ML18012A370
| ML18012A370 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/18/1996 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18012A371 | List: |
| References | |
| HNP-96-143, NUDOCS 9609240401 | |
| Download: ML18012A370 (22) | |
Text
CATEGORY 1 REGULAI!Y INFORMATION DISTRZBUTZ(SYSTEM (RIDE)
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.AC('.E;SSII!>4 NBR:9609240401 FACIL:I~O-400 Shearon DOC.DATE: 96/09/18 NOTARIZED: YES Harris Nuclear Power Plant, Unit 1, Carolina DOCKET I 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON,N.R. Carolina Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amend to license NPF-63,requesting change in diesel fuel oil sys pressure testing. C DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution, 2 ENCL l SIZE: +9 NOTES:Application for permit renewal filed. T 05000400 RECIPIENT ! COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 LE,N 1 1 INTERNAL: ACRS 1 1 E CE, 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 '1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083) TO EL1MINATE, YOUR NAME FROM DISTRIBUTION LXSTS FOR DOCUMENTS YOU DON'T NEED!
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Carolina Power & Light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant SERIAL: HNP-96-143
.SEP1 8 j996 10 CFR 50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DIESEL FUEL OIL SYSTEM PRESSURE TESTING
Dear Sir or Madam:
In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power Ec Light Company (CP&L) hereby requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). TS 4.8.1.1.2.h.2 currently requires "performing a pressure test of those portions of the diesel fuel oil system designed to Section III, Subsection ND of the ASME Code at a test pressure equal to 110% of the system design pressure" at least once per 10 years.
However, the TS does not recognize the inability to test tanks and non-isolable piping at this test pressure.
Final Safety Analysis Report (FSAR) Section 9.5.4.1 states that the diesel fuel oil system at the Harris Plant complies, with exceptions, to ANSI N195-1976. N195 Section 7.3 states that "[t]he
[design] arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components."
Section XI of the American Society of Mechanical Engineers (ASME) Code, 1983 Edition with Addenda through Summer 1983 requires testing for those portions of the Emergency Diesel Generator fuel oil system designed to Section III, Subsection ND of the Code. Article IWD-5000 permits exempting certain portions of piping systems from testing at 110% of the system design pressure. Specifically, IWD-5223 permits exemptions for atmospheric storage tanks, open-ended portions of suction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions of discharge lines beyond the last shutoff valve in non-closed systems, open-ended vent and drain lines from components extending beyond the last shutoff valve, and open-ended safety or relief valve discharge lines. IWD-5223 does, however, require alternative 960924040i 9609ia PDR ADQCK 05000400
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Document Control Desk HNP-96-143 / Page 2 examination/testing. For atmospheric storage tanks, the hydrostatic head developed with the tank filled to its design capacity is acceptable as the test pressure. Open-ended portions of suction or drain lines from a storage tank extending to the first shutoff valve may be considered an extension of the storage tank. Confirmation of adequate flow during system operation is acceptable for open-ended portions of discharge lines beyond the last shutoff valve in nonclosed systems. Open-ended vent and drain lines from components extending beyond the last shutoff valve and open-safety or relief valve discharge lines are exempt from hydrostatic test. 'nded The proposed amendment revises Technical Specification (TS) 4.8.1.1.2 by removing the TS 4.8.1.1.2.h.2 pressure testing requirement since adequate testing willbe completed in accordance with Section XI. provides a detailed description of the proposed changes and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides an environmental evaluation demonstrating that the proposed amendment meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment is required for approval of this amendment request. provides page change instructions for incorporating the proposed revisions. provides the proposed Technical Specification pages.
In accordance with 10 CFR 50.91(b), CP&L is providing the State of North Carolina, with a copy of the proposed license amendment.
CP&L requests approval of the proposed amendment by March 1, 1997 to support the next HNP refueling outage, currently scheduled to begin in March 1997. In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendment, once approved by the NRC, be implemented within 30 days of issuance of the amendment.
Please refer any questions regarding this submittal to Mr. T. D. Walt at (919) 362-2711.
