ML18012A573

Safety Evaluation Supporting Amend 70 to License NPF-63

ML18012A573
Person / Time
Site:	Harris
Issue date:	03/19/1997
From:	NRC (Affiliation Not Assigned)
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ML18012A572	List: ML18012A573
References
NUDOCS 9703210183
Download: ML18012A573 (7)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055$ 0001 SAFET EVALUA ION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.

70 TO FACILITY OPERATING LICENSE NO.

NPF-63 C ROLINA POWER

& LIGHT COMPANY H ARON ARRIS NUCLE 0

E L

U I 1

OCKE NO. 50-400 I.O

~INTNOOOO I N

By letter dated January 10,

1997, as supplemented January 31, February 20, and March 3, 1997, the Carolina Power

& Light Company (the licensee) submitted a

request for changes to the Shearon Harris Nuclear Power Plant, Unit 1

(SHNPP),

Technical Specifications (TS).

The requested changes would revise TS 4.8.1. 1.2.h.2 which requires a pressure test of those portions of diesel fuel oil systems designed to American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME) Code Section III.

In lieu of the required pressure

testing, the change limits the 10-year pressure test to the isolable portions of the diesel fuel oil piping system.

The January 31, February 20, and March 7,,1997, letters provided clarifying information that did not change the initial proposed no significant hazards consideration determination.

Furthermore, the January 10, 1997, request supersedes the September 18,

1996, proposed request to remove TS 4.8. 1. 1.2.h.2 (61 FR 55029).

2.0 EVALUATION The existing TS 4.8.1.1.2.h.2 requires a pressure test of those portions of the diesel fuel oil system designed to Section III, Subsection ND, of the ASME Code.

This pressure test is required to be performed at. 110X of the system design pressure at least once per 10 years.

Under the proposed

change, a pressure test will still be required for:

1) the portions of the diesel fuel oil piping from main fuel oil storage tank to the day tank,

2) the 'portions of the diesel fuel oil supply piping from the day tank to the diesel engine vendor-supplied piping, 3) the portions of the diesel fuel oil return piping from the diesel engine vendor-supplied

piping, and 4) the portions of piping between the diesel engine vendor-supplied piping and the safety relief valve.

The diesel fuel oil day tank and portions of certain associated

piping, and portions of connected piping to main fuel oil storage tank will not be tested at 110X of the system design pressure.

As 97032i0i83 9703i9 PDR ADOCK 05000400 P

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2 noted in the licensee's submittal letters, the day tank and certain portions of piping will be tested in accordance with the requirements and guidance of ASHE Code Section XI.

The diesel fuel oil system is designed to meet American National Standards Institute (ANSI) Standard N195-1976, which is in conformance with NRC Regulatory Guide (RG) 1.137.

Section 7.4 of ANSI N195-1976 requires that piping, fittings, pipe supports,

valves, tanks,

pumps, and strainers be designed to the ASHE Section III Code, Subsection,ND.

The licensee has stated that the fuel oil system at SHNPP complies with this requirement.

ANSI N195-1976, Section 7.3 states, "The arrangements shall provide for inservice inspection and testing in accordance with ASHE Boiler and Pressure Vessel

Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components."

The TS requirement for pressure testing the SHNPP diesel fuel oil system piping is based on Regulatory Position C.l.e(1) in Rev.

1 to RG 1. 137.

RG 1. 137, Paragraph l.e, states that "...

an acceptable method of meeting the requirements of Section 7.3 is to ensure that the system arrangement would allow: (1) Pressure testing of the fuel-oil system to a

pressure 1.10 times the system design pressure at 10-year intervals.

In the case of storage

tanks, recommendations of the tank vendor should be taken into account when establishing the test pressure."

t The licensee indicates in its submittals that ASME Section XI, 1983 Edition with Addenda through summer 1983, Article IWD-5000, is to be used for guidance.

This article allows for certain portions of piping systems to be exempt from pressure testing of the piping to llOX of the system design pressure.

This includes 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.

ASME Code Section XI, Article IWD-5000, provides requirements and guidance in performing the pressure tests for Class 3 systems.

