ML060870387

Relief Request No. 2R1-015 for the Second 10-Year Inservice Inspection Interval

ML060870387
Person / Time
Site:	Harris
Issue date:	04/17/2006
From:	Marshall M Plant Licensing Branch III-2
To:	Gannon C Carolina Power & Light Co
Michael Marshall 301-415-0539
References
TAC MC8954
Download: ML060870387 (17)

Text

April 17, 2006 Mr. Cornelius J. Gannon, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1- RELIEF REQUEST 2R1-015 FOR THE SECOND 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MC8954)

Dear Mr. Gannon:

By letter dated November 18, 2005, as supplemented by letter dated February 8, 2006, Carolina Power and Light Company submitted Relief Request (RR) 2R1-015 for Shearon Harris Nuclear Power Plant, Unit 1 (HNP), requesting relief from the requirements of paragraph (g) of section 50.55a of Title 10, Code of Federal Regulations (10 CFR) and the system leak test requirements that are specified in Table IWB-2500-1, Examination Category B-P, and Paragraph IWA-5222(a) of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Division 1. RR 2R1-015 is applicable to the second 10-year inservice inspection (ISI) interval for HNP and pertains to the system hydrostatic pressure test requirements for ASME Code Class 1 portions of the safety injection system, residual heat removal system, and for specified ASME Code Class 1 drain lines, vent lines, fill lines, and test lines.

The Nuclear Regulatory Commission staffs evaluation and conclusions are contained in the enclosed safety evaluation. The staff has determined that you have provided an acceptable basis for establishing that compliance with Section XI Table IWB-2500-1, Examination Category B-P, and Paragraph IWA-5222(a) would create a hardship for HNP, without a compensating increase in the level of quality and safety. The staff has also determined that you have proposed acceptable alternative system leak tests for these piping segments in lieu of performing the required system hydrostatic pressure tests. The proposed alternative provides reasonable assurance of structural integrity. Therefore, the staff concludes that the proposed alternative in RR 2R1-015 may be approved for the second 10-year ISI interval for HNP under the hardship provisions that are specified in 10 CFR 50.55a(a)(3)(ii).

Sincerely,

/RA/

Michael L. Marshall, Branch Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

Safety Evaluation cc w/encl: See next page

ML060870387 NRR-028 OFFICE LPL2-2/PM LPL2-2/LA OGC LPL2-2/BC NAME CPatel RSola PMoulding MMarshall DATE 4/11/06 4/13/06 4/13/06 4/17/06 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SECOND 10-YEAR INSERVICE INSPECTION INTERVAL PROGRAM CAROLINA POWER AND LIGHT COMPANY RELIEF REQUEST 2R1-015 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 INTRODUCTION

By letter dated November 18, 2005, as supplemented by letter dated February 8, 2006, Carolina Power and Light Company (CP&L, licensee), submitted Relief Request (RR) 2R1-015 for Shearon Harris Nuclear Power Plant, Unit 1 (HNP), requesting relief from the requirements of paragraph (g) to section 50.55a of Title 10, Code of Federal Regulations (10 CFR), and the system leak test requirements that are specified in Table IWB-2500-1, Examination Category B-P, and Paragraph IWA-5222(a) of Section XI of the 1989 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Division 1 (Section XI). RR 2R1-015 is applicable to the second 10-year inservice inspection (ISI) interval for HNP and pertains to the system hydrostatic pressure test requirements for specified ASME Code Class 1 piping (line) segments in the HNP safety injection (SI) and residual heat removal (RHR) systems and for specified ASME Code Class 1 vent lines, drain lines, test lines, and fill lines (VDTF lines).

2.0 REGULATORY EVALUATION

Inservice inspection of ASME Code Class 1, 2, and 3 components is performed in accordance with Section XI and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).

The regulation in 10 CFR 50.55a(a)(3) states, in part, that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if the licensee demonstrates that: (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.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, Enclosure

geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals must comply with the requirements in the latest edition and addenda of Section XI incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, as subject to the limitations in the rule.

