HNP-05-128, Relief Request from Inservice Inspection Program No. 2R1-015 Alternative to ASME Code Section XI, IWA-4000 Requirements

Relief Request from Inservice Inspection Program No. 2R1-015 Alternative to ASME Code Section XI, IWA-4000 Requirements

ML053410125
Person / Time
Site:	Harris
Issue date:	11/18/2005
From:	Kamilaris C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2R1-015, HNP-05-128
Download: ML053410125 (13)

Text

t I - - it Progress Energy Serial: HNP-05-128 NOV 1 8 2005 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION Xl, IWA-4000 REQUIREMENTS Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.55a, "Codes and Standards," paragraph (a)(3)(i), the Harris Nuclear Plant (HNP) of Carolina Power and Light Company (CP&L) doing business as Progress Energy Carolinas, Inc., requests relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," requirements for the pressure testing of piping and valves within the Class 1 pressure boundary. HNP proposes a system leakage test to the normal operating pressure boundary rather than a hydrostatic test to the full Class 1 pressure boundary.

HNP has concluded that the proposed alternative provides an acceptable level of quality and safety, and that compliance with the specified Code requirements would result in unnecessary hardship without a compensating increase in the level of quality and safety. HNP requests approval of this relief request, pursuant to 10 CFR 50.55a(a)(3)(ii).

Attachment 1 provides the proposed HNP relief request (2R1 -015).

HNP requests approval of this relief request by March 8, 2006 to support planning activities associated with Refueling Outage (RFO) 13 scheduled for the spring of 2006.

This document contains no new Regulatory Commitments.

Progress Energy Carolinas, Inc.

Harris Nuclear Plant P.O. Box 165 New Hill, NC 27562

r HNP-05-1 28 Page 2 Please refer any questions regarding this submittal to Mr. Dave Corlett at (919) 362-3137.

Sincerely, CS. a C.S. Kamilaris Manager, Site Support Services CSK/khv C:

Mr. R. A. Musser, NRC Sr. Resident Inspector Mr. C. P. Patel, NRC Project Manager Dr. W. D. Travers, NRC Regional Administrator

Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION Xi, IWA-4000 REQUIREMENTS ASME Code Component(s) Affected Code Class:

References:

IWB-2500, Code Case N-498-4 Examination Category: B-P Item Number: B15.51, B15.71

Description:

Piping and valves within the Class 1 pressure boundary. It includes Reactor Coolant, Charging, Safety Injection, and Residual Heat Removal Systems.

Component: Process piping, drains, vent, test, and fill lines within the Class 1 pressure boundary.

Applicable Code Edition and Addenda

ASME Section Xi, "Rules for Inservice Inspection of Nuclear Power Plant Components,"

Code 1989 Edition, no Addenda.

Applicable Code Requirement

Table IWB-2500-1, Examination Category B-P, Note 2 states, "The pressure retaining boundary during system hydrostatic test shall include all Class I components within the system boundary." Also, Code Case N-498-4 (Altemative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems) reply paragraph (a)(2) states, "The boundary subject to test pressurization during the system leakage test shall extend to all Class 1 pressure retaining components within the system boundary."

Note: HNP intends to use Code Case N-498-4 to satisfy the 10-Year System Hydrostatic Testing of Class 1,2, and 3 components. Code Case N-498-4 is approved for use in Regulatory Guide 1.147 with conditions.

Relief is requested from ASME Section Xl (Table IWB-2500-1, Examination Category B-P,Note 2) and Code Case N-498-4, regarding extension of the pressure retaining boundary during system pressure tests conducted at or near the end of each inspection interval to Class 1 pressure retaining components within the system boundary.

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Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1-015 ALTERNATIVE TO ASME CODE SECTION Xi, IWA-4000 REQUIREMENTS Reason and Justification for Requesting Relief:

Relief is requested in accordance with 10 CFR 50.55a(a)3)(ii) on the basis that hardship and unusual difficulty exist without a compensating increase in the level of quality and safety, regarding extension of the pressure retaining boundary during system pressure test to all Class 1 pressure retaining components within the system boundary.

