bulletin 96-02 ;
i1 ,
Connecticut Yankee Atomic Power Company (CYAPCO) on behalf of the i, Haddam Neck Plant, Northeast Nuclear Energy Company (NNECO) oni behalf of Millstone Nuclear Power Station Unit Nos. 1, 2, and 3,
and North Atlantic Energy Service Corporation (North Atlantic) onbehalf of Seabrook required response toNRC Bulletin 96-02, gation hereby provide" Movement of Heavy Loads Over Spent Fuel,4
over Fuel in the Reactor Core, or Over Safety-Related Equipment.".
NRC Bulletin 96-02 was issued on April 11, 1996, to provide'
notification of the importance of complying with existing
j regulatory guidelines associated with the control and handling of,
i heavy loads at nuclear power plants while the plant is operating(in all modes other than cold shutdown, refueling, and defueled)!
and remind licensees of their responsibilities for ensuring that i
heavy load activities . carried out under their license are ,
performed safely and within the requirements specified underTitle 10 of the Code of Federal Regulations. Additionally, the
L Bulletin. requested licensees to review their plans andcapabilities for handling heavy loads (e.g., spent fuel drystorage casks,. reactor cavity biological shield blocks) in
| licensing basis as previously analyzed in the final safetyi analysis report. Further, it required licensees to report to the! NRC whether and to what extent they have complied with the: requested actions contained in the Bulletin. The requiredI actions are applicable to both boiling-water reactor andi pressurized-water reactor operating licenses for nuclear powerj reactors.;
j' CYAPCO, NNECO, and North Atlantic have responded to and compliedj with the requested actions contained in this Bulletin. ;
Attachments 1 through 5 provide detailed responses to each of thei
! requested actions contained in Bulletin 96-02, for the Haddam 1
| Neck Plant, Millstone Nuclear Power Station Unit Nos. 1, 2, andj 3, and Seabrook Station, respectively. Attachment 6 contains newi commitments for each of the units pertaining to the movement of
heavy loads and associated actions as required by Bulletin 96-02.;
)'
Should you have any questions regarding this matter, please
i contact Mr. W. J. Temple, Nuclear Licensing Supervisor, Millstone' Unit 3, at (860) 437-5904.ii
Very truly yours,,
! CONNECTICUT YANKEE ATOMIC POWER COMPANY
! NORTHEAST NUCLEAR ENERGY COMPANYj NORTH ATLANTIC ENERGY SERVICE CORPORATION
i
I 9
| F. R. Q6cimp 'U; Vice President - Nuclear Operations
i
i
! *
I cc:!
'j T. T. Martin, Region I AdministratorS. Dembek, NRC Project Manager, Haddam Neck PlantJ. W. Andersen, NRC Project Manager, Millstone Unit No. 1
| D. G. Mcdonald Jr., NRC Project Manager, Millstone Unit No. 2V. L. Rooney, NRC Project Manager, Millstone Unit No. 3
i A. W. De Agazio, NRC Project Manager, Seabrook Station| W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant
T. A. Easlick, Senior Resident Inspector, Millstone Unit No.1,
: P. D. Swetland, Senior Resident Inspector, Millstone Unit No.2A. C. Carne, Senior Resident Inspector, Mille'one Unit No.3'
J. B. Macdonald, Senior Resident Inspector, _;abrook Station1
4 W. D. Lanning, Director, Millstone Oversight TeamW
The following provides the Haddam Neck Plant response toBulletin 96-02:
Required Action 1
For licensees planning to implement activities involvinghandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment within the next 2 yearsfrom the date of this. bulletin, provide the following:
A report, within 30 days of this bulletin, that addresses*
the licensee's review of its plan and capabilities tohandle heavy loads while the reactor is at power (in allmodes other than cold shutdown, refueling, and defueled)in accordance with existing regulatory guidelines. Thereport should also indicate whether the activities arewithin the existing regulatory guidelines. The report
should also indicate whether the activities are withinthe licensing basis and should include, if necessary, a
;schedule for submission of a license amendment request.-
| Additionally, the report should indicate whether changes! to Technical Specifications will be required.