3.0 TECHNICAL EVALUATION

3.1 Applicable Components RR 2R1-015 is applicable to specific ASME Code Class 1 line segments in the SI and RHR systems and to specific ASME Code Class 1 VDTF line segments. The applicable line segments are listed in Reference 1, as amended by Reference 3. The table attached to this safety evaluation (SE) identifies the components that are within the scope of RR 2R1-015. The table also identifies the valves that define the boundaries of the applicable line segments.

The applicable SI, RHR, and VDTF line segments are categorized as ASME Code Class 1 because the line segments are aligned to the reactor coolant pressure boundary (RCPB) out to and inclusive of the second containment isolation valves (CIVs) for the systems. With the exception of the applicable RHR line segments, each of the line segments is isolated from the RCPB by self-actuating check valves (CVs).

For the RHR line segments, the CIVs are motor-operated flow control valves (FCVs). The FCVs are interlocked to ensure redundant isolation of the RCPB from the ASME Code Class 2 portion of the RHR, which is subject to a lower design pressure. The Technical Requirements Manual for HNP specifies that the licensee should maintain the FCVs in the closed and de-energized configuration prior to raising the reactor coolant system (RCS) pressure above 425 psig. Plant operating instructions specify that the FCVs are to be maintained in the closed configuration prior to raising the RCS pressure above 370 psig or the RCS temperature above 350 degrees Fahrenheit (EF).

3.2 Applicable Code Edition and Requirements The licensee requested relief from the following Section XI requirements, as invoked by reference in 10 CFR 50.55a(g)(4):

• Section XI, Table IWB-2500-1, Examination Category B-P, All Pressure Retaining Components, Inspection Item B15.51, Piping, and Inspection Item B15.71, Valves:

Inspection Items B15.51 and B15.71 require that the licensee perform inservice hydrostatic pressure tests and VT-2 visual examinations of all ASME Code Class 1 pressure retaining piping and valves in accordance with the requirements of Section XI, Paragraph IWB-5222. The inspection items require that the inservice hydrostatic pressure test be performed at a frequency of once every 10-year ISI interval.

• Section XI, Paragraph IWB-5222 and Table IWB-5222-1: In response to a request for additional information (RAI), the licensee clarified that, pursuant to 10 CFR 50.55a(a)(3)(ii), relief is also being requested from compliance with the requirements of Section XI, Paragraph IWB-5222(a) and Table IWB-5222-1, which pertain to requirements for pressurizing the RCPB during hydrostatic pressure tests. The nominal

operating temperature of the RCPB at 100 percent rated power is above 500 EF. The nominal operating pressure of the RCPB at 100 percent rated power is 2235 pounds per square inch gauge (psig). Thus, Table IWB-5222-1 requires that the licensee perform the required hydrostatic pressure test at a test pressure of 2280 psig (i.e., 1.02 X 2235 psig).

• In response to the RAI from the NRC staff, the licensee confirmed that the applicable line segments do not include any pumps. Therefore, Inspection Item B15.61 in Section XI, Table IWB-2500-1, Examination Category B-P does not need to be included within the scope of the relief request.

• In its response to the RAI from the NRC staff, the licensee clarified that the code of record for HNP is the 1989 Edition of Section XI, without applicable addenda.

3.3 BASIS FOR THE RELIEF REQUEST The applicable RHR, SI, and VDTF line segments are each designed with two system CIVs in order to comply with the requirements of 10 CFR Part 50, Appendix, A, General Design Criteria, Criterion 55, Reactor Coolant Pressure Boundary Penetrating Containment. The RCPB extends to and is inclusive of the second CIVs in the line segments.

The licensee is requesting relief from complying with the requirements that are specified in:

(1)Section XI, Table IWB-2500-1, Examination Category B-P, Inspection Items B15.51 and B15.71; (2)Section XI, Paragraph IWB-5222(a); and (3)Section XI, Table IWB-5222-1. The licensee stated that the relief is being requested for the second 10-year ISI interval for HNP.

