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, 2006Mr. Cornelius J. Gannon, Vice PresidentShearon 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 REQUEST2R1-015 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 testrequirements that are specified in Table IWB-2500-1, Examination Category B-P, andParagraph 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 hydrostaticpressure 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, filllines, and test lines. The Nuclear Regulatory Commission staff's evaluation and conclusions are contained in theenclosed safety evaluation. The staff has determined that you have provided an acceptablebasis 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 ofperforming the requir ed system hydrostatic pressure tests. The proposed alternative providesreasonable assurance of structural integrity. Therefore, the staff concludes that the proposedalternative 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 ChiefPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-400

Enclosure:

Safety Evaluation cc w/encl: See next page

ML060870387NRR-028OFFICELPL2-2/PMLPL2-2/LAOGCLPL2-2/BCNAMECPatelRSolaPMouldingMMarshallDATE4/11/064/13/064/13/06 4/17/06 EnclosureSAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONSECOND 10-YEAR INSERVICE INSPECTION INTERVAL PROGRAMCAROLINA POWER AND LIGHT COMPANYRELIEF REQUEST 2R1-015SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1DOCKET NO. 50-40

01.0INTRODUCTION

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 thesystem leak test requirements that are specified in Table IWB-2500-1, ExaminationCategory 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 t he system hydrostatic pressure test requirements for specified ASMECode 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 filllines (VDTF lines).

2.0REGULATORY EVALUATION

Inservice inspection of ASME Code Class 1, 2, and 3 components is performed in accordancewith 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 ofparagraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), ifthe licensee demonstrates that: (i) the proposed alternatives would provide an acceptable levelof 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 (includingsupports) 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, geometry, and materials of construction of the components. The regulations require thatinservice examination of components and system pressure tests conducted during the first10-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.

3.0TECHNICAL EVALUATION

3.1Applicable ComponentsRR 2R1-015 is applicable to specific ASME Code Class 1 line segments in the SI and RHRsystems and to specific ASME Code Class 1 VDTF line segments. The applicable linesegments 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. Thetable 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 1because 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 theexception 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). TheFCVs 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 RequirementsManual 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 above425 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 (F).3.2Applicable Code Edition and RequirementsThe licensee requested relief from the following Section XI requirements, as invoked byreference in 10 CFR 50.55a(g)(4):*Section XI, Table IWB-2500-1, Examination Category B-P, "All Pressure RetainingComponents," Inspection Item B15.51, "Piping," and Inspection Item B15.71, "Valves