| Response 1<
1
| There are currently no plans to perform activities which
| involve the handling of heavy loads over spent fuel, fuel inthe reactor core, or safety-related equipment at the Haddam
,
j Neck Plant within the next 2 years while the reactor is at; power. All activities will be performed under the existingI NUREG 0612 guidelines. A review of plant procedures (MCM
2.2-8, " Control of Heavy Loads," and WCM 2.2-9, " Control of
; Mobile Crane Activities,") governing the control of heavyloads indicates that the Haddam Neck Plant is in compliancewith the existing regulatory guidelines, and that the
planned activities are within the current licensing basis'
| and do not require a license amendment request.t
|
!
L _ _ -- --- _ _ _ _ _ _ ._ _ _ _ .
_ _______ _ _
,
. .
.
4
Reauired Action 2
For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower (in all modes other than cold shutdown, refueling, anddefueled) and that involve a potential load drop accidentthat has not been evaluated in the FSAR, submit a licenseamendment request in advance (6-9 months) of the plannedmovement of the loads so as to afford the staff sufficienttime to perform an appropriate review.
Response 2
CYAPCO is currently in the process of performing a rarack inthe spent fuel pool. This activity has been reviewed andapproved by the NRC Staff. The NRC issued License AmendmentNo. 188 to DPR-61 to perform this work. Furthermore, CYAPCOhas no current plans to perform activities which involve thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment at the Haddam Neck Plantwhile the reactor is at power, which involve a potentialload drop accident that has not been evaluated in the FSAR.
.
{Recuired Action 3
1
! For licensees planning to move dry storage casks over spent
! fuel, fuel in the reactor cc,re, or safety-related equipment; while the reactor is at power (in all modes other than cold
| shutdown, refueling, and defueled) include in item 2 above,
| a statement of the capability of performing actions
: necessary for safe shutdown in the presence of radiologicalj source term that may result from a breach of the. dry storage
cask, damage to the fuel, and damage to safety-relatet'
equipment as a result of a load drop inside the facility.
|
|Response 3
1
; There are currently no plans to move dry storage casks overspent fuel, fuel in the reactor core, or safety-related 1
.
| equipment at the Haddam Neck Plant while the reactor is at
For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower (in all modes other than cold shutdown, refueling,
and defueled), determine whether changes to Technical'
| Specifications will be required in order to allow the! handling of heavy loads (e.g., the dry storage canister1 shield plug) over fuel assemblies in the spent fuel pool and
subait the appropriate information in advance (6-9 months)4
of the planned movement of~the loads for NRC review and,
approval.
f Response 4:
). There are currently no plans at the Haddam Neck Plant fornew " Heavy Loads" movements which would require Technical,
Specification changes.
j Lona Term Activities
i
There are currently no long term activities plannedinvolving heavy loads for the Haddam Neck Plant that have
! not been previously addressed. Any activities that mayarise will be reviewed against the appropriate regulatoryguidance to ensure compliance.
The following provides the Millstone Unit 1 response toBulletin 96-02:j
!
f Reauired Action 1!,
For licensees planning to implement activities involving
| handling of heavy loads over spent fuel, fuel in the reactorj core, or safety-related equipment within the next 2 years
{ from the date of this bulletin, provide the following:!2
A report, within 30 days of this bulletin, that addresses|*
j the licensee's review of its plan and capabilities tohandle heavy loads while the reactor is at power (in all
.
| modes other than cold shutdown, refueling, and defueled)i in accordance with existing regulatory guidelines. The
j report should also indicate whether the activities are |
j within the existing regulatory guidelines. The report |
i should also indicate whether the activities are withinj the licensing basis and should include, if necessary, a! schedule for submission of a license amendment request.
