HNP-08-099, Relief Request from ASME Boiler and Pressure Vessel Code, Section XI Requirements for the Service Water System

Relief Request from ASME Boiler and Pressure Vessel Code,Section XI Requirements for the Service Water System

ML083030139
Person / Time
Site:	Harris
Issue date:	10/24/2008
From:	Corlett D Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-08-099
Download: ML083030139 (15)

Text

Progrss E ergySerial:

HNP-08-099 Progress Energy 110 CFR 50.55a OCT 2 42008 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 ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI REQUIREMENTS FOR THE SERVICE WATER SYSTEM Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.55a, "Codes and Standards," paragraph (g)(5)(iii), the Harris Nuclear Plant (HNP) of Carolina Power and Light Company, doing business as Progress Energy Carolinas, Inc., submits the following request for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2001 Edition with addenda through 2003. This Relief Request is associated with HNP's Third Ten-Year inservice inspection (ISI) interval.

Approval is requested for deferral of code repair of a flaw in an ASME Code Class 3 piping socket weld in the HNP Service Water (SW) system. Per Generic Letter (GL) 90-05, code repair of the identified flaw at this time is impractical. The flaw, detected during plant operation, is in a section of Class 3 piping that cannot be isolated for completing a code repair within the time period permitted by the applicable Technical Specifications (TS) Limiting Condition for Operation (LCO). Since a code repair would therefore necessitate a plant shutdown, HNP requests NRC approval to defer implementation of code repairs to no later than the next scheduled refueling outage, as permitted by GL 90-05.

Emergency Service Water (ESW) weld 1-SW-172-FW-178 indicates past leakage although there is currently no leakage observed from the area of the weld. Evaluation of the flaw in accordance with the fracture mechanics methodology provided in GL 90-05 has determined that the structural integrity of the SW piping is not adversely affected by this flaw.

The attached relief request addresses the present condition of the weld and implementation of the compensatory actions taken per GL 90-05. Operability and functionality of the system have been maintained, and HNP has concluded that deferring repair of the flaw will not affect the health and safety of the public. Since 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(g)(5)(iii). contains the proposed HNP relief request (13R-05).

Progress Energy Carolinas, Inc.

Harris Nuclear Plant 7

P. O. Box 165 New Hill, NC 27562

HNP-08-099 Page 2 contains the Regulatory Commitments associated with this request.

Please refer any questions regarding this submittal me at (919) 362-3137.

Sincerely, D. H. Corlett Supervisor - Licensing/Regulatory Programs Harris Nuclear Plant DHC/jmd Attachments:

1.

2.

HNP Relief Request 13R-05 HNP Regulatory Commitments cc:

Mr. K. J. Korth, Acting NRC Senior Resident Inspector, HNP Mr. Larry Jones, Harris Plant Authorized Nuclear Inservice Inspector Mr. L. A. Reyes, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager, HNP to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 Request for Relief for Temporary Non-Code Repair of Service Water Piping Drain in Accordance with 10 CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1.0 ASME CODE COMPONENT AFFECTED (a)

==

Description:==

Socket-to-piping carbon steel weld on line 3SW1-267SA-1, a one inch grab sample location and floor drain via isolation valve 1 SW-272. This piping section is welded to line 3SW30-25SA-1, the "A" Train Emergency Service Water (ESW) discharge header to the Auxiliary Reservoir.

(b)

Function:

The ESW system provides cooling water to remove heat from essential plant heat loads associated with reactor auxiliary components for dissipation in the plant ultimate heat sink during emergency operation. The Operability of the ESW System ensures that sufficient cooling capacity is available for continued.

operation of safety-related equipment during normal and accident conditions.

(c)

Class:

ASME Code Class 3 (d)

Description of the flaw:

A rust stain and moisture indicative of a through-wall leak was found on the carbon steel socket-to-piping weld on drain line 3SW1-267SA-1 off the "A" Train ESW Return line to the Auxiliary Reservoir. The pinhole leak appears to be on the weld rather than the pipe wall, an indication of crevice corrosion versus general corrosion leading to uniform wall loss. Crevice corrosion, a localized phenomenon that does not propagate outwards from the initial leak location, has commonly been found at welds in the HNP Service Water (SW) system. There is currently no indication of measureable leakage.