":Inspection Items B15.51 and B15.71 require that the licensee perform inservicehydrostatic 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 foradditional 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 F. Thenominal 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 applicableline 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 c ode ofrecord for HNP is the 1989 Edition of Section XI, without applicable addenda.3.3BASIS FOR THE RELIEF REQUESTThe applicable RHR, SI, and VDTF line segments are each designed with two system CIVs inorder to comply with the requirements of 10 CFR Part 50, Appendix, A, "General Design Criteria," Criterion 55, Reactor Coolant Pressure Boundary Penetrating Containment. TheRCPB 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 theapplicable RHR, SI, and VDTF line segments would require either: (1) opening up the first CIVin 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 theseactions 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). 3.4Proposed AlternativeIn lieu of complying with the applicable hydrostatic pressure test requirements, the licenseeproposed to perform alternative system leak tests of the applicable line segments (including thevalves in the segments). In response to the RAI from the NRC staff, the licensee confirmedthat 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 theprovisions 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 alternativ e syst emleak test criteria of Code Case N-498-4 without exception, the NRC staff considers thelicensee's alternative acceptable.In its response to the RAI from the NRC staff, the licensee clarified that the alternative systemleak 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 licenseeclarified 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 statedthat the lines are aligned to the SI accumulators and, thus, the test pressures will r angefrom 585 - 665 psig. The test temperatures will be at ambient containment temperature(i.e., < 120 F).*ASME Code Class 1 RHR Line Segments and ASME Code Class 1 High PressureSafety Injection Line Segments Aligned to the Cold Leg Loop: The lines are aligned tothe RHR system when in MODES 4 and 5. The licensee stated that when RHR isremoved 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 motoroperated valves are closed for retiring the RHR, the elevated temperatures andpressures will be maintained in the line segments located between the first and secondCIVs. The licensee therefore stated that the test pressure will range from 325 - 360 psig and the test temperature will range from 300 - 350 F.*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 linesegments 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 SIsystem while in MODE 3. The licensee stated that the test temperature will be at the ambient containment temperature (i.e., < 120 F).*ASME Code Class 1 VDTF Lines: The licensee stated that the alternative pressure testwill not pressurize the line segments located after the first containment isolation valves to the required nominal operating pressure for the RCPB.3.5NRC Staff EvaluationASME Code Case N-498-4, "Alternative Requirements for 10-Year System Hydrostatic Testingfor 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 committee's alternative requirements for performing leak testing of ASME Code Class 1 systems in lieu of thehydrostatic 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 inRegulatory 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 Caseprovide an acceptable level of quality and safety in lieu of complying with t he system hydrostaticpressure test requirements for ASME Code Class 1 components. The licensee's proposed alternative system leak tests are intended to test the subject linesegments at the corresponding system test pressures and temperatures when t he systems areconfigured to MODE 3. The following bases establish how the licensee's 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 theCode Case because the test will be performed prior to changing the MODE switch toMODE 2, "Startup." 2.The licensee's alternative system leak test of the RCPB will conform toparagraphs (a)(2) and (a)(5) of the Code Case because the alternative leak tests will beperformed 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 theRCPB during normal operations to be performed at lower test pressures and temperatures. Normal operations for the facility include times during scheduledshutdowns and anticipated operational transients. The licensee will use the plantpressurizer 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 alternativesystem leak tests while in MODE 3 and still conform to paragraph (a)(3) of the CodeCase. 4.The NRC staff has confirmed that the test temperatures and pressures for the alternatesystem leak tests are lower than the plant's pressure-temperature limit curve inTechnical 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 inSection 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 systemsin MODE 3, or without requiring significant design modifications. Evidence of pressure boundary leakage that is detected during implementation of the alternativ e 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 testrequirements would require the licensee to defeat the double containment isolation designrequirement 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 licensee's proposed alternative system leak tests will provide reasonableassurance 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 Letter88-01 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 licensee's proposedalternative, would provide no compensating increase in quality and safety.Based on this assessment, the NRC staff concludes that compliance with the hydrostaticpressure test requirements during the second 10-year ISI interval will create a hardship for thelicensee. The staff also concludes that licensee has proposed acceptable alternativ e syst emleak tests for these line segments.4.0NRC STAFF CONCLUSIONThe NRC staff has reviewed RR 2R1-015, along with the proposed alternative system leak testsfor the ASME Code Class 1 SI, RHR, and VDTF line segments against the hardship provisionsof 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) licensee's proposal provides acceptable alternative system leak tests forthese line segments, and (3) the proposed alternative provides reasonable assurance of structural integrity. Therefore, based on the staff's 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 DocumentControl 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 ofNuclear Power Plant Components. 3. Serial Letter No. HNP-06-007 from C. S. Kamilaris (CP&L) to the NRC DocumentControl 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 Attachment RELIEF REQUEST 2R1-015 TABLE AFFECTED CLASS 1 PRESSURE RETAINING COMPONENTS