| Additionally, the report should indicate whether changes
| to Technical Specifications will be required.;
Response 1,
!i Millstone Procedure MP 790.4, " Control of Heavy Loads,"' defines the safe load paths to be used in the reactor,
j building and the intake structure and the qualifications of! personnel conducting movement of heavy loads at Millstone
Unit 1. This procedure is based upon NNECO submittals madejto the NRC in response to the unnumbered generic letter
,~
dated December 22, 1980, " Control of Heavy Loads." Thisprocedure follows the " defense in depth" philosophy ofNUREG-0612 to ensure safe handling of heavy loads, and is.
i therefore in accordance with existing regulatory guidelinesand the licensing basis. Millstone Unit 1 will review
I current procedures and evaluate practices with respect tothe use of mobile cranes lifting heavy loads in NUREG-06124
; safety-related equipment areas, prior to using mobile c m esduring power operation.;
| There are currently no plans to perform activities whichinvolve the handling of heavy loads over spent fuel or fuel
! in the reactor core at Millstone Unit 1 within the next 2i years while the plant is operating, with the exception of
the Millstone Unit 1 storage capacity expansion (reracking)as described in Response 4 as Future Spent Fuel Activities.
I There are planned work activities to be performed on the
i operating floor (elev. 10 8 ' -6" ) of the Unit i reactor
j building that will involve handling of heavy loads overj safety-related equipment. The work activities include the
movement of a radwaste cask and liner to support spent fuel.
j pool cleanup. A review of the plant procedures governing thej control of heavy loads confirms that Millstone Unit 1 is in
compliance with the existing regulatory guidslines, and that'
j the planned activities are within the current licensingbasis and therefore do not require a change to the Operatingi
j License or to the Technical Specifications.
|Reauired Action 2j
For licensees planning to perform activities involving the
| handling of heavy loads over spent fuel, fuel in the reactorj core, or safety-related equipment while the reactor is atj power (in all modes other than cold shutdown, refueling, andi defueled) and that involve a potential load drop accident
| that has not been evaluated in the FSAR, submit a license
; amendment request in advance (6-9 months) of the plannedmovement of the loads so as to afford the staff sufficient-
i time to perform an appropriate review.!
f Response 2
There are currently no plans to perform activities whichinvolve the handling of heavy loads over spent fuel, fuel in,
the reactor core, or safety-related equipment at Millstonei Unit I while the reactor is at power which involve a
| potential load drop accident that has not been evaluated in; the FSAR. Load drop analyses are currently being performed
for a spent fuel pool gate drop and a new fuel assembly loadi drop onto irradiated fuel assemblies. These analysis are| being performed due to lifting operations which occurred
during operating cycle 15. The above load drop analyses are
( corrective actions which were previously identified inLicense Event Reports, (LER) 96-016-00, " Heavy LoadsjSuspended Over Irradiated Fuel in the Spent Fuel Pool," andi
|
|
!i
|
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. .
l
LER 96-023-00, " Movement of New Fuel Assemblies Over theSpent Fuel Pool Resulted in a Condition Outside the Design|
| Basis."i,
j Required Action 3
i
| For licensees planning to move dry storage casks over spent
! fuel, fuel in the reactor core, or safety-related equipment
! while the reactor is at power (in all modes other than cold
! shutdown, refueling, and defueled) include in item 2 above,
! a statement of the capability of performing actionsj necessary for safe shutdown in the presence of radiologicalj source term that may result from a breach of the dry storage
cask, damage to the fuel, and damage to safety-related<
equipment as a result of a load drop inside the facility..'
Response 3
)There are currently no plans to move dry storage casks overspent fuel, fuel in the reactor core, or safety-relatedequipment at Millstone Unit 1 while the reactor is at power.,
i
i Required Action 4,
! !
I For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactor i
core, or safety-related equipment while the reactor is at 1
I; power (in all modes other than cold shutdown, refueling,
| and defueled), determine whether changes to Technical
Specifications will be required in order to allow the |handling of heavy loads (e.g., the dry storage canister |
1 shield plug) over fuel assemblies in the spent fuel pool and
! submit the appropriate information in advance (6-9 months) ;
j of the planned movement of the loads for NRC review and |approval. |
I|Response 4<
There are currently no plans to move heavy loads over spentfuel, fuel in the reactor core, or safety-related equipment
I at Millstone Unit 1 while the reactor is at power, with theexception of the Millstone Unit 1 storage capacity expansion
j (reracking). Based on preliminary engineering reviews fori the raracking project, no Technical Specifications changes j
pertaining to the handling of heavy loads are anticipated.4
If any Technical Specifications. changes are required, they j'
will be submitted 6 to 9 months in advance of the plannedmovement of the loads.