(e)

Flaw Detection:

The flaw was identified on May 16, 2008, at approximately 15:30 during operator rounds. The plant was in Mode 1 at 100% power.

Page Al-1 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 2.0 APPLICABLE CODE EDITION AND ADDENDA ASME Boiler and Pressure Vessel Code,Section XI, 2001 Edition with addenda through 2003.

3.0 APPLICABLE CODE REQUIREMENT Per NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations

& Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," Section C. 12, "If a leak is discovered in a Class 1, 2, or 3 component while conducting an inservice inspection, maintenance activity, or during facility operation, any corrective measures to repair or replace the leaking component must be performed in accordance with IWA-4000 of Section XI."

Article IWA-4000 (Repair/Replacement Activities) provides the requirements for performing repair/replacement activities on components and their supports. This is used whenever a flaw is discovered that does not meet the ASME requirements.

Per IWA-41 10 of IWA-4000 (Scope):

(a) The requirements of this Article apply regardless of the reason for the repair /replacement activity or the method that detected the condition requiring the repair/replacement activity.

(b) This Article provides requirements for repair/replacement activities associated with pressure retaining components and their supports, including appurtenances, subassemblies, parts of a component, core support structures, metal containments and their integral attachments, and metallic portions of Class CC containments and their integral attachments. Repair/replacement activities include welding, brazing, defect removal, metal removal by thermal means, rerating, and removing, adding, and modifying items or systems. These requirements are applicable to procurement, design, installation, examination, and pressure testing of items within the scope of this Division.

Relief is requested from these Article IWA-4000 requirements to defer the code repair of the identified through-wall flaw until the next outage of sufficient duration, but no later than the next refueling outage, provided the conditions of Generic Letter (GL) 90-05, "Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping," are met.

Page A1-2 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 4.0 IMPRACTICALITY OF COMPLIANCE Per GL 90-05, an ASME Code repair is required for Code Class 1, 2, and 3 piping unless specific written relief is granted by the NRC. Relief is appropriate When performing the repair at the time of discovery is determined to be impractical.

In accordance with this GL, impracticality is defined to exist if:

• The flaw detected during plant operation is in a section of Class 3 piping that cannot be isolated to complete a code repair within the time period permitted by the limiting condition of operation of the affected system as specified in the plant Technical Specifications, and

• Performance of code repair necessitates a plant shutdown.

The identified flaw is a pinhole leak through the middle of a socket welded joint. The welded joint joins the 1-inch drain pipe to a 1-inch sockolet fitting. The 1-inch sockolet fitting is welded to the ESW "A" Train Discharge Header, 3SW30-25SA-1. To repair this weld, the 30" ESW system will need to be taken out of service and drained.

Additionally, several other portions of the ESW and its associated components will need to be taken out of service while this train is being repaired.

The HNP Technical Specifications (TS) Limiting Condition for Operation (LCO) associated with the ESW System is:

3.7.4 At least two independent emergency service water loops shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

With only one emergency service water loop OPERABLE, restore at least two loops to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Since the identified repair cannot be performed in the above TS timeframe allowed for operating with one train of the emergency service water loops out of service, impracticality exists in accordance with the above GL 90-05 definition.

Page A1-3 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 5.0 BURDEN CAUSED BY COMPLIANCE In order to comply with the Code requirement, the plant would need to be shut down to perform the repair. As noted in GL 90-05, "The rather frequent instances of small leaks in some Class 3 systems, such as service water systems, could lead to an excessive number of plant start-up and shutdown cycles with undue and unnecessary stress on facility systems and components if the facilities were to perform a code repair when the leakage is identified."

Since the NRC staff has determined that temporary non-code repair of Class 3 piping that cannot be isolated without a plant shutdown is justified in some instances, HNP requests approval for this temporary non-code repair of code Class 3 piping, based on the impracticality in performing an ASME Code repair while the plant is operating.