Sincerely,
Document Control Desk HNP-96-143 / Page 3
Enclosures:
- 1. Basis for Change Request
- 2. 10 CFR 50.92 Evaluation
- 3. Environmental Considerations
- 4. Page Change Instructions
- 5. Technical Specification Pages W. R. Robinson, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his iiiformation are employees, contractors, and agents of Carolina Power & Light Company.
e Notary (Seal) iriy corooiissioo expires: g/pq/ci cy Mr. J. B. Brady, NRC Senior Resident Inspector Mr. Dayne H. Brown, N.C. DEHNR Mr. S. D. Ebneter, NRC Regional Administrator Mr. N. B. Le, NRC Project Manager
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ENCLOSURE TO SERIAL: HNP-96-143 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DIESEL FUEL OIL SYSTEM PRESSURE TESTING BASIS FOR CHANGE RE UEST
~Back round The Harris Plant Emergency Diesel Generators are designed to provide a reliable source of power to the emergency 6.9KV buses in the event that normal sources of off-site power are not available. There are two independent diesel generator systems capable of supplying the power needed for safe shutdown of the plant.
Independent fuel oil storage and transfer systems are provided to store, maintain, and supply fuel oil to the diesel generators. The systems each consist of a fuel oil storage tank, a transfer pump, a day tank, and associated piping and valves. The fuel oil storage tanks are horizontal, reinforced concrete tanks with steel liners located underground. Each of the storage tanks has a capacity of 175,000 gallons which is sufficient for continuous operation of each diesel generator for seven days. The centrifugal fuel oil transfer pumps each have a capacity of 40 gpm and are located below grade adjacent to the storage tanks. Upon demand, diesel fuel is pumped from the storage tank, through a simplex strainer, into a day tank. The day tanks are vertical steel tanks located in the diesel generator building situated to provide a positive suction pressure to an engine-driven fuel pump. The volume of each day tank is sufficient for approximately six hours, assuming maximum diesel engine fuel consumption. The fuel oil storage tanks are designed to Section VIII of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. The day tanks, fuel oil transfer pumps, and fuel oil system piping and valves are designed to Section III, Class 3 of the Code.
Final Safety Analysis Report (FSAR) Section 9.5.4.1 states that the diesel fuel,oil system at the Harris Plant complies, with [unrelated] exceptions, to ANSI N195-1976. (References to N195 contained herein refer to ANSI N195-1976, "Fuel Oil Systems for Standby Diesel Generators.")
N195 Section 7.3 states that "[t]he arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components."
The current Code of record for performing inservice inspection (ISI) and inservice testing (IST) at the Harris Plant is the 1983 Edition of the ASME Code,Section XI, with Addenda through Summer 1983. (References to Section XI herein refer to that particular edition and addenda of Page E1-1
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ENCLOSURE TO SERIAL: HNP-96-143 ASME Section XI.) Per Section XI, the intent of a pressure test is to detect leakage (Subarticle IWA-5211). Subarticle IWA-2400 defines the inspection intervals for inservice examinations and system pressure tests of Class 3 (Subsection ND) systems as 10 years.
In addition to the Section XI requirements for the Emergency Diesel Generator fuel oil system designed to Section III, Subsection ND, a duplicative requirement for pressure testing the fuel oil piping at the Harris Plant is contained in the plant Technical Specifications. TS 4.8.1.1.2.h.2 requires "performing a pressure test of those portions of the diesel fuel oil system designed to Section III, Subsection ND of the ASME Code at a test pressure equal to 110% of the system design pressure" at least once per 10 years. However, the TS does not recognize the inability to test atmospheric tanks and non-isolable piping at this test pressure.
BasisSection XI, A'rticle IWD-5000 provides requirements and guidance for performing pressure tests on Class 3 systems. Subarticle IWD-5223, Item (a) requires a test pressure of at least 110% of the design pressure for systems with a design temperature of 200 degrees Fahrenheit or less. The design temperature for fuel oil piping at the Harris Plant is 125 degrees Fahrehheit. IWD-5223 also permits exemption of certain portions of piping systems from testing at 110% of the system design pressure. IWD-5223, Items (b) through (g) permit exemption for atmospheric storage tanks, open-ended portions of suction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions of discharge lines beyond the last shutoff valve in non-closed systems, open-ended vent and drain lines from components extending beyond the last shutoff valve, and open-ended safety or relief valve discharge lines.