Future Spent Fuel Activities
The long term spent fuel storage needs of Millstone Stationwill result in several future initiatives, including spentfuel pool raracking and possibly inter-unit spent fuel
transfer. While these projects will likely be implementedmore than two years after issuance of NRC Bulletin 96-02, apreliminary discussion is provided.
Preliminary engineering work has begun on an inter-unitspent fuel transfer capability at Millstone Station. This
project will enable spent fuel transfer from the Unit 1 and2 spent fuel pools to the Unit 3 spent fuel pool. Heavyload issues, including cask drop analysis at each unit willbe included in this effort. The current schedule for thefirst spent fuel transfer campaign will take place some timeafter the year 2001.
The Millstone Unit 1 and Unit 3 spent fuel pools willrequire storage capacity expansion (raracking) in the
future. For Millstone Unit 1, a license amendment submittal'
| to address rerack implementation is scheduled to be; submitted prior to Refuel Outage No. 16. The actual
|schedule for this project is predicated on plant restart. |
f MILLSTONE UNIT 2| RESPONSE TO NRC BULI2 TIN 96-02
.
'
!!
tThe following provides the Millstone Unit 2 response to
| Bulletin 96-02:
!
| Reauired Action 1
!
I For licensees planning to implement activities involvinghandling of heavy loads over spent fuel, fuel in the reactor
!core, or safety-related equipment within the next 2 yearsfrom the date of this bulletin, provide the following:;
!A report, within 30 days of this bulletin, that addresses*
!
j the licana,ee's review of its plan and capabilities to! handle heavy loads while the reactor is at power (in all: modes other than cold shutdown, refueling, and defueled)1
|in accordance with existing regulatory guidelines. The
j report should also indicate whether the activities arei within the existing regulatory guidelines. The report
: should also indicate whether the activities are within
!. the licensing basis and should include, if necessary, a! schedule for submission of a license amendment request.
| Additionally, the report should indicate whether changesto Technical Specifications will be required.
; Response 1
!i Millstone Procedure MP 2712B1, " Control of Heavy Loads,"i defines the safe load paths to be used in the containment
, and auxiliary building, and also defines the qualification
} of personnel conducting movement of heavy loads at Millstone| 2. This procedure is based upon NNECO submittals made toj the NRC in response to the unnumbered generic letter dated
i December 22, 1980, " Control of Heavy Loads." This procedurefollows the " defense in depth" philosophy of NUREG-0612 to"
I ensure safe handling of heavy loads, and is therefore in: accordance with existing regulatory guidelines and thei licensing basis. Millstone Unit 2 does not use mobile cranesi in these areas and there is no procedure for such use. Usej of mobile cranes for other safety-related equipment wasi considered to be safe based on design redundancy. This was
accepted in the NRC SER on NNECO's NUREG 0612 Phase Ireview.
There are currently no plans to perform activities whichinvolve the handling of heavy loads over spent fuel, fuel inthe reactor core or safety related equipment at MillstoneUnit 2 within the next 2 years while the reactor is atpower. If required, activitics involving heavy loads in theauxiliary building will be performed in accordance with theabova procedure.
Based on the above, no changes to the Millstone Unit 2license or Technical Specifications are required.
Recuired Action 2
For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower (in all modes other than cold shutdown, refueling, anddefueled) and that involve a potential load drop accidentthat has not been evaluated in the FSAR, submit a licenseamendment request in advance (6-9 months) of the plannedmovement of the loads so as to afford the staff sufficienttime to perform an appropriate review.