6.0 PROPOSED ALTERNATIVE AND BASIS FOR USE Per the guidelines of GL 90-05, HNP is proposing to defer repair of the identified flaw until the next scheduled outage exceeding 30 days but no later than the next refueling outage, currently scheduled to begin in April 2009. To ensure that the acceptance criteria of GL 90-05 continue to be met, HNP has implemented compensatory actions to. detect changes in the condition of the identified defect.

6.1 SCOPE An indication of a through-wall leak was found on the carbon steel socket-to-piping weld on drain line 3SW1-267SA-1 off the "A" Train ESW Return line to the Auxiliary Reservoir. The pinhole leak appears to be on the weld rather than the pipe wall, an indication of crevice corrosion rather than general corrosion leading to uniform wall loss.

There is rust from the sockolet to the pipe weld and down the side of the pipe to the next socket weld where any leakage would drop to the floor. Based on field inspection, the size of this pinhole in ESW weld 1-SW-172-FW-178 was measured to be less than 1/16" diameter. The ESW system is currently in operation with no evidence of active measureable leakage from the weld.

Deferral of the code repair of the identified through-wall flaw will not impact the capability of the ESW system to perform its intended safety-related function, based on the following:

• The current loss of flow from the ESW system is negligible compared to the total system flow. Even with a conservatively estimated leak rate of one drop every five Page A1-4 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 minutes, the minimum design ESW flow through the "A" Train Header.is approximately 16,000 to 18,000 gpm; The leak is on the weld and not the pipe wall. Based on past ESW through-wall leak analyses, a weld leak is indicative of crevice corrosion which typically creates a localized flaw with no mechanism to propagate rapidly into the adjoining pipe or tee section. Therefore, the leak will not expand significantly unless a new failure mechanism is introduced; There is no concern of diversion of flow since the leak is downstream of all ESW loads and is very small; Based on Non-Destructive Evaluation (NDE) Ultrasonic Testing (UT) measurements adjacent to the weld and on the HNP Civil/Structural Design Engineering evaluation, there is no impact on the structural integrity of the ESW line involved; The leak is not affecting any other equipment important to safety in the immediate area; In accordance with the guidance in GL 90-05, an augmented inspection of five other similar locations has been performed. These inspections did not reveal any locations approaching minimum wall thickness or any areas of concern. The measurements also indicate that a system wide failure mechanism is unlikely to be the cause of the subject leak.

6.2 SPECIFIC CONSIDERATIONS There are no other identified leaks in the ESW System at this time. An augmented inspection of five other similar locations was performed in accordance with GL 90-05 to determine the extent of condition. NDE (UT) measurements did not reveal any piping approaching minimum wall or any other areas of concern. All of the data points taken were above minimum wall required.

Per Engineering Change (EC) 66198, the minimal acceptable wall thickness for service water piping is the greater of either 0.080" or 0. 3xTnom, where Tnom is the nominal wall thickness. For all lines evaluated in this case, the bounding thickness is 0.080". The lowest wall thickness reading on each line is shown in the last column. For all locations, the lowest wall thickness is 0.126" on line 3SW1-268SB-1, which is an acceptable value.

However, for purposes of conservatism, this line will be replaced in the next "B" Train refueling outage.

Page Al-5 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 Line #

Near Valve Tnominal (in)

Tmin, actual (in) 7SW1-196-1 1SW-279 0.133 0.149 3SWI-192SA-1 1SW-48 0.179 0.150 3SWI-172SB-1 1SW-46 0.179 0.149 3SW1-268SB-1 1SW-273 0.179 0.126 3SWI-160SB-1 1SW-38 0.179 0.150 3SWI-158SA-1 1SW-37 0.179 0.153 In addition, visual inspection of the following similar drain lines in the Reactor Auxiliary Building (RAB) 216 pipe tunnel was made as part of the evaluation: 1 SW-46, 1 SW-48, 1 SW-279, & 1 SW-273. The inspection did not reveal any other active leaks or signs of potential leaks (moisture, blistering of paint, or corrosion product buildup). Therefore, there is no indication of a failure mechanism that would challenge the system as a whole.

The pinhole leak will be repaired by replacing line 3SW1-267SA-1 in RFO-15. Until replacement is complete, a compensatory measure has been put in place for Operations to monitor the leak at least weekly, which meets the requirements of GL 90-05. In accordance with the guidance in GL 90-05, UT measurements of the area of the leak will be taken every three months until the leak is repaired.

