ML13017A349

Relief Request I3R-10 for Spent Fuel Pool Cooling Piping Inservice Inspection Program - Third 10-Year Interval

ML13017A349
Person / Time
Site:	Harris
Issue date:	01/28/2013
From:	Jessie Quichocho Plant Licensing Branch II
To:	Hamrick G Progress Energy Carolinas
Billoch-Colon, Araceli
References
TAC ME9892
Download: ML13017A349 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 28, 2013 Me George Hamrick Vice President Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc.

Post Office Box 165, Mail Code: Zone 1 New Hill, NC 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - RELIEF REQUEST 13R-10 FOR SPENT FUEL POOL COOLING PIPING INSERVICE INSPECTION PROGRAM - THIRD 10-YEAR INTERVAL (TAC NO. ME9892)

Dear Mr. Hamrick:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated November 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12313A442) as supplemented by letter dated December 17, 2012 (ADAMS Accession No.ML12353A317), Carolina Power and Light Company (the licensee), doing business a Duke Energy, submitted Relief Request 13R-10 for the Inservice Inspection Program for the third 10 year interval for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris).

The licensee requested relief from certain requirements of the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, IWB-3522.1. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(ii), the licensee requested to use proposed alternatives on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The licensee proposed an alternative to repair a leaking pipe in the spent fuel pool cooling system. Relief Request 13R-1 0 proposes to complete the repair prior to the next scheduled refueling outage during the fall of 2013 or November 30, 2013, whichever occurs first.

The details of the NRC staff review are included in the enclosed safety evaluation. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and, therefore, is in compliance with the ASME Code requirements.

G. Hamrick

- 2 Therefore, the licensee's proposed alternative is authorized in accordance with 10 CFR 50.55a(a)(3)(ii) at Harris, to be completed prior to the next scheduled refueling outage during the fall of 2013, but no later than November 30, 2013.

Sincerely, seA. Quichocho, Branch Chief lant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

Safety Evaluation cc w/enclosure: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST 13R-10: REACTOR VESSEL CLOSURE HEAD ALTERNATIVE TO THE REPAIR OF SPENT FUEL POOL COOLING SYSTEM SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NUMBER 50-400

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated November 8,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12313A442), as supplemented by letter dated December 17,2012 (ADAMS Accession No.ML12353A317), Carolina Power and Light Company (the licensee), doing business as Duke Energy, submitted Relief Request 13R-10 for the Inservice Inspection (lSI) Program for the third 10-year interval for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris).

The licensee requested relief from certain requirements of the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers (AS ME) Boiler and Pressure Vessel Code,Section XI, IWB-3522.1. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a}(3)(ii), the licensee requested to use proposed alternatives on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The licensee proposed an alternative to repair a leaking pipe in the Spent Fuel Pool (SFP) cooling system. Relief Request 13R-10 proposes to complete the repair prior to the next scheduled refueling outage during the fall of 2013 or November 30, 2013, whichever occurs first.

2.0 REGULATORY EVALUATION

In the November 8,2012, letter, the licensee requested authorization of an alternative to the requirements of Article IWB-3522.1 of Section XI ASME Code pursuant to 10 CFR 50.55a(g)(5)(iii). However, as a result of NRC staffs request for additional information, the licensee requested authorization of the proposed alternative pursuant to 10 CFR 50.55a(a}(3)(ii), as discussed in the licensee's December 17,2012, letter.

Section 50.55a(g)(4) of 10 CFR specifies that ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Enclosure

- 2 Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.

Section 50.55a(a)(3) of 10 CFR states that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternative requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 ASME Code Components Affected

The affected component is 12-inch Nominal Pipe Size, 'B' SFP Cooling Return line to the 'A' SFP. The 12-inch stainless steel pipe connects two elbows with circumferential groove welds on line 3SF12-176SB-1-4. The pipe is an ASME Code Class 3, Examination Category D-B, Code Item Number D2.1 O. The design pressure and temperature are 100 pounds per square inch gage (psig) and 200 degrees Fahrenheit (F), respectively. The pipe material is SA-312, TP304 and the elbow material is SA-403, WP 304W. The pipe and elbow thickness is schedule 40S (0.375" Nominal).

The SFP Cooling and Cleanup Systems are designed to remove residual heat from the spent fuel in the fuel storage pools and to maintain water quality in the fuel storage pools, the transfer canals, and the reactor cavity.