IWD-5223 of ASHE Section XI, Item (b) states that "In the case of atmospheric storage tanks, the hydrostatic

head, developed with the tank filled to its design capacity, shall be acceptable as the test pressure,"

and Item (c) states that "For the purpose of the test, open ended portions of suction or drain lines from a storage tank extending to the first shutoff valve shall be considered as an extension of the storage tank."

The day tank is an atmospheric

tank, and the level indicator and level switch lines, portions of suction and drain lines before the first shutoff valve, and portions of the diesel fuel oil supply line before the last shutoff valve are considered to be an extension of.the day tank.

The licensee commits to perform the required test in 'accordance with ASME Code Section XI, IWD-5223(b),'and proposes that the day tank and related piping be visually inspected for leaks during normal operation.

In its January 31, 1997 letter, the licensee also proposes an'observation of "adequate" level in the tanks to ensure the piping is full of oil during visual inspection.

However, during normal operation, the day tank and

'ssociated piping may experience the test pressure as required by IWD-5223(b),

T

b'ut IMD-5223(b) also requires that the oil in the tank be filled to its design level.

Therefore, the staff finds the licensee's proposal acceptable provided that the proposed observation of oil level verifies that the day tank is filled to its "design" level duri'ng the pressure test and visual inspection as required by IWD-5223(b) as stated in the licensee's March 3,

1997, supplemental letter.

The main fuel oil storage tank is also an atmospheric tank, but the tank is designed to ASHE Code Section VIII. Therefore, a pressure test is not required by the TS.

However, portions of connected piping such as suction

lines, sample lines, and pump recirculation lines are designed to ASHE Code Section III, and a pressure test is required by the TS.

According to IWD-5223(c),

those portions of connected piping before the first shutoff valve are considered to be an extension of the main fuel oil storage tank.

Similar to the,day tank, the licensee commits to perform the required test in accordance with ASHE Code Section XI, IWD-5223(b),

and proposes that the connected piping to the main fuel oil storage tank be visually inspected for leaks during normal operation, and that an observation of adequ'ate level in the tanks be performed to ensure the piping is full of oil during visual inspection.

Based on the above day tank review, the staff finds the licensee's proposal acceptable provided that the proposed observation of oil level verifies that the main fuel oil storage tank is filled to its "design" level during the pressure test and visual inspection, in accordance with IWD-5223(b).

IMD-5223(e) of ASHE Section XI states that "Open ended vent and drain lines from components extending beyond the last shutoff valve and open ended safety or relief valve discharge lines shall be exempt from hydrostatic test."

Per IWD-5223(e), the vent and overflow drain lines associated with the day tanks, and the discharge lines associated with the relief valve of the diesel engine are not required to be hydrostatic tested.

The licensee's proposal to exclude these lines from 110X of pressure test is, therefore, acceptable.

Table IMD-2500-1, Note (I) states that "The system boundary extends up to and including the first normally closed valve or valve capable of automatic closure as required to perform the system-related system function."

The piping between the two normally closed isolation valves of the day tank floor drain is considered outside the scope of system pressure

boundary, and is not required to be pressure tested by ASHE Code Section XI.

Therefore, it is acceptable to exclude these lines from hydrostatic test.

Based on the above evaluation, the staff finds that the proposed TS change to require only certain portions of the diesel fuel oil system to be tested every 10 years at llOX of the system design pressure meets the intent of RG 1.137 and is acceptable.

However, the staff finds that the proposed observation of "adequate" oil level in the tank is not in full conformance with the requirements and guidance of ASHE Code Section XI, IWD-5223(b), which requires that the oil tanks be filled to their design level during the 10-year pressure test.

In a subsequent letter dated Harch 3, 1997, the licensee stated that it will maintain the day tanks and main diesel fuel oil storage tanks to their

4 design levels during the 10-year pressure test, as required by ASME Code Section XI, IWD-'5223(b).

This meets the requirements of ASME Section XI and; therefore, the proposed change is acceptable.

3.0 S A E CONSULTATION In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendment.

The State

'fficial had no comments.

4.0 ENVIRONMENT L CONS DE TION The amendment changes 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 changes the Surveillance Requirements.

The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (62 FR 5490).

Accordingly, the amendment meets 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 the amendment.

5.0 CONCLUSIO 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

John Huang Date:

Birch'19, 1997

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