The licensee stated that implementation of the required hydrostatic pressure tests on the applicable RHR, SI, and VDTF line segments would require either: (1) opening up the first CIV in the line segments, (2) installing temporary bypasses around the first CIVs, or (3) modifying the systems to bypass the first CIVs. The licensee stated that implementing any of these actions would require the licensee to defeat the double containment isolation function of the inboard and outboard CIVs, as required to be configured in the closed position when operating in MODES 1, 2, or 3. The licensee stated that this would constitute a hardship for the facility as defined in 10 CFR 50.55a(a)(3)(ii).

3.4 Proposed Alternative In lieu of complying with the applicable hydrostatic pressure test requirements, the licensee proposed to perform alternative system leak tests of the applicable line segments (including the valves in the segments). In response to the RAI from the NRC staff, the licensee confirmed that it is applying the methods of Code Case N-498-4 as the basis for performing its alternative system leak tests and VT-2 visual examinations of the applicable line segments, including the provisions in paragraphs (a)(3) and (a)(4) of the Code Case for minimum hold time and test temperature requirements. Since the licensee clarified that it is applying the alternative system leak test criteria of Code Case N-498-4 without exception, the NRC staff considers the licensees alternative acceptable.

In its response to the RAI from the NRC staff, the licensee clarified that the alternative system leak tests will be at the nominal operating pressures for the applicable SI, RHR, and VDTF line

segments, as configured to containment isolation when in MODE 3. In addition, the licensee clarified that test pressures and temperatures for the alternative leak tests are as specified below:

• ASME Code Class 1 Low Pressure Safety Injection Line Segments: The licensee stated that the lines are aligned to the SI accumulators and, thus, the test pressures will range from 585 - 665 psig. The test temperatures will be at ambient containment temperature (i.e., < 120 EF).

• ASME Code Class 1 RHR Line Segments and ASME Code Class 1 High Pressure Safety Injection Line Segments Aligned to the Cold Leg Loop: The lines are aligned to the RHR system when in MODES 4 and 5. The licensee stated that when RHR is removed from service prior to reaching MODE 3, the line segments will be at an elevated temperature and pressure. The licensee stated that when the RHR motor operated valves are closed for retiring the RHR, the elevated temperatures and pressures will be maintained in the line segments located between the first and second CIVs. The licensee therefore stated that the test pressure will range from 325 - 360 psig and the test temperature will range from 300 - 350 EF.

• ASME Code Class 1 High Pressure Safety Injection Line Segments Aligned to the Hot Leg Loop: The licensee stated that flow is not established through the applicable line segments during ascension to MODE 3, or while in MODE 3. Therefore, the applicable line segments will be subject to the elevated head pressure for the high pressure SI system while in MODE 3. The licensee stated that the test temperature will be at the ambient containment temperature (i.e., < 120 EF).

• ASME Code Class 1 VDTF Lines: The licensee stated that the alternative pressure test will not pressurize the line segments located after the first containment isolation valves to the required nominal operating pressure for the RCPB.

3.5 NRC Staff Evaluation ASME Code Case N-498-4, Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems,Section XI, Division 1, was issued by the ASME Main Committee on February 15, 1999. The Code Case provides the committees alternative requirements for performing leak testing of ASME Code Class 1 systems in lieu of the hydrostatic pressure tests that are required in accordance with Section XI Table IWB-2500-1, Examination Category B-P,Section XI Paragraph IWB-5222(a), and Section XI, Table IWB-5222-1. The Code Case also provides alternative leak test requirements for systems that are classified as ASME Code Class 2 or 3.

The NRC has endorsed ASME Code Case N-498-4 (by reference in 10 CFR 50.55(b)(5) and in Regulatory Guide 1.147, Revision 14) as an acceptable ASME Code Case for implementation without exception and has determined that the alternative system leak tests in the Code Case provide an acceptable level of quality and safety in lieu of complying with the system hydrostatic pressure test requirements for ASME Code Class 1 components.