6.3 CAUSE OF LEAK The leak is on the weld between the 1 inch socket and the piping upstream of valve 1SW-272 (line 3SW1-267SA-1). The drain line is for the "A" ESW Return Header (line 3SW30-25SA-1). The pinhole leak is not at the weld toe, but appears to emanate from the middle of the weld and is attributed to crevice corrosion. Crevice corrosion is a localized phenomenon that results in wall thinning and has occurred on other ESW piping in the past at HNP, especially at welds. The toe of welds or gaps between layers of weld bead act as the 'crevices' in which local corrosion cells develop. Also, a single flaw or defect in the weld material can create a site for an active corrosion cell which will eventually corrode through the weld material and create the leak path. Based on past inspections where through-wall leaks have occurred, this phenomenon is localized and does not propagate outwards from the initial leak location.

Due to the localized nature of this mechanism, the overall material loss resulting from the corrosion is generally minimal. In this way it is similar to pitting corrosion. UT measurements around the area of the leak verify that wall loss of the general area is not of concern. Further data has verified that wall loss resulting from corrosion does not propagate outwards and is localized. The dimensions of the flaw are provided on page AI-12 of 12. The lowest wall thickness reading adjacent to the leak was 0.130" (after a Page A1-6 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 0.015" reduction due to paint thickness). A structural evaluation for this line performed by HNP Design Engineering indicates that there is no concern of failure.

6.4 STRUCTURAL INTEGRITY OF LINES NDE (UT) measurements were taken adjacent to the affected weld and at augmented locations by a qualified HNP Quality Control (QC) inspector.

The leak and surrounding UT data have also been evaluated by HNP Mechanical/Civil Design Engineering. The results are as follows:

Pipe 3SW1-267SA-1 was reported leaking at the weld on the weld side of the 1" sockolet from line No. 3SW30-25SA-1. The applicable stress analysis node point is 1997; Maximum pipe stress ratio from Calculation 8050-54 at this location is 0.466; A Flaw Evaluation was performed in accordance with GL 90-05. The flaw evaluation demonstrates that the piping with the pinhole leak is structurally adequate.

Based on the above, this leak does not represent a concern for the structural integrity of the 1" drain line 3SW1-267SA-1.

6.5 FLAW EVALUATION In accordance with GL 90-05, "through-wall" flaw evaluation criteria was used to evaluate the pinhole leak in ESW ASME Section III, Class 3 piping line 3SW1-267SA-

1. The referenced GL 90-05 is applicable to ASME Section III, Class 3 piping.

The flaw is a pinhole leak through the middle of a socket welded joint. Although an accurate measurement of the pinhole diameter is difficult to obtain, the size of the pinhole was measured to be less than 1/16" diameter based on field inspection. The welded joint joins the 1-inch drain pipe to a 1-inch sockolet fitting. The 1-inch sockolet fitting is welded to the ESW "A" Train Discharge Header, 3SW30-25SA-1 in the RAB 216' pipe tunnel. The pinhole, which is a planar flaw, is a small hole that most likely extends in the axial direction toward the fitting. It is located where there is stagnant water between the outer diameter of the pipe and the inside diameter of the sockolet fitting. Both the circumferential and axial flaw methodologies were performed for conservatism.

Page A1-7 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 UT measurements of the pipe wall thickness were obtained around the pipe just below the weld containing the pinhole. The paint thickness is estimated to be 0.015" thick.

The lowest reading is 0.130" (0.145" less 0.015" for coatings), located just below the pinhole. Other than below the pinhole, the pipe thickness varies between 0.170" and 0.180" around the pipe circumference.

