ML021210717

Issuance of Amendments 181 & 124, Replacing the Existing Requirement for Hydrostatic Testing of Diesel Fuel Oil System Piping,Tac Nos MB3911 & MB3915

ML021210717
Person / Time
Site:	Saint Lucie
Issue date:	04/23/2002
From:	Moroney B NRC/NRR/DLPM/LPD2
To:	Stall J Florida Power & Light Co
Moroney B, NRR/DLPM, 415-3974
References
TAC MB3911, TAC MB3915
Download: ML021210717 (12)

Text

April 23, 2002 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING REVISION TO SURVEILLANCE REQUIREMENTS FOR PRESSURE TESTING THE DIESEL FUEL OIL SYSTEM (TAC NOS. MB3911 AND MB3915)

Dear Mr. Stall:

The Commission has issued the enclosed Amendment Nos. 181 and 124 to Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Units 1 and 2. These amendments consist of changes to the Technical Specifications in response to your application dated January 25, 2002.

These amendments replace the existing requirement for hydrostatic testing of Diesel Fuel Oil System piping with the requirement to perform system pressure testing at normal operating conditions in accordance with the inservice inspection program.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Brendan T. Moroney, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389

Enclosures:

1. Amendment No. 181 to DPR-67

2. Amendment No. 124 to NPF-16

3. Safety Evaluation cc w/enclosures: See next page

ML021210717 OFFICE PDII-2/PM PDII-2/LA EMCB/SC OGC PDII-2/SC NAME BMoroney BClayton TChan SUttal TKoshy DATE 3/17/02 3/28/02 03/29/02 4/16/02 4/22/02 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-335 ST. LUCIE PLANT UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 181 License No. DPR-67

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (the licensee), dated January 25, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, Facility Operating License No. DPR-67 is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and by amending paragraph 2.C.(2) to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 181, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas Koshy, Acting Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: April 23, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 181 TO FACILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains marginal lines indicating the area of change.

Remove Page Insert Page 3/4 8-6b 3/4 8-6b

FLORIDA POWER & LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO, FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST. LUCIE PLANT UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.124 License No. NPF-16

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company, et al. (the licensee), dated January 25, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, Facility Operating License No. NPF-16 is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and by amending paragraph 2.C.2 to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 124, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas Koshy, Acting Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: April 23, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 124 TO FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains marginal lines indicating the area of change.

Remove Page Insert Page 3/4 8-7a 3/4 8-7a

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 181 AND 124 TO FACILITY OPERATING LICENSES NOS. DPR-67 AND NPF-16 FLORIDA POWER AND LIGHT COMPANY, ET AL.

ST. LUCIE PLANT, UNITS NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389

1.0 INTRODUCTION

By letter dated January 25, 2002, Florida Power & Light Company (the licensee) submitted a request to amend the Technical Specifications (TS) for pressure testing of the diesel fuel oil system piping at the St. Lucie Plant, Units 1 and 2. The proposed amendments would revise TS Section 4.8.1.1.2.g.2 from the prescriptive testing requirement of performing a test at a pressure equal to 110 percent of the system design pressure, to performing a pressure test in accordance with the inservice inspection program.

2.0 BACKGROUND

The current TS 4.8.1.1.2.g.2 was developed from U.S. Nuclear Regulatory Commission (NRC)

Regulatory Guide (RG) 1.137, Revision 1, 1979, Fuel-Oil Systems for Standby Diesel Generators. This regulatory guide endorses the American National Standards Institute (ANSI)

Standard N195-1976, which requires that the arrangement of the diesel fuel oil system shall provide for inservice inspection and testing in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. For those portions of the diesel fuel oil system designed to the Code, this would require a 110 percent pressure test at 10-year intervals. RG 1.137 endorses this surveillance as an acceptable method of meeting the ANSI standard.

Licensees are subject to the conditions in paragraph (g), Inservice Inspection Requirements, of Title 10, Code of Federal Regulations (10 CFR), Section 50.55a, Codes and Standards.

Paragraph (g) requires, in part, that Classes 1, 2, and 3 components and their supports meet the requirements of Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the ASME Boiler and Pressure Vessel Code or equivalent quality standards.

Currently, the 1989 edition of the ASME Code is applicable to both the Unit 1 and Unit 2 Inservice Inspection Programs at the St. Lucie plant. This edition requires a hydrostatic test to be performed on all Class 1, 2, and 3 systems once each 10-year interval of the inservice inspection plans.