Table 1 identifies the Class 1 pressure retaining components that are associated with the requested relief.

The Class 1 drains, vent, test, and fill lines are equipped with isolation valves, which provide double isolation of the Reactor Coolant Pressure Boundary (RCPB). These valves are generally maintained in the closed position during normal plant operation.

The piping outboard of the first isolation valve is not normally pressurized. Under normal operating conditions, the piping and connections are subjected to reactor coolant system pressure and temperature only if leakage through the inboard valves occurs. To perform the ASME Code required pressure test, it would be necessary to manually open the inboard valves to pressurize the piping and connections.

Pressurization by this method defeats the double isolation and reduces the margin of personnel safety for those performing the test. Furthermore, performing the test with the Inboard isolation valves open requires several man-hours to position the valves for the test and restore the valves to their closed positions once the test is completed.

These valves are located in close proximity to the RCS loop piping and thus would require personnel entry into high radiation areas within the containment and a consequent increase in radiation exposure. Since this test would be performed near the end of an outage when all RCS work has been completed, the time required to open and close these valves would Impact the outage schedule. Thus, compliance with this specific Code requirement results in unnecessary hardship pursuant to IOCFR50.55a(a)(3)(ii) without a compensating increase in the level of quality and safety.

Also, HNP design of Class 1 process piping requires substantial effort to extend the Class 1 system boundary where check valves or non-redundant components serve as the first system isolation from the reactor coolant system. Such configurations may require check valve disassembly or other temporary configurations to achieve test pressures at upstream piping and valves. Since the Class 1 system pressure testing is performed in Mode 3, these temporary configurations could conflict with Technical Specification requirements. Establishing and restoring such temporary configurations could also result in an unwarranted increase in worker radiation exposure.

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I Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION XI, IWA-4000 REQUIREMENTS Based on the above, extension of the pressure-retaining boundary during system leakage tests to Class 1 pressure retaining components within the system boundary represents a hardship and unusual difficulty that does not provide a compensating increase inthe level of quality and safety.

The following is specific information pertaining to the various pipe segments for which relief has been requested.

Small Size Class I Vent, Drain. Test, and Fill Lines Relief is requested from fully pressurizing piping between the first and second isolation device on small size vent, drain, test, and fill lines. There are twenty-six vent, drain, test and fill lines in the Reactor Coolant System (RCS) ranging in size from 0.5 inch to two inches. The configurations are two small isolation valves in series. The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary. The Code-required leakage test would be performed in MODE 3 at the normal operating pressure of 2235 psig and at a nominal temperature of about 557 0F.

Leakage testing of these piping segments at nominal operating pressure in MODE 3 would require the opening of the inboard isolation valve at the normal operating RCS temperature and pressure conditions. In so doing, the design requirement for two primary coolant pressure boundary isolation devices would be violated. Additionally, opening these valves introduces the potential risk for spills and personnel contamination.

These piping segments are VT-2 inspected through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. The leakage test will not specifically pressurize past the first isolation valva for this inspection. No external or visible leakage will be allowed for a test to be successful. Since this type of test will assure that the combined first and second isolation devices are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure, the increase in safety achieved from the Code-required leakage test is not commensurate with the hardship of performing such testing.

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Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1-015 ALTERNATIVE TO ASME CODE SECTION Xi, IWA-4000 REQUIREMENTS Larger Size Class 1 Piping Segments 12 Inch Residual Heat Removal Motor Operated Valves This piping segment consists of two 86-foot run of piping between Residual Heat Removal (RHR) inlet valves 1RH-39 & 40, and 1RH-I & 2. These valves are interlocked at a required setpoint of <363 psig to avoid over-pressurization of the RHR system. The interlock prevents manual opening of the valves from the Control Room with RCS pressure above the setpoint.

The piping segment is VT-2 inspected through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. The proposed system pressure test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. No external or visible leakage will be allowed for the test to be successful. This test will provide assurance that the combined first and second isolation valves are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure.