Response 2
i 1
There are currently no plans to perform activities whichj involve the handling of heavy loads over spent fuel, fuel in
the reactor core or safety related equipment at Millstonei
i Unit 2 while the reactor is at power. If required,
} activities involving heavy loads in the auxiliary building} will be performed in accordance with procedure MP 2712B1,
" Control of Heavy Loads."
The Millstone Unit 2 FSAR does not specifically addressa
i potential load drop accidents other than the cask drop inthe spent fuel pool. Typical activities involving movement,
'of heavy loads at Millstone Unit 2 were previously evaluated
! by the NRC during the NUREG-0612'" Phase I reviow and arei
|
:,
'"
| U.S. Nuclear Regulatory Commission letter to W. G.| Counsil, " Control of Heavy Loads (Phase I ) for
considered to be within the plant's licensing basis.
| Therefore, no license amendment requests are planned.!
! Required Action 3
|[ For licensees planning to move dry storage casks over spent
fuel, fuel in the reactor core, or safety-related equipment;
] while the reactor is at power (in all modes other than coldi shutdown, refueling, and defueled) include in item 2 above,; a statement of the capability of performing actions
i necessary for safe shutdown in the presence of radiological !
I source term that may result from a breach of the dry storage I
cask, damage to the fuel, and damage to safety-related l'
| equipment as a result of a load drop inside the facility.;
Response 3.
! There are currently no plans to move dry storage casks overi spent fuel, fuel in the reactor core, or safety-related
equipment at Millstone Unit 2 while the reactor is at power.f
| Reauired Action 4
For licensees planning to perform activities involving the; handling of heavy loads over spent fuel, fuel in the reactor; core, or safety-related equipment while the reactor is at
| power (in all modes other than cold shutdown, refueling,
j and defueled), determine whether changes to Technical; Specifications will be required in order to allow thei handling of heavy loads (e.g., the dry storage canister
shield plug) over fuel assemblies in the spent fuel pool andsubmit the appropriate information in advance (6-9 months);
{ of the planned movement of the loads for NRC review and
] approval.1
! Response 4i:!
There are currently no plans to move heavy loads over spent,
| fuel or fuel in the reactor core at Millstone Unit 2 whilethe reactor is at power. Therefore, changes to theMillstone Unit 2 Technical Specifications are not necessary.
Future Spent Fuel Activities
i
The long term spent fuel storage needs of Millstone Stationwill result in several future initiatives, including spent
] fuel pool raracking and possibly inter-unit spent fuel
transfer. While these projects will likely be implementedmore than two years after issuance of NRC Bulletin 96-02, apreliminary discussion is provided.
Preliminary engineering work has begun on a inter-unit spentfuel transfer capability at Millstone Station. This projectwill enable spent fuel transfer from the Millstone Unit 1and 2 spent fuel pools to the Millstone Unit 3 spent fuelpool. Heavy load issues, including cask drop analysis ateach unit will be included in this effort. The currentschedule for the first spent fuel transfer campaign willtake place some time after the year 2001.
ii MILLSTONE UNIT 3i RESPONSE TO NRC BULLETIN 96-02
|
The following provides the Millstone Unit 3 response toBulletin 96-02:
|,
Reauired Action 1;1
| For licensees planning to implement activities involving
| handling of heavy loads over spent fuel, fuel in the reactor;' core, or safety-related equipment within the next 2 years! from the date of this bulletin, provide the following:
k
A report, within 30 days of this bulletin, that addresses*
the licensee's review of its plan and capabilities to |
| handle heavy loads while the reactor is at power (in allmodes other than cold shutdown, refueling, and defueled)in accordance with existing regulatory guidelines. Thereport should also indicate whether the activities arewithin the existing regulatory guidelines. The report
should also indicate whether the activities are withinthe licensing basis and should include, if necessary, aschedule for submission of a license . amendment request.Additionally, the report should indicate whether changesto Technical Specifications will be required.
Response 1
There are currently no plans to perform activities whichinvolve the handling of heavy loads over spent fuel or fuelin the reactor core, or safety-related equipment at
Millstone Unit 3 within the next 2 years while the reactoris at power that are not within our present licensing basisor that require a license amendment request. A review ofthe Millstone Unit 3 procedures governing " control of HeavyLoads" while the reactor is at power will be conducted bythe end of 1996.