Since the UT measurements indicate some wall thinning, the minimum wall thickness evaluation was also performed, in addition to the circumferential and axial flaw evaluations. The allowable stress for ASTM A106, Grade B, pipe material is:

S = 15000 psi reference ASME Section III, Appendices The pipe properties for 3SW1-267SA-1 (1-inch, schedule 80 pipe) are:

Do= 1.315 in tnom = 0.179 in reference: Engineering Design Basis (EDB),

Calculation 8050-54 and NAVCO Piping Datalog t = 0.130 in Actual measured thickness used for flaw evaluation which is greater than tmin The operating temperature is 125 deg F, design pressure is 150 psig (reference EDB) p = 150 psi T = 125 deg The minimum required wall thickness for hoop stress per ASME Section III is:

p Do tm 2(S + 0.4p) tm = 0.007 in The applicable pipe stress calculation 8050-54 shows the maximum stress ratio is 0.466.

The section modulus for 1-inch pipe, schedule 80, is 0.1606 in 3. The minimum wall thickness measured is 0.130". The section modulus for 1-inch pipe with a uniform thickness (conservative) of 0.130" is 0.1308 in 3. The maximum stress ratio based on the reduced wall thickness is 0.572. The stress levels are less than the normal allowable with a reduced wall thickness.

The "through-wall" flaw evaluation is as follows:

Allowable Stress Intensity Factor ksi = 1000 psi Page A1-8 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 The allowable stress intensity factor (K) for determining the acceptability of flawed piping is:

Ksi = 35 ksi(in)"'

CS allowable stress intensity factor for flaws (reference NRC GL 90-05)

Circumferential Flaw Evaluation The following through-wall flaw evaluation is performed in accordance with GL 90-05,, Section C.3.a. The stress intensity factor for through-wall flaw (including safety factor of 1.4) is:

K = 1.4 (s)(F)(3.1416*a)0 5 where the geometry factor "F" is:

F = 1 + (A)(c)' 5 + (B)(c)2 5 + (C)(c)35 where:

"2a" equals the flaw length, in. (reference GL 90-05);

"s" equals the combination of deadweight, pressure, thermal, seismic stresses; R = mean pipe radius a = 0.0625 in Note: The flaw length (2a) is basically the diameteJr of the pinhole which is less than 1/16". However, 1/16" is conservatively used for "a".

R = Do-t R = 0.593 in.

2 Moment Stress due to Deadweight and Pressure:

Moment Stress due to DBE Seismic:

Combined stress is:

Nomenclature:

MA = 1464 psi MBE = 11340 psi S = MA + MBE = 12804 psi A = -3.26543 + 1.52784 0.072698 (

+ 0.0016011 3

A = 2.339 Page A1-9 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 B = 11.36322 - 3.91412

+ 0.18619 (R-0.004099 B =-2.997 2

3 C

-3.18609 + 3.84763 (R) -

0.18304 (R) + 0.00403 (M)

C 10.93 a

c --

c = 0.034 3.1416 R F = 1 + (A)(c)' 5 + (B)(c)2 5 + (C)(c) 3 5; F = 1.014 K = 1.4 (s)(F)(3.1416*a)° 5 K = 8.053 ksi(in)0 5 less than Ksi = 35 ksi(in)° 5 6.6 AUGMENTED INSPECTIONS There are no operating mode restrictions associated with this condition. The leak will be visually inspected weekly by Operations until it is repaired in RFO-15. Normal walkdowns are performed by system engineers once every quarter in accordance with 10 CFR 50.65, Maintenance Rule. This increase in periodicity of inspection is in accordance with the criteria of GL 90-05, which recommends that a qualitative assessment of leakage be performed at least weekly to determine any degradation of structural integrity. In addition, Ultrasonic measurements of the area where the flaw is located will be performed every three months, as required by GL 90-05.

The leak will be permanently repaired by piping replacement or a code weld repair in RFO-15.

6.7 CONCLUSION

The minimum wall thickness, maximum bending stress and through-wall flaw evaluations performed for the pinhole flaw demonstrate that the piping, including the weld joining the pipe to the sockolet for line 3SW1-267SA-1, is structurally adequate in accordance with the guidance provided in GL 90-05. The flaw was evaluated using the through-wall flaw fracture mechanics methodology provided by NRC Generic Letter 90-05, which is a conservative approach to evaluating the pinhole leak.