The licensee identified a through-wall leak on the 12-inch stainless steel pipe and elbow circumferential groove weld (weld number 1-SF-4-2-VW-6) interface on 'B' Train SFP Cooling line 3SF12-176SB-1-4. The leak is on the bottom (6 o'clock position) of the weld. Also, the licensee identified three through-wall leaks on the 12-inch stainless steel pipe and elbow circumferential groove weld (weld number 1-SF-4-2-VW-3) interface on 'B' Train SFP Cooling line 3SF12-176SB-1-4. The leaks are at 12 o'clock, 3 o'clock, and 7 o'clock positions of the weld.

3.2

Applicable Code Edition and Addenda

The Code of Record for the third 10-year I SI interval at Harris isSection XI of the 2001 Edition through 2003 Addenda of the ASME Code.

3.3

Applicable Code Requirement

The 2001 Edition through 2003 Addenda of the ASME Code,Section XI, IWB-3522.1, states in part that:

- 3 The following relevant conditions that may be detected during the conduct of system pressure test shall require corrective action to meet the requirements of IW8-3142 and IWA-5250 prior to continued service: (a) Leakage from non-insulated components.

3.4 Licensee's Reason for Relief In fall 2012, the licensee detected evidence of a flaw by the presence of dry boric acid during performance of the ASME Section XI periodic pressure test for the '8' Train Unit 1 New Fuel Pool Cooling System. The licensee confirmed through-wall leakage in the stainless steel pipe to-elbow weld after the weld was cleaned of boric acid and re-inspected. The licensee monitors leakage by daily walkdowns, which confirm that the leak rate remains negligible. The licensee identified three additional leaks during subsequent walkdowns and inspections. Leakage from these three locations also remains negligible. The licensee removed the portion of the piping that contains the flaws from service and it will not be returned to service until the ASME Code repairs are complete.

The design functions of removing residual heat from the spent fuel in the fuel storage pools and maintaining water quality in the fuel storage pools, the transfer canals, and the reactor cavity is performed using other components. The licensee noted that the portion of piping that contains the flaws is not isolable from the 'A' Spent Fuel Pool with installed components, as there are no valves between the pool and the flaw locations.

The licensee stated that, upon discovery of the flaws, it initiated preparations to perform ASME Code repairs. Performance of the code repair requires isolating the affected portion of piping from the SFP. The licensee attempted to install a freeze seal but could not establish the necessary isolation boundary. The licensee plans to use a mechanical plug to isolate the flaw locations from the SFP. However, the mechanical plug will have to be designed, fabricated, procured, and tested prior to the implementation of the repair work, resulting in a significant delay from the original schedule.

The Code of construction for the SFP Cooling System piping is the ASME Code,Section III, 1971 Edition through Summer 1973 Addenda, Class 3 requirements (Subsection ND). Welds were constructed to provide a suitable surface for the code-required nondestructive examination (NDE). For ASME Class 3 constructed welds, the code required NDE was a surface inspection.

The licensee stated that the welds were not required to be profiled such that an ultrasonic volumetric inspection capable of characterizing flaws could be performed throughout the entire weld. No preservice volumetric inspections were required or performed. Code Case N-513 requires the use of volumetric inspection for initial characterization of flaws, monitoring of flaw growth, and extent of condition inspections. The licensee stated that the use of volumetric inspection is not practical because the surface conditions are not acceptable for a qualified volumetric inspection, preservice inspections were not performed, and surface profiling the welds could propagate or worsen the extent of the flaws. Therefore, volumetric inspections for flaw characterization per Code Case N-513 are not practical and the Code Case will not be invoked.

-4 There are no specific Technical Specifications (TSs) or Limited Conditions of Operation associated with the SFP Cooling System. The SFP Cooling System is a support system that could impact TS 3.9.11, Water Level - New and Spent Fuel Pools, with a requirement to restore level within four hours if level is less than 23 feet.

The licensee has determined that it is impractical to complete the code repair during the 30 days typically considered reasonable for the repair activity due to the time needed for design, fabrication, procurement, testing, and planning associated with the use of the mechanical plug hardware to isolate the repair location from the SFP.

3.5 Licensee's Request for Relief, Proposed Alternative, and Basis for Use In lieu of the ASME Code repair, the licensee proposed the following to disposition the subject degraded pipe:

a. The flaw geometry shall be characterized by physical measurement. The full pipe circumference at the flaw location shall be inspected to characterize the surface length of flaws in the pipe section. The subsurface length of the flaw will be assumed to be four times the surface length for characterization purposes. The depths of the identified flaws are known to be through-wall.

b. The flaws shall be classified as planar or non-planar. The through-wall aspect supports classification as planar.

c. When multiple flaws, including irregular (compound) shape flaws, are detected, the interaction and combined area loss of flaws in a given pipe section shall be accounted for in the flaw evaluation.

d. A flaw evaluation shall be performed to determine the conditions for flaw acceptance.