The licensees proposed alternative system leak tests are intended to test the subject line segments at the corresponding system test pressures and temperatures when the systems are configured to MODE 3. The following bases establish how the licensees alternative system leak test methods conform to the provisions in ASME Code Case N-498-4:

1. Performing the test in MODE 3 Hot Standby, will conform to paragraph (a)(1) of the Code Case because the test will be performed prior to changing the MODE switch to MODE 2, Startup.

2. The licensees alternative system leak test of the RCPB will conform to paragraphs (a)(2) and (a)(5) of the Code Case because the alternative leak tests will be performed over the entire length of the applicable line segments (inclusive of the applicable CIVs).

3. Paragraph (a)(3) of the Code Case permits the testing of the isolated portions of the RCPB during normal operations to be performed at lower test pressures and temperatures. Normal operations for the facility include times during scheduled shutdowns and anticipated operational transients. The licensee will use the plant pressurizer heaters to heat and pressurize the RCPB to the recommended test pressures and temperatures of the Code Case, as subject to the configuration for containment isolation in MODE 3. Therefore, the licensee can implement the alternative system leak tests while in MODE 3 and still conform to paragraph (a)(3) of the Code Case.

4. The NRC staff has confirmed that the test temperatures and pressures for the alternate system leak tests are lower than the plants pressure-temperature limit curve in Technical Specification Figure 3.4-2 for performing the hydrostatic pressure test.

Therefore, the proposed alternative conforms to paragraph (a)(4) of the Code Case.

For the isolated portions of the RCPB, the alternative pressures and temperatures defined in Section 3.4 of this SE represent the highest test pressures and temperatures that can be achieved without defeating the double containment isolation design requirement for the systems in MODE 3, or without requiring significant design modifications. Evidence of pressure boundary leakage that is detected during implementation of the alternative system leak tests will require the licensee to enter the degraded pressure boundary components into the Corrective Actions, provisions of Section XI, Paragraph IWA-5250.

Pressurization of the subject line segments in accordance with applicable hydrostatic test requirements would require the licensee to defeat the double containment isolation design requirement or implement significant plant modifications. Either approach would subject the licensee to a hardship. Based on its endorsement of ASME Code Case N-498-4, the staff concludes that the licensees proposed alternative system leak tests will provide reasonable assurance of continued leakage integrity of the subject components and systems.

Furthermore, the licensee performs additional examinations of the RCPB in accordance with other Examination Categories in Section XI, Table IWB-2500-1 and also performs augmented system walkdowns of the RCPB for evidence of boric acid leakage as part of its Generic Letter 88-01 inspections. These additional examinations provide additional monitoring of the structural integrity of the RCPB. Therefore, the staff has determined that requiring compliance

with the applicable Code provisions, as opposed to authorizing the licensees proposed alternative, would provide no compensating increase in quality and safety.

Based on this assessment, the NRC staff concludes that compliance with the hydrostatic pressure test requirements during the second 10-year ISI interval will create a hardship for the licensee. The staff also concludes that licensee has proposed acceptable alternative system leak tests for these line segments.

4.0 NRC STAFF CONCLUSION The NRC staff has reviewed RR 2R1-015, along with the proposed alternative system leak tests for the ASME Code Class 1 SI, RHR, and VDTF line segments against the hardship provisions of 10 CFR 50.55a(a)(3)(ii). Based on its evaluation, the staff concludes that: (1) licensee has provided a sufficient basis to demonstrate that compliance with the requirements of Section XI, Table IWB-2500-1, Examination Category B-P, Inspection Items B15.51 and B15.71;Section XI, Paragraph IWB-5222; and Section XI, Table IWB-5222-1 (as applied to these line segments) would create a hardship for HNP without a compensating increase in the level of quality and safety, (2) licensees proposal provides acceptable alternative system leak tests for these line segments, and (3) the proposed alternative provides reasonable assurance of structural integrity. Therefore, based on the staffs assessment, the staff concludes that RR 2R1-015 may be granted for the second 10-year ISI interval pursuant to the hardship provisions of 10 CFR 50.55a(a)(3)(ii).