Activities involving heavy loads over safety-relatedequipment while the reactor is at power are anticipated atMillstone Unit 3 within the next two years. Typicalactivities include moving concrete floor plugs, new fuelcasks, and weights needed for load testing of cranes
i required for these activities. These activities are within'
the licensing basis, and will be conducted in accordance;
j with plant procedures and existing regulatory guidelines,i specifically, NUREG 0612, and Generic Letter 85-11. A
: license amendment and Technical Specification changes arej not required to perform these activities. The activities
j have been previously approved by the NRC Staff as noted in,
NUREG-1031, " Safety Evaluation Report" (SER), and SERJ Supplements 1 through 5.
j Millstone Procedure MP 3704B, " Control of Heavy Loads,"j controls the lifting of heavy loads at Millstone Unit 3
consistent with NUREG 0612. This procedure defines the safe:
] load paths to be used in the containment, fuel building, andi engineered safety features (ESF) building. Millstone Unit 3
] will review current procedures and evaluate practices with
1 respect to the use of mobile cranes lifting heavy loads in
| NUREG-0612 areas by the end of 1996.!
No changes to the Millstone Unit 3 Technical Specifications*
are expected as a result of the above resolutions.
Reauired Action 2
i For licensees planning to perform activities involving theI handling of heavy loads over spent fuel, fuel in the reactor
| core, or safety-related equipment while the reactor is atI power (in all modes other than cold shutdown, refueling, and: defueled) and that involve a potential load drop accidentI that has not been evaluated in the FSAR, submit a license
|amendment request in advance (6-9 months) of the planned
i movement of the loads so as to afford the staff sufficienti time to perform an appropriate review.i
i Response 2;
i
| There are currently no plans to perform activities whichinvolve the handling of heavy loads over spent fuel, fuel inthe reactor core, or safety-related equipment at Millstone
| Unit 3 while the reactor is at power which involve a; potential load drop accident that has not been previously
! identified / evaluated and found acceptable in the licensing
( basis documentation or which has been evaluated pursuant to
| 10CFR50.59 to ensure compliance with the licensing basis,commitments to the guidelines of NUREG-0612, and that no,
i unreviewed safety question is introduced. Administrative 1y,
the Millstone Unit 3 FSAR does not currently include a'
description of the activities involving the handling ofheavy loads over spent fuel, fuel in the reactor core, orsafety-related equipment while the reactor is at power. TheMillstone Unit 3 FSAR will be revised by the end of 1996, toinclude an outline of the details involved in the handling'
of heavy loads over spent fuel, fuel in the reactor core, orsafety-related equipment while the reactor is at power.
I
Reauired Action 3i
For licensees planning to move dry storage casks over spentfuel, fuel in the reactor core, or safety-related equipment
. while the reactor is at power (in all modes ot'ner than cold'
shutdown, refueling, and defueled) include in item 2 above,a statement of the capability of performing actions
necessary for safe shutdown in the presence of radiologicalsource term that may result from a breach of the dry storagecask, damago to the fuel, and damage to safety-related'
equipment as a result of a load drop inside the facility.,
4
: Response 3
!
There are currently no plans to move dry storage casks overspent fuel, fuel in the reactor core, or safety-related
equipment at Millstone Unit 3 while the reactor is at power.i
Recuired Action 4
For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower (in all modes other than cold shutdown, refueling,
.
and defueled), determine whether changes to Technical
Specifications will be required in order to allow thehandling of heavy loads (e.g. the dry storage canister
,
shield plug) over fuel assemblies in the spent fuel pool andsubmit the appropriate information in advance (6-9 months)of the planned movement of the loads for NRC review and
j approval.
IResponse 4
There are currently no plans to move heavy loads over spentfuel, fuel in the reactor core, or safety-related equipmentat Millstone Unit 3 while the reactor is at power, that
require changes to the Technical Specifications. Activitieswhich require- Technical Specification changes will bei
submitted for NRC review and approval in advance of the| planned movement.