The flaw evaluation shall be performed in accordance with Code Case N-513-3, Section 3. Flaw acceptance criteria shall assume that the length of the flaw is four times the surface length to account for the lack of information associated with subsurface characterization of the flaws.

e. Frequent periodic surface inspections of no more than 30 day intervals shall be used to determine if flaws are growing and to establish the time, tallow. at which the detected flaw will reach the allowable size. The allowable size limit will assume that the length of the flaw is four times the surface length to account for the lack of information associated with volumetric characterization of the flaws.

f. Leakage shall be observed by daily walkdowns to confirm the analysis conditions used in the evaluation remain valid.

g. The code repair is scheduled to be complete prior to the end of the next refueling outage, currently scheduled for fall 2013.

- 5 The deferral of the repairs of the SFP Cooling System weld flaws is acceptable based on the following:

1. Use of physical measurement of surface flaw length in lieu of volumetric inspection is satisfactory based upon the proposal to use four times the surface length of the flaw for flaw characterization, evaluation, and monitoring of flaw growth rate.

2. The 'B' SFP Cooling System return line to the 'A' SFP, 3SF12-176SB-1-4, has been isolated from the remaining portions of the SFP Cooling System since the original leak discovery and will continue to be isolated from the remaining portions. The conservatively estimated pressure at the flaw locations is 20 psig due to head pressure (approximately 46 feet) from the 'A' SFP.

3. Ultrasonic thickness examinations were performed in the areas directly adjacent to the flawed welds. The ultrasonic examinations confirmed that there were no wall thinning concerns as all recorded readings were within manufacture tolerances from pipe wall nominal thickness.

4. Best effort ultrasonic examinations were performed to assist in determining the relative size of the indications. For weld 1-SF-4-2-VW-3, through-wall leak locations showed flaw-like characteristics and could be seen from multiple examination angles.

For weld 1-SF-4-2-VW-6, no indications were identified that could be attributed to the leak.

5. Accessible large bore welds (12, 14, and 16-inch nominal diameter piping) on the SFP Cooling Systems were visually examined. There was no additional evidence of leakage on the inspected portions of piping.

6. The maximum allowable flaw lengths for both circumferential and axial planar flaws have been calculated for the 12-inch stainless steel SFP Cooling Piping in accordance with the requirements of Code Case N-513-3, paragraph 3. The calculated allowable flaw length is significantly greater than four times the surface length including consideration for multiple flaws in the same weld.

7. The current leak rate is negligible.

8. The daily visual examinations are sufficient to monitor the leakage from the flaw locations and to ensure that significant rapid flaw growth does not occur. The proposed alternatives, (a) through (g) above, provide reasonable assurance of structural integrity. Items (a) through (d) have been completed. Item (e) will be performed monthly. Item (f) is being performed on a daily basis. Relief is requested from ASME Boiler and Pressure Vessel Code, IWB-3522.1.

-6 3.6 Duration of the Proposed Alternative The proposed alternatives shall be used until the affected weld repairs can be scheduled and implemented, no later than the next scheduled refueling outage during the fall of 2013 or November 30, 2013, whichever occurs first.

3.7 Regulatory Commitments In the December 17,2012, letter, the licensee revised the original Regulatory Commitments in the November 8,2012, letter. The revised Regulatory Commitments are as follows:

Leakage shall be observed by daily walkdowns. Frequent periodic physical measurements and ultrasonic thickness measurements in the vicinity of the flaws at no more than 30 day intervals shall be used to monitor flaw size. If either the flaw size or leakage exceeds the administrative limit prior to the next refueling outage in the fall of 2013, the degraded pipe will be repaired or replaced. The length of the flaw will be considered to be four times the surface length of the flaws in each weld.

4.0 STAFF EVALUATION 4.1 Technical Basis Section 4 of the relief request, "Impracticality of Compliance," states that volumetric inspections per ASME Code Case N-513-3 are impractical and the code case will not be invoked. However, Section 6, Proposed Alternative and Basis for Use, requires that the flaw evaluation be performed in accordance with ASME Code Case N-513-3, Section 3. The NRC staff asked the licensee to clarify whether the relief request follows ASME Code Case N-513-3. In the December 17, 2012, letter, the licensee clarified that the relief request did not invoke Code Case N-513-3.

The NRC staff notes that 10 CFR 50.55a(a)(3) permits licensees to submit justifiable alternative for NRC review and approval and the licensee is not required to use Code Case N-513-3.