Since the flaw in line 3SW 1 -267SA-1 satisfies the criteria of the above evaluation approach, it is acceptable to propose a temporary non-code repair of the code Class 3 piping in accordance with GL 90-05. Furthermore, the provisions of the through-wall flaw evaluation Page Al-10 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a REQUEST: 13R-05 Revision 0 per GL 90-05 demonstrate that the structural integrity of the ESW piping components is not adversely affected by this defect.

Based on the above analysis, HNP is requesting NRC approval per 10 CFR 50.55a(g)(5)(iii) to defer ASME Section XI IWA-4000 repair/replacement requirements for the identified flaw in accordance with the guidance provided in GL 90-05.

7.0 DURATION OF PROPOSED ALTERNATIVE Repair of the defect will be deferred until the next scheduled outage exceeding 30 days, but no later than the next refueling outage, provided the condition continues to meet the acceptance criteria of Generic Letter 90-05. HNP is currently monitoring the leak location for any changes, specifically, a resumption of leaking.

HNP's next refueling outage, RFO-15, is currently scheduled to begin in April 2009.

8.0 PRECEDENT A similar request for relief was approved on November 30, 2007, for South Texas Project Unit 2:

NRC Docket No. 50-499 ML073120446 TAC No. MD6189.

Page A 1-1 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a RELIEF REQUEST: 13R-05 Revision 0 DA UT-8 Rev 7

~j'Proojress; Ene~rgy NG.

NDE Report 4 N/A Page 1 of DIGITAL ULTRASONIC THICKNESS NDE REPORT Plant: 5 BNP r CR3 0 HNP C RNP WO:

N/A Unit: 0 1 02 E] 3 Date:

5/16/08 Component / Itern Tested:

Service Water piping tSW-272 NbE Procedure:

No,:

427 Rev.:

7 TR:__

Component Material:

Expected Z CiS SA-106 [1 S"S

]_ Other (Specify):

Nominal I Range:

.189 Ty-pe

-Ty-pe Thickness Gauge:

Couplant:

MIg.: Panametnqs Model: 3;10L+

S/N: 32386301 Software Rev. No.:2.041t.2 Brand:

Ultral Gel Batch No.:

04125 Calibration I Reference Std.:

fl.Test Item-Mic./Caliper No.:

Primary Cal. Thickness:.100 to.300

[.Step Bsok SIN:

CT-2076 0 C/S D S/S O Other (Describe Below)

Cal. Check Thickness:.100 to.300 Transducer.

D798 79797 0.200 7.5 MHz Mg.: Panametrs Model:

S/N:

Diametar:

Freq.:

0 Single E Dual Component Conditions:

Inst: Receiver Gain Setting Auto dB Other Test.Conditions:

High Temp:

0 Yes 0

No Technique: [ Single-Echo C] Thru-Coat None Coatedt Painted: 0 Yes 0 No Muhtiple-Echo Sketch component or item and area tested, Include thickness data.

Note: Readings are with the coatings with an average of.015' S'.75 4

o Inspector Mike Hart Certilicaticn Level Dare

)~

______ J Level 1 A(Sce-r 51,t018 Inspector Ceitiffci~on Lovel Datle Reviewed By (it Required)

Title DMI De

___0 IO'V1o%

NGGM-PM.0011 APPENDIX A Page Al-12 of 12 to SERIAL: HNP-08-099 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 10 CFR 50.55a RELIEF REQUEST: 13R-05 LIST OF REGULATORY COMMITMENTS The following table identifies the actions in this document to which the Harris Nuclear Plant has committed. Statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments.

Item Commitment Completion Date 1

Replace temporary non-code repair of defect in weld on line 3SW1-267SA-1 with a permanent repair. Temporary non-code repair consists of deferral of code repair until the next RFO-15 (April 2009) scheduled outage exceeding 30 days but no later than the next scheduled refueling outage, provided the condition continues to meet the acceptance criteria of Generic Letter 90-05.

2 Perform weekly inspections of location to detect changes in size or leakage of weld until code repair is performed. The structural integrity and the monitoring frequency will be re-RFO-15 (April 2009) evaluated if significant changes are found in the condition of the weld area during this monitoring.

3 Perform ultrasonic measurements of the area where the flaw is located at least once every 90 days.

RFO-15 (April 2009)

Page A2-1 of 1