HNP-96-209, Application for Amend to License NPF-63,requesting Rev to TS 4.8.1.1.2.h.2 Re Test Tanks & Nonisolable Piping at Test Pressure
| ML18012A462 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/10/1997 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18012A463 | List: |
| References | |
| HNP-96-209, NUDOCS 9701220114 | |
| Download: ML18012A462 (22) | |
Text
CATEGORY 1 a
REGUDAT INFORMATION DISTRIBUTZONOLSTEM (RIDE) f ACCE'SSION NBR:9701220114 DOC.DATE: 97/Ol/10 NOTARIZED: YES FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit -1, Carolina AUTH.NAME AUTHOR AFFILIATION ROBINSON,W.R.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Application for amend to license NPF-63,requesting rev to TS 4.8.1.1.2.h.2 re to test tanks S non-isolable piping at this test pressure.
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Carolina Power & Light Company PO Box 165 New Hill NC 27562 William R. Robinson Vice President Harris Nuclear Plant SERIAL: HNP-96-209 10 CFR 50.90 JN l 0 ISA United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DIESEL FUEL OIL SYSTEM PRESSURE TESTING (A.C. SOURCES - OPERATING)
Dear Sir or Madam:
This transmittal supersedes a previous letter dated September 18, 1996, from W. R. Robinson to USNRC, Letter Serial Number HNP-96-143.
In accordance with the Code ofFederal Regulations, Title 10, Part 50.90, Carolina Power &
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 ofthe diesel fuel oil system designed to Section III,Subsection ND ofthe ASME Code at a test pressure equal to 110% ofthe system design pressure" at least once per 10 years.
However, the TS does not recognize the inabilityto 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 ANSIN195-1976. N195 Section 7.3 states that "the 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 ofNuclear Power Plant Components."
Section XIofthe American Society ofMechanical Engineers (ASME) Code, 1983 Edition with Addenda through Summer 1983 requires testing for those portions ofthe Emergency Diesel Generator fuel oil system design to Section III,Subsection ND ofthe Code. Article IWD-5000 970i220ii4 9'70fi0 P]>I PDR ADQCK 05000400
)J PD State Road 1134 New Hill NC Tel 919 362-2502 Fax 919 362-2095
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Document Control Desk HNP-96-209 / Page 2 permits exempting certain portions ofpiping systems from testing at 110% ofthe system design pressure.
Specifically, IWD-5223 permits exemptions for atmospheric storage tanks, open-ended portions ofsuction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions ofdischarge 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 reliefvalve discharge lines. IWD-5223 does, however, require alternative examination/testing.
For atmospheric storage tanks, the hydrostatic head developed with the tank filledto its design capacity is acceptable as the test pressure.
Open-ended portions ofsuction or drain lines from a storage tank extending to the first shutoff valve may be considered an extension ofthe storage tank. Confirmation ofadequate flowduring system operation is acceptable for open-ended portions ofdischarge 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-ended safety or reliefvalve discharge lines are exempt from hydrostatic test.
The proposed amendment clarifies Technical Specification (TS) 4.8.1.1.2 pressure testing requirements for isolable and non-isolable diesel fuel oil piping.
Enclosure 1 provides a detailed description ofthe 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 ofthis 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), CPS's providing the State ofNorth Carolina with a copy ofthe proposed license amendment.
CP&Lrequests approval ofthe proposed amendment by March 1, 1997 to support the next HNP refueling outage, currently scheduled to begin in April 1997. In order to allow time for procedure revision and orderly incorporation into copies ofthe Technical Specifications, CPAL requests that the proposed amendment, once approved by the NRC, be implemented within 30 days ofissuance ofthe amendment.
'v 4
Document Control Desk HNP-96-209 / Page 3 Please refer any questions regarding this submittal to Ms. D. B. Alexander at (919) 362-3190.
Sincerely, DJC/twk
Enclosures:
- 1. Basis for Change Request 2.
10 CFR 50.92 Evaluation
- 3. Environmental Considerations
- 4. Page Change Instructions
- 5. Technical Specification Pages
) l(
W. R. Robinson, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best ofhis information, knowledge and belief; and the sources of his information are employees, contractors, and agents ofCarolina Power &Light Company.
My commission expires:
AC@
Notary (Seal)
Mr. J. B. Brady, NRC Senior Resident Inspector Mr. Dayne H. Brown, N.C. DEHNR Mr. L. A. Reyes, NRC Regional Administrator Mr. N. B. Le, NRC Project Manager
Document Control Desk HNP-96-209 / Page 4 bc:
Ms. D. B. Alexander Ms. P. B. Brannan Mr. H. Chernoff (RNP)
Mr. G. W. Davis Mr. J. W. Donahue Ms. S. F. Flynn Mr. H. W. Habermeyer, Jr.