Future Spent Fuel Activities
! The long term spent fuel storage needs of Millstone Stationwill result in several future initiatives, including spentfuel pool reracking and possibly inter-unit spent fuel
transfer. While these projects will likely be implementedmore than two years after issuance of NRC Bulletin 96-02, apreliminary discussion is provided.
Preliminary engineering work has begun on a. inter-unit spentfuel transfer capability at Millstone Station. This projectwill enable spent fuel transfer from the Millstone Unit 1and 2 spent fuel pool to the Millstone Unit 3 spent fuelpool. Heavy load issues, including cask drop analysis ateach unit will be included in this effort. The currentschedule for the first spent fuel transfer campaign willtake place some time after the year 2001.
The Millstone Unit 3 spent fuel pool will require storagecapacity expansion (reracking) in the future. The licenseamendment and rerack implementation for the Millstone Unit 3spent fuel pool is required prior to Refuel Outage No. 7which is scheduled for the spring of 1999. A preliminaryestimate, subject to actual plant restart, for the licenseamendment submittal is late 1998 to early 1999 and forimplementation in late 1999 to early 2000.
The following provides the Seabrook Station response toBulletin 96-02:
Required Action 1
For licensees planning to implement activities involvinghandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment within the next 2 yearsfrom the date of this bulletin, provide the following:
A report, within 30 days of this bulletin, that addresses*
the licensee's review of its plan and capabilities tohandle heavy loads while the reactor is at power (in allmodes other than cold shutdown, refueling, and defueled)in accordance with existing regulatory guidelines. Thereport should also indicate whether the activities arewithin the existing regulatory guidelines. The report
should also indicate whether the activities are withinthe licensing basis and should include, if necessary, aschedule for submission of a license amendment request.Additionally, the report should indicate whether changesto Technical Specifications will be required.
Response 1
North Atlantic is not planning to perform any activityinvolving the movement of heavy loads over spent fuel orfuel in the reactor core, or safety-related equipment atSeabrook Station within the next two years while the reactoris at power that is not in compliance with the licensingbasis or that requires a license amendment request or
technical specification change. Activities involving themovement of heavy loads over spent fuel or fuel in thereactor core, or safety-related equipment which have notbeen previously identified / evaluated and found acceptable inthe licensing basis documentation will be evaluated pursuantto 10CFR50.59 to ensure compliance with the licensing basis,commitments to the guidelines of NUREG-0612 and that nounreviewed safety question is introduced. For example,North Atlantic is planning to change out an ocean service
water pump with a rebuilt pump using a mobile crane with theplant at full power during the week of May 13, 1996. This'
activity involves the movement of a heavy load over safety )related equipment and has not been previously addressed inthe licensing basis documentation. Therefore, a 10CFR50.59
evaluation will be performed for this activity to addressthe aforementioned attributes.
An additional confirmatory review of the Seabrook Stationprocedures governing heavy load handling with fixed ormobile cranes while the reactor is at power will beconducted by the end of 1996 to verify compliance withNUREG-0612. North Atlantic previously documented by letter
,
dated October 31, 1985, that procedures have been developedin accordance with NUREG-0612. Seabrook Station heavy load
handling systems have been reviewed and approved by the NRCStaff and the Idaho National Engineering Laboratory asdocumented in NUREG-0896, " Safety Evaluation Report",
Supplement No. 5, dated July 1986. Licensing basis
documentation relating to compliance with the guidelines ofNUREG-0612 is identified in SER Supplement 5.
Reauired Action 2
For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower (in all modes other than cold shutdown, refueling, anddefueled) and that involve a potential load drop accidentthat has not been evaluated in che FSAR, submit a licenseamendment request in advance (6-9 months) of the plannedmovement of the loads so as to afford the staff sufficienttime to perform an appropriate review.