Safety Injection Loops Low Head Check Valves ISI-250, 252, & 254, and Upstream Piping These three piping segments each consist of a 26-28 foot run of piping along with a short 1.00 inch connection. These lines are for injecting low head Emergency Core Cooling System (ECCS) water from the accumulators and the low head safety injection system (i.e., RHR system in ECCS configuration). The primary isolation and secondary isolation devices for the 12 inch lines are check valves oriented to flow into the RCS.

The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary.

Leakage testing in MODE 3 would require a pressure source be connected at each segment location. in so doing, the design requirement for two primary coolant pressure boundary isolation devices would be violated. For test locations located overhead and away from normal personnel access areas, ladders or scaffolding would have to be installed to provide access to the piping segment and to open the valve. This process would lead to the occupational dose associated with leakage testing these lines.

These lines are located in areas involving occupational radiation exposure, and leakage testing of these lines would increase occupational radiation dose.

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Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION XI, IWA-4000 REQUIREMENTS The leakage test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. Otherwise, the pressure in the segment will be at least at the operating pressure of the cold leg accumulators, which are pressurized to between 585 and 665 psig. No external or visible leakage will be allowed for the test to be successful.

Since this test will assure that the combined first and second isolation devices are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure, the increase in safety achieved from the Code-required leakage test is not commensurate with the hardship of performing such testing.

Safety Injection Loops High Head Check Valves ISI-81, 82, 83, 136, 137 & 138, and Upstream Piping These six piping segments each consist of a 2-inch and 6-inch piping span between two check valves oriented toward the RCS. These lines are for injecting high head ECCS water into the hot and cold legs after an accident. The primary and secondary isolation devices are check valves oriented to flow into the RCS. The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary.

Leakage testing of these piping segments at nominal operating pressure in MODE 3 would require a modification to allow pressurizing to the normal operating RCS temperature and pressure conditions.

The leakage tests will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. No external or visible leakage will be allowed for the test to be successful. This test will assure that the combined first and second isolation valves are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure.

Proposed Altemate Exarnbatiognus The Class I system boundary during leakage tests will be maintained in a normal, operational alignment with items identified within Table 1 constituting exceptions to the Code-required boundary. The 8/T-2 visual examination will extend to the Class 1 pressure boundary.

Items within Table I will be visually examined for evidence of leakage during system leakage testing without being pressurized.

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Attachment 1to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION Xi, IWA-4000 REQUIREMENTS Implementation Schedule This Relief Request is applicable to the HNP Second 10-year Inservice Inspection Interval.

Precedents Similar request for relief was approved for H. B. Robinson Plant Unit No. 2 (TAC No.

MB2773), and Pilgrim Nuclear Power Station (TAC No. MC1472). Similar request for relief was submitted for approval for Indian Point Unit No. 2 (Docket No. 50-247),

FitzPatrick Nuclear Power Plant (Docket No. 50-333), and Indian Point Units No. 2 & 3 (Docket No. 50-247 and 50-286).

Note that ASME Code has recently approved Code Case N-731, Alternative Class 1 System Leakage Test Pressure Requirements. The code case allows "for portions of Class 1 safety injection systems that are continuously pressurized during an operating cycle, the pressure associated with a statically-pressurized passive safety injection system of a pressurized water reactor may be used."

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Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION Xi, IWA-4000 REQUIREMENTS Table 1: Relief Request Number 2R1 -015 Affected Class 1 Pressure Retaining Components - Examination Category B-P ip Affected Line or Component PipeP (in.) JSchedule Appro l Lengthiln9sl xDiamterg NO.