Mr. W. J. Hindman Ms. W. C. Langston (PEARAS File)
Mr. R. D. Martin Mr. W. S. Orser Mr. R. A. Patterson Mr. G. A. Rolfson Mr. R. S. Stancil Mr. D. L. Tibbitts Mr. M. A. Turkal (BNP)
Mr. T. D. Walt Nuclear Records File: HI/A-2D File: H-X-0511
ENCLOSURE TO SERIAL: HNP-96-209 ENCLOSURE 1
SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DIESEL FUEL OIL SYSTEM PRESSURE TESTING (A.C. SOURCES - OPERATING)
The Harris Plant Emergency Diesel Generators are designed to provide a reliable source ofpower to the emergency 6.9KV buses in the event that normal sources ofoff-site power are not available. There are two independent diesel generator systems capable ofsupplying the power needed for safe shutdown ofthe 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 ofa 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 ofthe storage tanks has a capacity of 175,000 gallons which is sufficient for continuous operation ofeach diesel generator for seven days. The centrifugal fuel oil transfer pumps each have a capacity of40 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 ofeach day tank is sufficient for approximately six hours, assuming maximum diesel engine fuel consumption.
The fuel oil storage tanks are designed to Section VIIIofthe American Society ofMechanical 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 ofthe 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 ANSIN195-1976.
(References to N195 contained herein refer to ANSIN195-1976, "Fuel Oil Systems for Standby Diesel Generators.")
N195 Section 7.3 states that "the arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI,Rules for In-Service Inspection ofNuclear Power Plant Components."
Page E1-1
ENCLOSURE TO SERIAL: HNP-96-209 The current Code ofrecord for performing inservice inspection (ISI) and inservice testing (IST) at the Harris Plant is the 1983 Edition ofthe ASME Code,Section XI,with Addenda through Summer 1983. (References to Section XIherein refer to that particular edition and addenda of ASME Section XI.) Per Section XI, the intent ofa pressure test is to detect leakage (Subarticle IWA-5211). Subarticle IWA-2400 defines the inspection intervals for inservice examinations and system pressure tests ofClass 3 (Subsection ND) systems as 10 years.
In addition to the Section XIrequirements 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 ofthose portions ofthe diesel fuel oil system designed to Section III,Subsection ND ofthe ASME Code at a test pressure equal to 110% ofthe 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.
Section XI,Article IWD-5000 provides requirements and guidance for performing pressure tests on Class 3 systems.
Subarticle IWD-5223, Item (a) requires a test pressure ofat least 110% of the design pressure for systems with a design temperature of200 degrees Fahrenheit or less. The design temperature for fuel oil piping at the Harris Plant is 125 degrees Fahrenheit.
IWD-5223 also permits exemption ofcertain portions ofpiping systems from testing at 110% ofthe system design pressure.
IWD-5223, Items (b) through (g) permit exemption for atmospheric storage tanks, open-ended portions ofsuction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions ofdischarge 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 reliefvalve discharge lines.
In accordance with existing commitments, CP&Lwillcontinue to perform inservice inspection and testing ofthe diesel fuel oil system in accordance with the ASME Boiler and Pressure Vessel Code,Section XI. Based on Section XI,IWD-5223 exemptions discussed above, pressure testing at 110% ofthe system design pressure willonly be required on the izQabh 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.
Page El-2
ENCLOSURE TO SERIAL: HNP-96-209 The exemptions allowed by ASME Code Section XIwillbe invoked for the atmospheric day tank and non-isolable piping as identified in the attached schematic.
Page El-3
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ENCLOSURE TO SERIAL: HNP-96-209 ENCLOSURE2 SHEARON HARMS NUCLEARPOWER PLANT'RC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DIESEL FUEL OIL SYSTEM PRESSURE TESTING (A.C. SOURCES - OPERATING)
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 facilityinvolves no significant hazards consideration ifoperation ofthe facilityin accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences ofan accident previously evaluated, (2) create the possibility ofa new or different kind ofaccident from any accident previously evaluated, or (3) involve a significant reduction in a margin ofsafety. 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:
The Harris Plant Emergency Diesel Generators are designed to provide a reliable source ofpower to the emergency 6.9KV buses in the event that normal sources ofoff-site power are not available. The diesel generators are capable ofsupplying the power needed for the safe shutdown ofthe plant. The fuel oil storage and transfer system is provided to store, maintain, and supply fuel oil to the diesel generators.
The system consists oftwo separate, independent fuel oil systems, each consisting ofa 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 ANSIN195-1976. N195 Section 7.3 states that "the arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI,Rules for In-Service Inspection ofNuclear Power Plant Components."
Section XIofthe American Society ofMechanical Engineers (ASME) Code, 1983 Edition with Addenda through Summer 1983, Article IWD-5000 permits exempting certain portions ofpiping systems from testing at 110% ofthe system design pressure.
Specifically, IWD-5223 permits Page E2-1
~ y,
)
~
r.