However, the NRC staff evaluates the acceptability of the proposed alternative based on Code Case N-513-3, that permits degraded Class 2, and 3 piping to remain in service for a limited period of time before the pipe is required to be repaired in accordance with the ASME Code.

Section 6(a) of the relief request states that"...[t]he subsurface length of the flaw will be assumed to be four times the surface length for characterization purposes.... " The NRC staff asked the licensee to discuss the technical basis for the factor of 4 and the degradation mechanism of the flaws in the subject pipe. In the December 17, 2012, letter, the licensee explained that flaw geometry will be characterized by physical measurement, rather than volumetric inspection. In the absence of volumetric characterization of the flaw, the licensee will use engineering judgment to bound the possible subsurface characteristics of the flaw.

Ultrasonic thickness measurements confirmed that there was no general wall thinning. The licensee clarified that it will measure the flaw length on the outside surface of the subject pipe

- 7 periodically, multiply the observed flaw length on the outside surface of the pipe by 4 to account for the subsurface flaw length (e.g., inside surface of the pipe). The resultant flaw size will be recorded as the detected flaw size. The licensee will compare the detected flaw size to the administrative flaw size. If the detected flaw size exceeds the administrative flaw size, the licensee will repair the subject pipe in accordance with the ASME Code as discussed in the licensee's Regulatory Commitments.

Although it is appropriate for the licensee to use a factor to size and estimate the subsurface flaw length, the NRC staff does not have data to verify whether the factor of 4 in sizing the subsurface flaw length is bounding. The NRC staff understands that some subsurface flaws may be longer than the licensee's sizing estimation especially for the circumferential flaws because of bending stresses affect circumferential flaws. However, the following circumstances alleviate the NRC's concern on the licensee's use of factor of 4 to size the subsurface flaw length:

1. The licensee will perform daily walkdowns to monitor the subject pipe. If the subsurface flaw length is greater than the licensee's sizing estimation, excessive leakage will result and the licensee will take corrective actions as discuss in the licensee's Regulatory Commitment.

2. The licensee will use administrative flaw size in lieu of allowable flaw size as an acceptance criterion. The administrative flaw size is smaller than the allowable flaw size and is more conservative as an acceptance criterion.

3. The pipe has been taken out of service. The applied loading on the subject pipe is reduced. Therefore, the driving force on crack growth is reduced.

4. The pipe and associated weld are made of stainless steel which has a relatively high fracture toughness to resist rapid crack growth. Combining a 24-hour frequency walkdown, a reduced crack driving force, and crack-resistant stainless steel, the NRC staff believes that the probability of catastrophic pipe failure would not be likely.

Therefore, the NRC finds that even though there is no valid technical basis to support the use of the factor of 4, the licensee's daily walkdowns, the administrative acceptance criterion for flaw size and reduced loading will provide reasonable assurance of structural integrity of the subject pipe.

The licensee stated that the likely degradation mechanism in the subject pipe is stress corrosion cracking. The licensee plans to take samples during the ASME Code repair activity in the near future and perform analyses to better understand the cause of the flaws. The licensee will perform destructive examinations to better understand the root cause of the flaws in the subject pipe.

4.2 Flaw Evaluation The licensee performed a flaw evaluation based on Code Case N-513, paragraph 3. The licensee used materials properties and applied loading of the subject pipe with a design

- 8 pressure and temperature of 100 psig and 200 degrees F, respectively. The flaw evaluation is based on fully plastic limit load approach as specified in N-S13-3. The licensee calculated the allowable flaw sizes to be 27.4 inches for axial flaws and 17.3 inches for circumferential flaws.

The NRC staff questioned whether the licensee performed crack growth calculations as part of its flaw evaluation. In the December 17,2012, letter, the licensee clarified that the flaw evaluation did not predict flaw growth, because it credits frequent periodic inspections of no more than 30-day intervals to determine if flaws are growing and to establish the time at which the detected flaws will grow to the allowable size. The NRC staff noted that Code Case N-S13-3 does permit licensees to use periodic inspections in lieu of performing flaw growth analysis.

The NRC staff finds the licensee's flaw evaluation acceptable because the licensee followed the methodology in Code Case N-S13-3.

4.3 Inservice Monitoring As stated above, the licensee will perform daily walkdowns of the subject pipe and will perform periodic surface inspections of no more than 30 days to determine if flaws are growing and to establish the time, tallow, at which the detected flaw will reach the allowable size.

In the December 17, 2012, letter, the licensee clarified that it will determine the outside surface flaw length by physical measurement at least once every 30 days. The licensee will multiply the combined outside surface flaw length of all the flaws in each weld by 4 and treat it as the detected flaw length. If the detected flaw length exceeds the allowable flaw length, the licensee will repair the pipe immediately per the ASME Code. In addition, the licensee will implement an administrative limit on the flaw size. If flaws in a weld grow to a combined outside surface length of 2 inches, which corresponds to a detected flaw length of 8 inches after multiplying the factor of 4, the licensee will repair the pipe immediately per the ASME Code.