Response 2
North Atlantic is not planning to perform activities whichinvolve the handling of heavy loads over spent fuel, fuel inthe' reactor core, or safety-related equipment at SeabrookStation while the reactor is at power which involve apotential load drop accident that has not been previouslyidentified / evaluated and found acceptable in the licensingbasis documentation or which has been evaluated pursuant to10CFR50.59 to ensure compliance with the licensing basis,commitments to the guidelines of NUREG-0612 and that nounreviewed safety question is introduced.
| Tne Seabrook Station UFSAR does not currently include adescription of the activities involving the handling ofheavy loads over spent fuel, fuel in the reactor core, orsafety-related equipment while the reactor is at power. TheSeabrook Station UFSAR will be revised by the end of 1996,
to include an outline of the details involved in thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower.
Required Action 3
For licensees planning to move dry storage casks over spentfuel, fuel in the reactor core, or safety-related equipmentwhile the reactor is at power (in all modes other than coldshutdown, refueling, and defueled) include in item 2 above,a statement of the capability of performing actions
necessary for safe shutdown in the presence of radiologicalsource term that may result from a breach of the dry storagecask, damage to the fuel, and damage to safety-relatedequipment as a result of a load drop inside the facility.
Response 3
North Atlantic is not planning to move dry storage casksover spent fuel, fuel in the reactor core, or safety-relatedequipment at Seabrook Station while the reactor is at power.The movement of dry storage casks over the Seabrook StationSpent Fuel Pool is physically precluded due to the limitedtravel of the cask handling crane (Reference: SeabrookStation UFSAR Section 15.7.5).
Required Action 4
For licensees planning to perform activities involving thehandling of heavy loads over spent fuel, fuel in the reactorcore, or safety-related equipment while the reactor is atpower (in all modes other than cold shutdown, refueling,
and defueled), determine whether changes to Technical
Specifications will be required in order to allow the
handling of heavy loads (e.g., the dry storage canistershield plug) over fuel assemblies in the spent fuel pool andsubmit the appropriate information in advance (6-9 months)of the planned movement of the loads for NRC review andapproval.
.___ _ _____ -
_
1..
i-
.
Response 4
North Atlantic is not planning to perform any activity )!
involving the movement of heavy loads over spent fuel orfuel in the reactor core, or safety-related equipment atSeabrook Station within the next 2 years while the reactor ,
is at power that is not in compliance with the licensing {basis or that requires a license amendment request or
'
technical specification change.
I.ona Term Activitim
The Seabrook Station Spent Fuel Pool storage capacity will|i be increased to the Technical Specification limit (Reference
Seabrook Station Technical Specification 5.6.3.) with the ;
addition of six spent fuel racks during the third and fourthquarters of 1998. The racks will be installed with a cranethat is designed and operated in conformance with the
| guidelinos of NURF.G-0612. Procedures and safe load pathswill be implemented to preclude travel of heavy loads overspent fuel.
respect to the use of mobile cranes liftingheavy loads in NUREG-0612, safety-relatedequipment areas, prior to using mobile cranesduring power operation.
B15682-MP1-2 Technical Specification changes (if
necessary) for the handling of heavy loadsdue to the Millstone Unit 1 storage capacityexpansion, will be submitted 6 to 9 months inadvance of the planned movement of the loads.
B15682-SBK-1 Activities involving the movement of heavy.
1 loads over spent fuel or fuel in the reactorcore, or safety-related equipment which have
,
not been previously identified / evaluated andfound acceptable in the licensing basisdocumentation will be evaluated pursuant to10CFR50.59 to ensure compliance with the
licensing basis, commitments to the
guidelines of NUREG-0612 and that nounreviewed safety question is introduced.
B15682-SBK-2 The Seabrook Station UFSAR will be revised bythe end of 1996, to include an outline of thedetails involved in the handling of heavyloads over spent fuel, fuel in the reactorcore, or safety-related equipment while thereactor is at power.
B15682-SBK-3 An additional confirmatory review of theSubrook Station procedures governing heavyload handling with fixed or mobile craneswhile the reactor is at power will beconducted by the end of 1996 to verifycompliance with NUREG-0612.