The ASME Boiler and Pressure Vessel Committee publishes a document entitled Code Cases. Generally, the individual Code Cases that make up this document explain the intent of Code rules or provide for alternative requirements under special circumstances. RG 1.147,

Inservice Inspection Code Case Acceptability - ASME Section XI, Division 1, lists those Section XI ASME Code Cases that are generally acceptable to the NRC staff for implementation in the inservice inspection of light-water-cooled nuclear power plants. Through publication of RG 1.147, Revision 12, the NRC has accepted ASME Code Case N-498-1, Alternative Rules for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems. This Code Case relieves licensees, committed to earlier editions of the Code, from the burden of performing hydrostatic testing of code class systems.

3.0 EVALUATION Section 4.8.1.1.2.g.2 of the current St. Lucie TS requires a pressure test at a test pressure equal to 110 percent of the system design pressure at least once per 10 years for those portions of the diesel fuel oil system designed to the US American Standard B31.7 Class 3 requirements for St. Lucie Unit 1, or designed to the ASME Section III, Subsection ND(Class 3),

for St. Lucie Unit 2. The proposed license amendment would remove the prescriptive testing requirements of TS 4.8.1.1.2.g.2 to allow the Class 3 portions of the diesel fuel oil system of each unit to be pressure tested in accordance with the inservice inspection program, which the licensee states meets the requirements of 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(g)(5)(i).

The proposed change would authorize the licensee to use ASME Section XI, Code Case N-498-1, which has been approved by the NRC in Regulatory Guide 1.147, Revision 12. Under the provisions of Code Case N-498-1, a system pressure test at nominal operating pressure shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval of Inspection Program B (10-year inspection program). The existing requirement of TS 4.8.1.1.2.g.2 regarding pressure testing at 110 percent of the system design pressure was derived from RG 1.137, Revision 1, which specifies testing in accordance with the ASME Code,Section XI. However, industry experience shows that most leaks are discovered at nominal operating pressure. The pressure test at 110 percent system design pressure is an enhanced leakage test, which does not provide a significant increase in assurance of structural integrity beyond that provided by a system pressure test at nominal operating pressure. Based on the premise that leakage is equally detectable at nominal operating pressure and the higher hydrostatic test pressure, although flow rate through a given leakage path may be slightly less in the case of the former than that of the latter, Code Case N-498-1 was found acceptable by the NRC because it provides an acceptable level of quality and safety, pursuant to 10 CFR 50.55a(a)(3)(i).

Based on the evaluation above, the staff finds the proposed change to TS Section 4.8.1.1.2.g.2 requiring performance of a pressure test of the diesel fuel oil system at least once per 10 years in accordance with the inservice inspection program, based on Code Case N-498-1, to be acceptable.

4.0 STATE CONSULTATION

Based upon a letter dated March 8, 1991, from Mary E. Clark of the State of Florida, Department of Health and Rehabilitative Services, to Deborah A. Miller, Licensing Assistant, U.S. Nuclear Regulatory Commission, the State of Florida does not desire notification of issuance of license amendments.

5.0 ENVIRONMENTAL CONSIDERATION

These amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (67 FR 7419, dated February 19, 2002). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: P. Patnaik, NRR Date: April 23, 2002

Mr. J. A. Stall ST. LUCIE PLANT Florida Power and Light Company cc:

Senior Resident Inspector Mr. R. G. West St. Lucie Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957 Craig Fugate, Director Mr. T. L. Patterson Division of Emergency Licensing Manager Preparedness St. Lucie Nuclear Plant Department of Community Affairs 6351 South Ocean Drive 2740 Centerview Drive Jensen Beach, Florida 34957 Tallahassee, Florida 32399-2100 Mr. Don Mothena M. S. Ross, Attorney Manager, Nuclear Plant Support Services Florida Power & Light Company Florida Power & Light Company P.O. Box 14000 P.O. Box 14000 Juno Beach, FL 33408-0420 Juno Beach, FL 33408-0420 Mr. Douglas Anderson Mr. Rajiv S. Kundalkar County Administrator Vice President - Nuclear Engineering St. Lucie County Florida Power & Light Company 2300 Virginia Avenue P.O. Box 14000 Fort Pierce, Florida 34982 Juno Beach, FL 33408-0420 Mr. William A. Passetti, Chief Mr. J. Kammel Department of Health Radiological Emergency Bureau of Radiation Control Planning Administrator 2020 Capital Circle, SE, Bin #C21 Department of Public Safety Tallahassee, Florida 32399-1741 6000 SE. Tower Drive Stuart, Florida 34997 Mr. Donald E. Jernigan, Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957