Since testing is already required in accordance with Section XI of the ASME Code for those portions of the Emergency Diesel Generator fuel oil system designed to Section III, Subsection ND of the ASME Code, the proposed amendment willremove, in lieu of revising, the TS 4.8.1.1.2.h.2 pressure testing requirement.
Conclusions The existing Technical Specification 4.8.1.1.2.h.2 testing requirements are not necessary to ensure that the fuel oil supply system will perform its intended function. In accordance with existing commitments, CPS'ill continue to perform inservice inspection and testing of the diesel fuel oil system in accordance with the ASME Boiler and Pressure Vessel Code,Section XI.
Page E1-2
S ENCLOSURE TO SERIAL: HNP-96-143 Based on Section XI, IWD-5223 exemptions discussed above, pressure testing at 110% of the system design pressure, or alternative pressure testing in accordance with NRC-endorsed ASME Code cases, will only be required on the isolable portions of:
fuel oil transfer pump discharge piping to the day tank, and fuel oil supply line from the day tank to the diesel vendor-supplied piping, and fuel oil return piping from diesel vendor-supplied piping to the day tank regulator valve.
The atmospheric day tank and non-isolable piping, as shown in the attached schematic, will be exempted from the 110% pressure testing.
Page El-3
1 ATTACHMENT 1 PIPING EXEMPT FROM 118% HYDROTEST (TYPICAL FOR
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i FLGS FOR i 1A-SA TANK DRAIN i NOT INCLUDED IN TEST BOUNDARY FD lalsl SISISISISISIO DIESEL FUEL OIL SYSTEM SCHEMATIC PIPING EXEMPT FROM 118% PRESSURE TEST (TYPICAL)
ENCLOSURE TO SERIAL: HNP-96-143 ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT A.C. SOURCES - OPERATING 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration ifoperation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power Ec Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination. The bases for this determination are as follows:
Pro osed Chan e The Harris Plant Emergency Diesel Generators are designed to provide a reliable source of power to the emergency 6.9KV buses in the event that normal sources of off-site power are not available. The diesel generators are capable of supplying the power needed for the safe shutdown of the plant. The fuel oil storage and transfer system is provided to store, maintain, and supply fuel oil to the diesel generators. The system consists of two separate, independent fuel oil systems, each consisting of a fuel oil storage tank, a transfer pump, a day tank, and associated piping and valves.
Final Safety Analysis Report (FSAR) Section 9.5.4.1 states that the diesel fuel oil system at the Harris Plant complies, with [unrelated] exceptions, to ANSI N195-1976. N195 Section 7.3 states that "[t]he arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components."
Section XI of the American Society of Mechanical Engineers (ASME) Code, 1983 Edition with Addenda through Summer 1983, Article IWD-5000 permits exempting certain portions of piping systems from testing at 110% of the system design pressure. Specifically, IWD-5223, permits exemptions for atmospheric storage tanks, open-ended portions of suction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions of discharge lines beyond-the last shutoff valve in non-closed systems, open-ended vent and drain lines from components extending beyond the last shutoff valve, and open-ended safety or relief valve discharge lines.
Page E2-1
ENCLOSURE TO SERIAL: HNP-96-143 I
Technical Specification (TS) 4.8.1.1.2.h.2 currently requires "performing a pressure test of those portions of the diesel fuel oil system designed to Section III, Subsection ND of the ASME Code at a test pressure equal to 110% of the system design pressure" at least once per 10 years.
However, the TS does not recognize the inability to test atmospheric tanks and non-isolable piping at this test pressure.
Since testing is already required in accordance with Section XI of the ASME Code for those portions of the Emergency Diesel Generator fuel oil system designed to Section III, Subsection ND of the ASME Code, the proposed amendment will remove, in lieu of revising, the TS 4.8.1.1.2.h.2 pressure testing requirement..
Basis This change does not involve a significant hazards consideration for the following reasons:
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Applying ASME Code,Section XI alternative examination/testing will not affect any initiators of any previously evaluated accidents or change the manner in which the emergency diesel generators or any other systems operate. The diesel fuel oil system supports the emergency diesel generators which serve an accident mitigating function.