5.0 REFERENCES

1. Serial Letter No. HNP-05-128 from C. S. Kamilaris (CP&L) to the NRC Document Control Desk, Shearon Harris Nuclear Plant, Unit 1, 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, November 18, 2005.

2. 1989 Edition of the ASME Code,Section XI, Division 1, Rules for Inservice Inspection of Nuclear Power Plant Components.

3. Serial Letter No. HNP-06-007 from C. S. Kamilaris (CP&L) to the NRC Document Control Desk, Shearon Harris Nuclear Plant, Unit 1, Docket No. 50-400/License No.

NPF-63, Response to Request for Additional Information on the Relief Request from Inservice Inspection Program No. 2R1-015, Alternative to ASME Code Section XI IWA-4000 Requirements, February 8, 2006.

Principal Contributor: James Medoff Date: April 17, 2006

Attachment:

As stated

RELIEF REQUEST 2R1-015 TABLE AFFECTED CLASS 1 PRESSURE RETAINING COMPONENTS - EXAMINATION CATEGORY B-P Pipe Affected Line Approx Diameter Boundary Exception(s) or Component Length (ft.)

(in.)

Loop Drain Valve 1RC-7 remains closed to avoid pressurizing Line Isolation 2 < 1 ft.

downstream Class 1 pipe and valve 1RC-8 Valve Loop Drain Valve 1RC-16 remains closed to avoid pressurizing Line Isolation 2 < 1 ft.

downstream Class 1 pipe and valve 1RC-17 Valve Loop Drain Valve 1RC-28 remains closed to avoid pressurizing Line Isolation 2 < 1 ft.

downstream Class 1 pipe and valve 1RC-29 Valve Pressurizer PORV Vent Line on Valve 1RC-110 remains closed to avoid pressurizing Primary 0.75 0.5 ft.

downstream Class 1 pipe and valve 1RC-111 Sample Path off Pressurizer Instrument Vent Line on Pressurizer Valve 1RC-984 remains closed to avoid pressurizing 0.5 0.5 ft.

Level downstream Class 1 pipe and valve 1RC-985 Instrument Loop 1LT-459 Instrument Vent Line on Pressurizer Valve 1RC-986 remains closed to avoid pressurizing 0.5 0.5 ft.

Level downstream Class 1 pipe and valve 1RC-987 Instrument Loop 1LT-460 Instrument Vent Line on Pressurizer Valve 1RC-988 remains closed to avoid pressurizing 0.5 0.5 ft.

Level downstream Class 1 pipe and valve 1RC-989 Instrument Loop 1LT-461 CVCS Check valve to remain closed to avoid disassembly or Pressurizer other temporary configurations required to achieve test 2 < 1 ft.

Spray pressures at upstream piping and valves 1CS-491 and Downstream 1CS-488 CV and Test Connection Valve 1CS-489 remains closed to avoid pressurizing 1 1.5 ft.

Isolation downstream Class 1 pipe and valve 1CS-490 Valve Attachment

RELIEF REQUEST 2R1-015 TABLE Affected Class 1 Pressure Retaining Components - Examination Category B-P Pipe Affected Line Approx Diameter Boundary Exception(s) or Component Length (ft.)

(in.)

Norm Check valve to remain closed to avoid disassembly or Charging Line other temporary configurations required to achieve test 3 < 1 ft.

Upstream CV pressures at upstream piping and valves 1CS-500 and and Test 1CS-497 Connection Valve 1CS-498 remains closed to avoid pressurizing Isolation 1 1.5 ft.

downstream Class 1 pipe and valve 1CS-499 Valve Alt Charging Check valve to remain closed to avoid disassembly or Line other temporary configurations required to achieve test 3 < 1 ft.