Length DrwnNoBudayEcpins Loop Drain Line 2 SCH 160, A- 2165-S-1 300 Valve 1RC-7 remains closed to Isolation Valve 376 TP304 < 1 ft. 2165-G-800 avoid pressurizing downstream

____ __ __ __ _ __ __ __ _____ 21 65-G-1 29 Class I pipe and valve I RC-8 Loop Drain Line 2 SCH 12165-S-1 300 Valve 1RC-1 6 remains closed to Isolation Valve 2 376 TP304 < t 21 65-G-800 avoid pressurizing downstream Isolation Valve_

___ 11 2165-G-1 29 Class 1 pipe and valve 1RC-1 7 Loop Drain Line 2 SCH 160, A- 2165-S-1 300 Valve 1RC-28 remains closed to Isolation Valve 2 376 TP304 < 1ft. 21 65-G-800 avoid pressurizing downstream Isolation____

Valve 376 TP304 y 2165-G-1 29 Class 1 pipe and valve 1RC-29 Pressurizer Valve I RC-1I0 remains closed PORV Vent Line SCH 160, A- 2165-S-1 301 to avoid pressurizing on Primary 0.75 376 TP304 0.5 ft. 2165-G-801 downstream Class i pipe and Sample Path off 21 65-G-1 48 downsteam RClas Ippean Pressurizer valve 1RC-1 Instrument Vent Line on 2165-S-1301 VleC94rmiscoe Pressurizer Level 0.5 SCH 160 A- 0.5 ft. 2165-G-801 to avoed pressurizing Instrument Loop 376 TP304 2165-G-147 downstream Class 1 pipe and I LT-459 valve 1RC-985 Line on 2165-S-1301 Valve I RC-986 remains closed Pressurizer Level 0.5 SCH 160, A- 0.5 ft. 2165-G-801 to avoid pressurizing Instrument Loop 376 TP304 2165-G-147 downstream Class I pipe and I LT-460 valve 1RC-987 Instrument Vent Valve I RC-988 remains closed Line Lineon on SCH 160, A- 0.5 ft 2165-S-1301 2165-SI01 VleC98rmiscoe to avoid pressurizing Instrument Loop 376 TP304 . 2165-G-147 downstream Class 1 pipe and I1LT-461 valve 1RC-989 Check valve to remain closed to avoid disassembly or other CVCS temporary configurations Pressurizer Spray 2 < 1 ft. 2165-S-1303 required to achieve test Downstream CV SCH 160, A- 2165-G-803 pressures at upstream piping and Test 376 TP304 2165-G-1 37 and valves 1CS-491 and 1CS-Connection 2165-G-1 39 488 Isolation Valve Valve 1CS-489 remains closed I 1.5 ft. to avoid pressurizing downstream Class 1 pipe and valve 1CS-490 Page A1-7 of 11

Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1-015 ALTERNATIVE TO ASME CODE SECTION XI, IWA-4000 REQUIREMENTS TABLE 1: RELIEF REQUEST NUMBER 2R1 -015 AFFECTED CLASS 1 PRESSURE RETAINING COMPONENTS - EXAMINATION CATEGORY B-P AfetdLn r Pipe }Appro Component i ICompne Diameter (in.) Pipe Schedule Lnt xepgo Drawing No. Boundary Exception(s)

Check valve to remain closed to avoid disassembly or other temporary configurations Norm Charging 2 < I ft. 2165-S-1 303 required to achieve test Line Upstream SCH 160, A- 2165-G-803 pressures at upstream piping CV and Test 376 TP304 2165-G 37 and valves 1CS-500 and 1CS-Connection 42165G1 397 Isolation Valve  ; -- Valve 1CS-498 remains closed 1 1.5 ft. to avoid pressurizing downstream Class 1 pipe and valve 1CS-499 Check valve to remain closed to avoid disassembly or other temporary configurations Alt Charging Line 2ft. 21 65-S-1 303 required to achieve test Upstream CV and SCH 160, A- 2165-G-803 pressures at upstream piping Test Connection 376 TP304 21 65-G-1 37 and valves I CS-486 and I CS-Isolation Valve 2165-G-1 39 483 Valve 1CS-484 remains closed 1 1.5 ft. to avoid pressurizing downstream Class 1 pipe and valve 1CS-485 Valve 1CS-460 remains closed Upstream 1 C 1A .5ft. 2165--03 to avoid pressurizing Isolation Valve 376 TP304 21 65-G-1 38 downstream Class I pipe and