In terms of leak rate, the licensee stated that the current leak rate is negligible. The makeup capability to the SFPs is 230 gallons per minute. The licensee will impose an administrative limit on leak rate of S gallons per minute. If the leak rate reaches the administrative limit, the licensee will repair the subject pipe immediately.

The NRC staff finds that the proposed 30-day inspection interval and daily walkdowns are acceptable because they are consistent with Code Case N-S13-3, paragraphs (e) and (f),

respectively. The NRC staff further finds acceptable that the licensee has established the allowable flaw sizes, administrative flaw size, and administrative leak rate. The allowable flaw size, administrative flaw size, and administrative leak rate will provide reasonable assurance that the leaking pipe will not fail catastrophically.

4.4 Hardship The licensee submitted the relief request based on the impracticality argument pursuant to 10 CFR SO.SSa(g)(S)(iii). The NRC staff questioned the appropriateness of using impracticality argument to submit the relief request. In the December 17,2012, letter, the licensee responded that the relief request was submitted under impracticality per 10 CFR SO.SSa{g)(S)(iii) because guidance in Generic Letter 90-0S, "Guidance for Performing Temporary Non-Code Repair of

- 9 ASME Code Class 1,2, and 3 Piping," indicates the inability to perform a repair within a required timeframe supports the impractical argument. The licensee stated that due to the time needed for design, fabrication, procurement, testing, and planning associated with the use of a mechanical plug to isolate the repair location from the SFP, it is impractical to complete the code repair during the 30 days considered typically reasonable for the repair activity.

The licensee further stated that implementation of Code Case N-513 normally uses volumetric inspection for initial characterization of flaws, monitoring of flaw growth, and extent of condition inspections. The use of volumetric inspection is not practical because the surface conditions are not acceptable for a qualified volumetric inspection, and surface profiling the welds could propagate or worsen the extent of the flaws. Causes of impracticality include potential damage to a system or component.

The licensee stated that an alternative basis for relief that would also be valid is hardship or unusual difficulty without a compensating increase in level of quality or safety in accordance with 10 CFR 50.55a(a)(3)(ii). The licensee further stated that hardship is caused by the need for a hardware change, the fabrication of a mechanical plug to isolate the repair location from the SFP to provide conditions allowing the code repair. Regulatory commitments described herein to monitor the flaw and take corrective action in the event that the flaw sizes approach limits provide reasonable assurance that structural integrity will be maintained. Therefore, there is no compensating increase in level of quality or safety.

The NRC staff recognizes that this relief request could be accepted under the impracticality argument pursuant to 10 CFR 50.55a(g)(5)(iii). However, the NRC staff finds that it is not impractical for the licensee to shut down the plant to repair the degraded pipe. It is a hardship for the licensee to shut down the plant for an extended period of time to complete the design, fabrication, procurement, testing, and planning of the mechanical plug. The NRC staff finds that the hardship argument pursuant to 10 CFR 50.55a(a)(3)(ii) is more appropriate than the impracticality argument. The NRC finds that the licensee has provided sufficient and valid arguments to support the hardship argument in performing immediately the Code repair of the subject pipe.

In summary the NRC staff finds that the licensee proposed daily walkdowns, 30-day inspection interval, flaw evaluation, and that the Regulatory Commitments provide reasonable assurance of the structural integrity of the subject piping to the next scheduled refueling outage during the fall of 2013 or November 30,2013, whichever occurs first.

5.0 CONCLUSION

As set forth above, the NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity of the subject spent fuel pool piping. The NRC staff finds that complying with the specified ASME Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the requirements of the ASME Code,Section XI for which relief was not requested. Therefore, the NRC authorizes

- 10 the use of Relief Request 13R-10 at Harris until the next scheduled refueling outage during the fall of 2013 or November 30, 2013, whichever occurs first.

All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized herein by the NRC staff remain applicable, including the third party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: John Tsao Date: January 28, 2013

G. Hamrick

- 2 Therefore, the licensee's proposed alternative is authorized in accordance with 10 CFR 50.55a(a)(3)(ii) at Harris, to be completed prior to the next scheduled refueling outage during the fall of 2013, but no later than November 30, 2013.

Sincerely, IRA!

Jessie A. Quichocho, Branch Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

Safety Evaluation cc w/enclosures: Distribution via ListServ DISTRIBUTION:

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