Upstream CV pressures at upstream piping and valves 1CS-486 and and Test 1CS-483 Connection Valve 1CS-484 remains closed to avoid pressurizing Isolation 1 1.5 ft.

downstream Class 1 pipe and valve 1CS-485 Valve Excess Letdown Valve 1CS-460 remains closed to avoid pressurizing Upstream 1 1.5 ft.

downstream Class 1 pipe and valve 1CS-461 Isolation Valve Check valve to remain closed to avoid disassembly or Between other temporary configurations required to achieve test Accumulator 12 26 pressures at upstream piping and valves 1SI-249 and 1A-SA 1SI-250 Discharge CV and SI to RCS Valve 1SI-273 remains closed to avoid pressurizing 1 2 Loop A CV downstream Class 1 pipe and valve 1SI-274 Between Check valve to remain closed to avoid disassembly or Accumulator other temporary configurations required to achieve test 12 28 1B-SB pressures at upstream piping and valves 1SI-251 and Discharge CV 1SI-252 and SI to RCS Valve 1SI-275 remains closed to avoid pressurizing 1 2 Loop B CV downstream Class 1 pipe and valve 1SI-276 Between Check valve to remain closed to avoid disassembly or Accumulator other temporary configurations required to achieve test 12 26 1C-SA pressures at upstream piping and valves 1SI-253 and Discharge CV 1SI-254 and SI to RCS Valve 1SI-277 remains closed to avoid pressurizing Loop C CV 1 2 downstream Class 1 pipe and valve 1SI-278

RCS Loop to Valves 1RH-39 and 1RH-40 remain closed to avoid over-RHR Pump 12 86 pressurization of the RHR system B Isolation and Drain Valve 1SI-41 remains closed to avoid pressurizing Line 1 2 downstream Class 1 pipe and valve 1SI-42

RELIEF REQUEST 2R1-015 TABLE Affected Class 1 Pressure Retaining Components - Examination Category B-P Pipe Affected Line Approx Diameter Boundary Exception(s) or Component Length (ft.)

(in.)

RCS Loop to Valves 1RH-1 and 1RH-2 remain closed to avoid over-RHR Pump 12 86 pressurization of the RHR system A Isolation and Drain Valve 1RH-3 remains closed to avoid pressurizing 1 2 Line downstream Class 1 pipe and valve 1RH-4 6 38 Check valve to remain closed to avoid disassembly or RCS Cold other temporary configurations required to achieve test 2 68 Leg Loop 1 pressures at upstream piping and valves 1SI-81, 1SI-SIS, Boron 2 3 356, 1SI-8, and 1SI-72 injection, and Valve 1SI-27 remains closed to avoid pressurizing 1 1.5 CVCS paths. downstream Class 1 pipe and valve 1SI-28 Valve 1SI-79 remains closed to avoid pressurizing 1 1.5 downstream Class 1 pipe and valve 1SI-80 6 33 Check valve to remain closed to avoid disassembly or Class 1 piping other temporary configurations required to achieve test from Residual 2 83 pressures at upstream piping and valves 1SI-82, 1SI-Heat 2 7 357, 1SI-9, and 1SI-73 Exchanger to RCS Cold Valve 1SI-33 remains closed to avoid pressurizing 1 1.5 Leg Loop 2. downstream Class 1 pipe and valve 1SI-34 Valve 1SI-75 remains closed to avoid pressurizing 1 1.5 downstream Class 1 pipe and valve 1SI-76 Class 1 piping 6 25.5 Check valve to remain closed to avoid disassembly or from Residual other temporary configurations required to achieve test 2 49.5 Heat pressures at upstream piping and valves 1SI-83, 1SI-Exchanger to 2 1.5 358, 1SI-10, and 1SI-74 RCS Cold Valve 1SI-39 remains closed to avoid pressurizing Leg Loop 3. 1 1.5 downstream Class 1 pipe and valve 1SI-40 Valve 1SI-77 remains closed to avoid pressurizing 1 1.5 downstream Class 1 pipe and valve 1SI-78 Class 1 piping 6 43 Check valve to remain closed to avoid disassembly or from Residual other temporary configurations required to achieve test 2 2.5 Heat pressures at upstream piping and valves 1SI-136, Exchanger to 2 2.5 1SI-134, 1SI-104, and 1SI-127 RCS Hot Leg Valve 1SI-376 remains closed to avoid pressurizing Loop 1. 1 1.5 downstream Class 1 pipe and valve 1SI-377 Class 1 piping 6 44.5 Check valve to remain closed to avoid disassembly or from Residual other temporary configurations required to achieve test Heat 2 2.5 pressures at upstream piping and valves 1SI-137, Exchanger to 2 2.5 1SI-135, 1SI-105, and 1SI-128 RCS Hot Leg Loop 2. Valve 1SI-132 remains closed to avoid pressurizing 1 1.5 downstream Class 1 pipe and valve 1SI-133