____ ___ ____ __ ____ ___ ___ ___ ____ ___ ___ valve I C S-461 Check valve to remain closed to avoid disassembly or other Between 12 SCH 140, A- 26 2165-S-1309 temporary configurations Accumulator IA- 376 TP316 216 809 required to achieve test SA Discharge CV 2165-G-804 pressures at upstream piping and Si to RCS 65-G-154 and valves 1SI-249 and 1SI-250 Loop OA CV SCH 160 A- _65-G-121 Valve 1SI-273 remains closed to 1376 TP304 2 avoid pressurizing downstream Class 1 pipe and valve 1SI-274 Check valve to remain closed to avoid disassembly or other Between 12 CH 140, A- 28 2165-S-I 309 temporary configurations Accumulator I B- 376 TP316 2165-G-809 required to achieve test SB Discharge CV 2165-G-154 pressures at upstream piping and Sl to RCS - 265-G5 -5 and valves 1SI-251 and ISI-252 Loop gB" CV SCH 160 A- Valve 1SI-275 remains closed to 1 376 TP304 2 avoid pressurizing downstream Class I pipe and valve 1SI-276 Page A1-8 of 11

Attachment I to HNP Seral No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1-015 ALTERNATIVE TO ASME CODE SECTION XI, IWA-4000 REQUIREMENTS TABLE 1: RELIEF REQUEST NUMBER 2R1-015 AFFECTED CLASS 1 PRESSURE RETAINING COMPONENTS - EXAMINATION CATEGORY B-P Pipe Appro Affected Line or Diameter Pipe x DrwnNoBudayEcpins Component (in.) Schedule Length DrawingNo. BoundaryException(s)

Check valve to remain closed to avoid disassembly or other Between 12 SCH 140, A- 26 2165-S-1 309 temporary configurations Accumulator 1C- 376 TP316 21-G-809 required to achieve test SA Discharge CV 21 65-G -154 pressures at upstream piping and Si to RCS . 2165G 155 and valves 1SI-253 and 1SI-254 Loop "C" CV SCH 160, A- Valve 1S I-277 remains closed to 376 TP304 2 avoid pressurizing downstream Class 1 pipe and valve 1SI-278 Valves 1RH-39 and 1RH-40 SCH 140S, remain closed to avoid over-RCS Loop to 12 A-376 86 2165-S-1324 pressurization of the RHR RHR Pump "B" TP31'6265G24 stm Isolation aind1 A 2165-G-155 Valve 1RH-41 remains closed to De 10 A- 2 avoid pressurizing downstream 376 TP304  : Class 1 pipe and valve 1RH-42

. H 1Valves 1RH-1 and 1RH-2 remain SCH.40S . closed to avoid over-RCS LPop to 3-376 86 2165-S-1324 pressurization of the RHR RH um A T362166-G-824 systemW Isolation and 2165-G-155 Valve 1RH-3 remains closed to 1 3Ln TP10, 2 avoid pressurizing downstream

.376 TP34 Class 1 pipe and valve 1RH-4 6 38 Check valve to remain closed to 2 68 avoid disassembly or other temporary configuratikns RCS Cold Leg i2165-S-1310 required to achieve test Cold Leg 2 3 2165-G-810 pressures at upstream piping Loop 1 SIS, ;15S10 n avs118,II36 S-Boron injection, SCH 160, A ;15~- 0 n avs I8,1S-5,1S-and CVCS paths. 376 TP304 _ 21 65-G-808 8, and .1S-72 2165-G-154 Valve 1SI-27 remains closed to 1 1.5 2165-G-1 55 avoid pressurizing downstream 21 65-G-1 56 Class 1 pipe and valve 1SI-28 Valve 1SI-79 remains closed to 1 1.5 avoid pressurizing downstream Class 1 pipe and valve 1SI-80 Page A1-9 of 11

Attachment I to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1 -015 ALTERNATIVE TO ASME CODE SECTION Xi, IWA-4000 REQUIREMENTS

