ML20117E904
| ML20117E904 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/28/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20117E886 | List: |
| References | |
| NUDOCS 9609030157 | |
| Download: ML20117E904 (4) | |
Text
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1 y,pn M UNITED STATES
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NUCLEAR REGULATORY COMMISSION -
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WASHINGTON, D.C. 2066M001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 95 TO FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 73 TO FACILITY OPERATING LICENSE NPF-81 GEORGIA POWER COMPANY. ET AL.
V0GTLE ELECTRIC GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425
1.0 INTRODUCTION
i By letter dated June 17, 1996, as supplemented by letter dated August 16, 1996, Georgia Power Company, et al. (GPC or the licensee) proposed license amendments to change the Technical Specifications (TS) for Vogtle Electric i
Generating Plant (VEGP), Units 1 and 2.
The proposed changes would revise TS 3/4.8.1, A.C. Sources, and its associated Bases, by changing Surveillance Requirement 4.8.1.1.2.j(2).
The change limits the 10-year pressure test of the diesel fuel oil system to the isolable portions of the fuel oil piping.
The licensee further proposes that the TS Bases be changed by the addition of a related discussior, clarifying how the proposed change is to be applied to the 10-year test.
The August 16, 1996, information that did not change the scope of the Juneletter provided additional suppor 17, 1996, application and initial proposed no significant hazards consideration determination.
This TS change is also included in the licensee's May 1,1995, application for full conversion to the improved technical specification format.
The staff review of that application has not been completed.
This specific TS change is necessary now to support testing of the diesel fuel oil system required to be performed prior to the expected completion of the full conversion review.
2.0 EVALUATION The existing TS 4.8.1.1.2.j(2) requires a pressure test of those portions of the diesel fuel oil system designed to Section III, Subsection ND, of the ASME Boiler and Pressure Vessel Code.
This pressure test is required to be performed at 110% of the system design pressure at least once per 10 years.
Under the proposed change, a pressure test will still be required for the diesel fuel oil piping from: (1) the transfer pump discharge piping to the day tank; (2) the fuel oil supply line from the day tank to the vendor-supplied piping; and, (3) the fuel oil return piping from the vendor-supplied piping to the regulator valve. The fuel oil day tank, the fuel oil storage tank, and certain portions of the piping will not be tested at 110% of the system design pressure. As noted in the proposed addition to the TS Bases, the licensee has stated that the day tank will be tested by recirculating the fuel oil and verifying no tank leakage, and the storage tank will be tested by filling the 9609030157 960828 PDR ADOCK 05000424 P
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i 4 tank to greater than the normal fill level and monitoring the level for a j
period of time as a test. for leakage.
Testing of certain portions of the piping will be in conformance with allowances specified in the ASME standard.
The diesel fuel oil system is designed to meet American National Standards Institute (ANSI) Standard N195-1976, which i in conformance with NRC Regulatory Guide (RG) 1.137.
The TS requirement for pressure testing the VEGP diesel is based on Regulatory Position C.1.e(1) in Rev 1 to 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 ASME Section III Code, Subsection ND. The licensee has stated that the fuel oil system at VEGP complies with this requirement. ANSI N195-1976, Section 7.3 states, "The arrange.nents 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 licensee points out that ANSI N195-1976 does not contain additional requirements for inspection or testing of the system after it is placed in service.
However, their interpretation of the requirement in ANSI N195-1976 to provide arrangements to allow inservice inspection and testing indicates to them that the ANSI standard implies that some type of inspection and testing should still be performed.
RG 1.137, Paragraph 1.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 j
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."
The licensee has stated 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 pressurizing the piping to 110% 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.
The licensee points out that in accordance with ASME Section XI, the intent of a pressure test is to detect leakage (reference ASME Section XI, Article IWA-5000, Subarticle IWA-5211). ASME Section XI, Article IWD-5000, provides requirements and guidance in performing the pressure tests for Class 3 systems. Subarticle.IWD-5223 of ASME 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."
The fuel oil' storage tank and day tank are atmospheric tanks; therefore, the licensee has determined that test pressure of 1.10 times the system pressure is not required for these tanks. The day tank is an aboveground, exposed tank.
By recirculating the fuel oil from the day tank to the storage tank, the day tank can be visually inspected for leaks. This meetsSection XI requirement and, therefore, is acceptable.
The storage tank is an underground tank, which cannot feasibly be visually-inspected for leaks.
To identify leaks in the storage tank would require verifying a level change over a period
1
. of time. As stated in Technical Specification 4.8.1.1.2, the fuel level in the storage tank is verified at least every 31 days.
The licensee proposes that the tank be filled to its design capacity and the surveillance data be used to verify any leakage without having to declare the emergency diesel generator (EDG) inoperable. This is acceptable because filling the tanks and monitoring the level over a period of time meets the intent of the ASME Section XI requirements.
The licensee notes that Subarticle IWD-5223, Item (d) of ASME Section XI states that "For open ended portions of discharge lines beyond the last shutoff valve in non-closed systems, confirmation of adequate flow during system operation shall be acceptable in lieu of system hydrostatic test." The licensee then states that the overflow line from the day tank to the storage tank and the truck fill lines may be considered open ended discharge lines in non-closed systems.
In their August 16, 1996, letter, the licensee provided
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additional information concerning their plans to test the fuel oil system.
Specifically, the fuel oil recirculation lines would be visually inspected during operation of the EDG, the fuel oil pump test lines will be visually inspected during operation of a fuel oil transfer pump with flow through the lines, and the exposed overflow lines from the day tank to the storage tank will be visually inspected after 10 minutes of pump operation in an overflow condition. These actions will subject these system components to their 2
operating pressure during which time a visual inspection will be made.
Therefore, the licensee's proposal for these components meetsSection XI requirements and, therefore, is acceptable.
4 The. licensee also stated in its August 16, 1996, letter that a blank will be installed in 'the truck fill line to the fuel oil day tank.
Since this modification will permanently remove the piping from service, testing is not required. This is an acceptable alternative to performing a pressure test.
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As a separate but related matter, the staff notes that relocating the requirement in current TS 4.8.1.1.2.j(2) for the 10-year pressure test of the fuel oil system from the TS to a licensee controlled document is allowed by the NRC program for conversion to the improved TS format and has been proposed by the licensee in their application for TS conversion.
The staff expects that the current TS 4.8.1.1.2.j(2) requirement will not appear in the improved TS when it is issued.
Based on the above, the staff finds acceptable the proposed TS change to clarify that the portions of the diesel fuel oil system required to be tested at 110% of the system design pressure is limited to the isolable portions of the system piping.
3.0 ETATE CONSULTATION In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendments.
The State official had no comments.
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4.0 ENVIRONMENTAL CONSIDERATION
The amendments 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 (61 FR 37300 dated July 17,1996). Accordingly, the 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 the amendments.
5.0 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 Commission's 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:
L. Wheeler Date:
August 28, 1996 2