Where portions of piping are non-isolable or where atmospheric tanks are involved, the Section XI ASME alternatives to 110% pressure testing continue to ensure the integrity of the fuel oil system without any impact on analyzed accident scenarios or their consequences. Therefore, the proposed amendment does not result in an increase in the probability or consequences of an accident previously evaluated.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed alternative testing and surveillance will not involve any physical alterations or additions to plant equipment or alter the manner in which any safety-related system performs it function. Using ASME Section XI, or NRC-approved ASME Code 'cases, as guidance for pressure testing continues to provide assurance that the fuel oil supply system willperform its intended function. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Page E2-2
0 ENCLOSURE TO SERIAL: HNP-96-143
- 3. The proposed amendment does not involve a significant reduction in the margin of safety.
There are no changes being made to the safety limits or safety settings that would adversely impact plant safety. Further, there is no impact on the margin of safety as defined in the Technical Specifications. Utilizing ASME Section XI as guidance for determining those sections of piping that should be pressure-tested or tested at atmospheric pressure will ensure proper operation of the diesel generator fuel oil supply system. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Page E2-3
- y ENCLOSURE TO SERIAL: HNP-96-143 ENCLOSURE3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT A.C. SOURCES - OPERATING ENVIRONMENTALCONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment ifoperation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure. Carolina Power Ec Light Company has reviewed this request and determined that the proposed amendment meets the eligibilitycriteria 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 needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:
Pro osed Chan e The Harris Plant Emergency Diesel Generators are designed to provide a reliable source of power to the emergency 6.9KV buses in the event that normal sources of off-site power are not available. The diesel generators are capable of supplying the power needed for the safe shutdown of the plant. The fuel oil storage and transfer system is provided to store, maintain, and supply fuel oil to the diesel generators. The system consists of two separate, independent fuel oil systems, each consisting of a fuel oil storage tank, a transfer pump, a day tank, and associated piping and valves.
Final Safety Analysis Report (FSAR) Section 9.5.4.1 states that the diesel fuel oil system at the Harris Plant complies, with [unrelated] exceptions, to ANSI N195-1976. N195 Section 7.3 states that "[t]he arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components."
Section XI of the American Society of Mechanical Engineers (ASME) Code, 1983 Edition with Addenda through Summer 1983, Article IWD-5000 permits exempting certain portions of piping systems from testing at 110% of the system design pressure. Specifically, IWD-5223, permits exemptions for atmospheric storage tanks, open-ended portions of suction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions of discharge lines beyond Page E3-1
ENCLOSURE TO SERIAL: HNP-96-143 the last shutoff valve in non-closed systems, open-ended vent and drain lines from components extending beyond the last shutoff valve, and open-ended safety or relief valve discharge lines.
Technical Specification (TS) 4.8.1.1.2.h.2 currently requires "performing a pressure test of those portions of the diesel fuel oil system designed to Section III, Subsection ND of the ASME Code at a test pressure equal to 110% of the system design pressure" at least once per 10 years.
However, the TS does not recognize the inability to test atmospheric tanks and non-isolable piping at this test pressure.
Since testing is already required in accordance, with Section XI of the ASME Code for those portions of the Emergency Diesel Generator fuel oil system designed to Section III, Subsection ND of the ASME Code, the proposed amendment willremove, in lieu of revising, the TS 4.8.1.1.2.h.2 pressure testing requirement..
Basis The change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
- 1. As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.
- 2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed change does not involve any new equipment or require existing systems to perform a different type of function than they are currently designed to perform. The change does not introduce any new effluents or increase the quantities of existing effluents. As such, the change can n'ot affect the types or amounts of any effluents that may be released offsite.
- 3. The proposed amendment does not result in a significant increase in individual or cumulative occupational ra'diation exposure.
The proposed change does not result in any physical plant changes or new surveillances which would require additional personnel entry into radiation controlled areas. Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.
Page E3-2
ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT A.C. SOURCES - OPERATING PAGE CHANGE INSTRUCTIONS Removed Pa e Inserted Pa e 3/4 8-9 3/4 8-9