. I  ; ,; " 1 1~~-

TABLE 1: RELIEF REQUEST NUMBER 2R1-015 AFFECTED CLASS 1 PRESSURE RETAINING COMPONENTS - EXAMINATION CATEGORY B-P Affected Line or Diameter Schiue Length Drawing No. Boundary Exception(s) 6 33 Check valve to remain closed to 2 83 avoid disassembly or other temporary configurations 2165-S-1310 required to achieve test Class 1 piping 2 7 2165-G-810 pressures at upstream piping from Residual A 2165-S-1 308 and valves ISI-82, 1SI-357, 1SI-Heat Exchanger SCH 160, - 2165-G-808 9, and 1SI-73 to RCS Cold Leg 6 3 2165-G-1 54 Valve 1SI-33 remains closed to Loop 2. 1 1.5 2165-G-1 55 avoid pressurizing downstream 2165-G-156 Class 1 pipe and valve 1SI-34 Valve 1SI-75 remains closed to 1 1.5 avoid pressurizing downstream Class 1 pipe and valve 1S1-76 6 25.5 Check valve to remain closed to 2 49.5 avoid disassembly or other temporary configurations 2165-S-1310 required to achieve test Class 1 piping 2 1.5 2165-G-810 pressures at upstream piping from Residual SCH 160 A- 2165-S-1 308 and valves 1SI-83, 1SI-358, 1SI-Heat Exchanger 3CH 160, 2165-G-808 10, and 1SI-74 to RCS Cold Leg 376 TP304 2165-G-154 Valve 1SI-39 remains closed to Loop 3. 1 1.5 2165-G-1 55 avoid pressurizing downstream 2165-G-156 Class 1 pipe and valve 1SI-40 Valve 1Sl-77 remains closed to 1 1.5 avoid pressurizing downstream Class 1 pipe and valve 1S 1-78 6 43 Check valve to remain closed to 2 2.5 avoid disassembly or other Class 1 piping temporary required toconfigurations Class1idual 2165-S-1 308 achieve test from Residual 2 SCH 160, A- 2.5 2165-G-808 pressures at upstream piping Heat Exchanger 376 TP304 2165-G-154 and valves 1SI-136, 1SI-134, to RCS Hot Leg 2165-G-1 56 1SI-104, and 1SI-127 Loop I. Valve 1Sl-376 remains closed to 1 1.5 avoid pressurizing downstream Class 1 pipe and valve 1SI-377 Page Al-10 of 11

• , . V Attachment 1 to HNP Serial No. HNP-05-128 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST FROM INSERVICE INSPECTION PROGRAM NO. 2R1-015 ALTERNATIVE TO ASME CODE SECTION XI, IWA-4000 REQUIREMENTS TABLE 1: RELIEF REQUEST NUMBER 2R1-015 AFFECTED CLASS I PRESSURE RETAINING COMPONENTS - EXAMINATION CATEGORY B-P Pipe Appro Affected Line or DimtrPipe x DrwnNoBudayEcpins Component (in.) Schedule Length Drawing No. Boundary Exception(s) 6 44.5 Check valve to remain closed to 2 2.5 avoid disassembly or other

s. ptemporary configurations Class 1 piping 2165-S-1308 required to achieve test from Residual 2 SCH 160, A- 2.5 2165-G-808 pressures at upstream piping Heat Exchanger 376 TP304 2165-G-1 54 and valves 1SI-137, 1SI-1 35, to RCS Hot Leg 2165-G-156 1SI-105, and 1SI-128 o Valve 1SI-1 32 remains closed to 1 1.5 avoid pressurizing downstream

_Class 1 pipe and valve 1S-133 6 1 Check valve to remain closed to 2 42.5 avoid disassembly or other Class 1 piping 2 21 3 temporary configurations fromaRes1pidua 2165-S-1 308 required to achieve test from Residual SCH 160, A- 2165-G-808 pressures at upstream piping Heat Exchanger 2 376 TP304 2165-G-1 54 and valves 1SI-1 38, 1SI-1 06, to RCS Hot Leg 2165-G-1 56 and 1SI-129 Lo 3. Valve 1SI-130 remains closed to 1 1.5 avoid pressurizing downstream A Class 1 pipe and valve 1S-1 31 PageAl-11 of 11