ENCLOSURE TO SERIAL: HNP-96-209 exemptions for atmospheric storage tanks, open-ended portions ofsuction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions ofdischarge 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 reliefvalve discharge lines.
This amendment request clarifies the requirements ofTechnical Specification (TS) 4.8.1.1.2.h.2 which currently requires "performing a pressure test ofthose portions ofthe diesel fuel oil system designed to Section III,Subsection ND ofthe ASME Code at a test pressure equal to 110% ofthe system pressure" at least once per 10 years.
The system pressure test is to be performed at a pressure of 110% ofthe design pressure at least once per 10 years and only on those sections of piping that are isolable. ASME Code Section XIexemptions willbe invoked for the atmospheric day tank and non-isolable piping.
This change clarification does not involve a significant hazards consideration for the following reasons:
1.
The proposed amendment does not involve a significant increase in the probability or consequences ofan accident previously evaluated.
Applying ASME Code, Section XIalternative examination/testing willnot affect any initiators ofany 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 ofpiping are non-isolable or where atmospheric tanks are involved, the Section XIASME 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 ofan accident previously evaluated.
The proposed amendment does not create the possibility ofa new or different kind of accident from any accident previously evaluated.
The proposed alternative testing and surveillance willnot involve any physical alterations or additions to plant equipment or alter the manner in which any safety-related system performs its function. Using ASME Section XIguidance for testing continues to provide assurance that the fuel oil supply system willperform its intended function. Therefore, Page E2-2
r C
ENCLOSURE TO SERIAL: HNP-96-209 the proposed changes do not create the possibility ofa new or, different kind ofaccident from any accident previously evaluated.
3.
The proposed amendment does not involve a significant reduction in the margin ofsafety.
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 ofsafety as defined in the Technical Specifications. UtilizingASME Section XI as guidance for determining those sections ofpiping that should be pressure-tested or tested at atmospheric pressure willensure proper operation ofthe diesel generator fuel oil supply system.
Therefore, the proposed changes do not involve a significant reduction in a margin ofsafety.
Page E2-3
ENCLOSURE TO SERIAL: HNP-96-209 ENCLOSURE3 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT DIESEL FUEL OIL SYSTEM PRESSURE TESTING (A.C. SOURCES - OPERATING) 10 CFR 51.22(c)(9) provides criterion for and identification oflicensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.
A proposed amendment to an. operating license for a facilityrequires no environmental assessment if operation ofthe facilityin 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 ofany effluents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure.
Carolina Power 0 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 ofthe amendment.
The basis for this determination follows:
The Harris Plant Emergency Diesel Generators are designed to provide a reliable source ofpower to the emergency 6.9KV buses in the event that normal sources ofoff-site power are not available. The diesel generators are capable ofsupplying the power needed for the safe shutdown ofthe plant. The fuel oil storage and transfer system is provided to store, maintain, and supply fuel oil to the diesel generators.
The system consist oftwo separate, independent fuel oil systems, each consisting ofa 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 ANSIN195-1976. N195 Section 7.3 states that "the arrangement shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection ofNuclear Power Plant Components."
Page E3-1
ENCLOSURE TO SERIAL: HNP-96-209 Section XIofthe American Society ofMechanical Engineers (ASME) Code, 1983 Edition with Addenda through Summer 1983, Article IWD-5000 permits exempting certain portions ofpiping systems from testing at 110% ofthe system design pressure.
Specifically, IWD-5223, permits exemptions for atmospheric storage tanks, open-ended portions ofsuction and drain lines from a storage tank extending to the first shutoff valve, open-ended portions ofdischarge 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 reliefvalve discharge lines.
This amendment request clarifies the requirements ofTechnical Specification (TS) 4.8.1.1.2.h.2 which currently requires "performing a pressure test ofthose portions ofthe diesel fuel oil system designed to Section III,Subsection ND ofthe ASME Code at a test pressure equal to 110% ofthe system pressure" at least once per 10 years.
The system pressure test is to be performed at a pressure of 110% ofthe design pressure, at least once per 10 years and only on those sections ofpiping that are isolable. ASME Code Section XIexemptions willbe invoked for the atmospheric day tank and non-isolable piping.
The change meets the eligibility,criteria 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.
The proposed amendment does not result in a significant change in the types or significant increase in the amounts ofany effluents that may be released offsite.
The proposed change does not involve any new equipment or require existing systems to perform a different type offunction than they are currently designed to perform. The change does not introduce any new effluents or increase the quantities ofexisting effluents. As such, the change can not affect the types or amounts ofany effluents that may be released offsite.
3.
The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation 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.
Page E3-2
f
ENCLOSURE TO SERIAL: HNP-'96-209 Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.
Page E3-3
ENCLOSURE4 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT, DIESEL FUEL OIL SYSTEM PRESSURE TESTING 3/4 8-9 B 3/4 8-2 3/4 8-9 B 3/4 8-2