RELIEF REQUEST 2R1-015 TABLE Affected Class 1 Pressure Retaining Components - Examination Category B-P Pipe Affected Line Approx Diameter Boundary Exception(s) or Component Length (ft.)

(in.)

Class 1 piping 6 1 Check valve to remain closed to avoid disassembly from Residual 2 42.5 or other temporary configurations required to Heat 2 1 achieve test pressures at upstream piping and Exchanger to RCS Hot Leg valves 1SI-138, 1SI-106, and 1SI-129 2 1 Loop 3. Valve 1SI-130 remains closed to avoid pressurizing 1 1.5 downstream Class 1 pipe and valve 1SI-131

Mr. C. J. Gannon, Jr. Shearon Harris Nuclear Power Plant Carolina Power & Light Company Unit 1 cc:

David T. Conley Mr. Robert J. Duncan II Associate General Counsel II - Director of Site Operations Legal Department Shearon Harris Nuclear Power Plant Progress Energy Service Company, LLC Carolina Power & Light Company Post Office Box 1551 Post Office Box 165, Mail Zone 1 Raleigh, North Carolina 27602-1551 New Hill, North Carolina 27562-0165 Resident Inspector/ Harris NPS Mr. Robert P. Gruber c/o U. S. Nuclear Regulatory Commission Executive Director 5421 Shearon Harris Road Public Staff NCUC New Hill, North Carolina 27562-9998 4326 Mail Service Center Raleigh, North Carolina 27699-4326 Ms. Margaret A. Force Assistant Attorney General Chairman of the North Carolina State of North Carolina Utilities Commission Post Office Box 629 Post Office Box 29510 Raleigh, North Carolina 27602 Raleigh, North Carolina 27626-0510 Public Service Commission Mr. Herb Council, Chair State of South Carolina Board of County Commissioners Post Office Drawer 11649 of Wake County Columbia, South Carolina 29211 P. O. Box 550 Raleigh, North Carolina 27602 Ms. Beverly Hall, Section Chief Division of Radiation Protection Mr. Tommy Emerson, Chair N.C. Department of Environment Board of County Commissioners and Natural Resources of Chatham County 3825 Barrett Drive P. O. Box 87 Raleigh, North Carolina 27609-7721 Pittsboro, North Carolina 27312 Mr. Chris L. Burton Mr. Christos Kamilaris, Manager Manager Support Services Performance Evaluation and Shearon Harris Nuclear Power Plant Regulatory Affairs PEB 7 Carolina Power & Light Company Progress Energy P. O. Box 165, Mail Zone 1 Post Office Box 1551 New Hill, North Carolina 27562-0165 Raleigh, North Carolina 27602-1551 Mr. David H. Corlett, Supervisor Mr. Eric McCartney Licensing/Regulatory Programs Plant General Manager Shearon Harris Nuclear Power Plant Shearon Harris Nuclear Power Plant Carolina Power & Light Company Carolina Power & Light Company P. O. Box 165, Mail Zone 1 P. O. Box 165, Mail Zone 3 New Hill, NC 27562-0165 New Hill, North Carolina 27562-0165 Mr. John H. ONeill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

Washington, DC 20037-1128