- EXAMINATION CATEGORY B-PAffected Lineor ComponentPipeDiameter(in.)ApproxLength (ft.)Boundary Exception(s)Loop DrainLine IsolationValve 2< 1 ft.Valve 1RC-7 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-8 Loop DrainLine IsolationValve 2< 1 ft.Valve 1RC-16 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-17Loop DrainLine IsolationValve 2< 1 ft.Valve 1RC-28 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-29 PressurizerPORV VentLine onPrimarySample PathoffPressurizer0.750.5 ft.Valve 1RC-110 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-111 InstrumentVent Line onPressurizerLevelInstrumentLoop 1LT-4590.50.5 ft.Valve 1RC-984 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-985 InstrumentVent Line onPressurizerLevelInstrumentLoop 1LT-4600.50.5 ft.Valve 1RC-986 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-987 InstrumentVent Line onPressurizerLevelInstrumentLoop 1LT-4610.50.5 ft.Valve 1RC-988 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RC-989 CVCSPressurizerSprayDownstreamCV and TestConnectionIsolationValve 2< 1 ft.Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1CS-491 and1CS-48811.5 ft.Valve 1CS-489 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1CS-490 RELIEF REQUEST 2R1-015 TABLEAffected Class 1 Pressure Retaining Components - Examination Category B-PAffected Lineor ComponentPipeDiameter(in.)ApproxLength (ft.)Boundary Exception(s)NormCharging LineUpstream CVand TestConnectionIsolationValve 3< 1 ft.Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1CS-500 and1CS-49711.5 ft.Valve 1CS-498 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1CS-499 Alt ChargingLineUpstream CVand TestConnectionIsolationValve 3< 1 ft.Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1CS-486 and1CS-48311.5 ft.Valve 1CS-484 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1CS-485 ExcessLetdownUpstreamIsolationValve11.5 ft.Valve 1CS-460 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1CS-461 BetweenAccumulator1A-SADischarge CVand SI to RCSLoop "A" CV1226Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-249 and1SI-250 12Valve 1SI-273 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-274 BetweenAccumulator1B-SBDischarge CVand SI to RCSLoop "B" CV1228Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-251 and1SI-252 12Valve 1SI-275 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-276 BetweenAccumulator1C-SADischarge CVand SI to RCSLoop "C" CV1226Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-253 and1SI-254 12Valve 1SI-277 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-278 RCS Loop toRHR Pump"B" Isolationand DrainLine1286Valves 1RH-39 and 1RH-40 remain closed to avoid over-pressurization of the RHR system 12Valve 1SI-41 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-42 RELIEF REQUEST 2R1-015 TABLEAffected Class 1 Pressure Retaining Components - Examination Category B-PAffected Lineor ComponentPipeDiameter(in.)ApproxLength (ft.)Boundary Exception(s)RCS Loop toRHR Pump"A" Isolationand DrainLine1286Valves 1RH-1 and 1RH-2 remain closed to avoid over-pressurization of the RHR system 12Valve 1RH-3 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1RH-4 RCS Cold Leg Loop 1SIS, Boroninjection, andCVCS paths. 638Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-81, 1SI-356, 1SI-8, and 1SI-72268 2311.5Valve 1SI-27 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-28 11.5Valve 1SI-79 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-80 Class 1 pipingfrom Residual HeatExchanger toRCS ColdLeg Loop 2. 633Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-82, 1SI-357, 1SI-9, and 1SI-73283 2711.5Valve 1SI-33 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-34 11.5Valve 1SI-75 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-76 Class 1 pipingfrom Residual HeatExchanger toRCS ColdLeg Loop 3.

625.5Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-83, 1SI-358, 1SI-10, and 1SI-74249.521.511.5Valve 1SI-39 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-40 11.5Valve 1SI-77 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-78 Class 1 pipingfrom Residual HeatExchanger toRCS Hot LegLoop 1. 643Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-136, 1SI-134, 1SI-104, and 1SI-12722.522.511.5Valve 1SI-376 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-377 Class 1 pipingfrom Residual HeatExchanger toRCS Hot LegLoop 2. 644.5Check valve to remain closed to avoid disassembly orother temporary configurations required to achieve testpressures at upstream piping and valves 1SI-137, 1SI-135, 1SI-105, and 1SI-12822.522.511.5Valve 1SI-132 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-133 RELIEF REQUEST 2R1-015 TABLEAffected Class 1 Pressure Retaining Components - Examination Category B-PAffected Lineor ComponentPipeDiameter(in.)ApproxLength (ft.)Boundary Exception(s)Class 1 pipingfrom Residual HeatExchanger toRCS Hot Leg Loop 3.61Check valve to remain closed to avoid disassemblyor other temporary configurations required toachieve test pressures at upstream piping andvalves 1SI-138, 1SI-106, and 1SI-129242.5 21 2111.5Valve 1SI-130 remains closed to avoid pressurizingdownstream Class 1 pipe and valve 1SI-131 Mr. C. J. Gannon, Jr.Shearon Harris Nuclear Power PlantCarolina Power & Light CompanyUnit 1 cc:David T. Conley Associate General Counsel II -

Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551Resident Inspector/ Harris NPSc/o U. S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, North Carolina 27562-9998Ms. Margaret A. ForceAssistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602Public Service CommissionState of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211Ms. Beverly Hall, Section ChiefDivision of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721Mr. Chris L. BurtonManager Performance Evaluation and Regulatory Affairs PEB 7 Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551Mr. Eric McCartneyPlant General Manager Shearon Harris Nuclear Power Plant Carolina Power & Light Company P. O. Box 165, Mail Zone 3 New Hill, North Carolina 27562-0165Mr. Robert J. Duncan IIDirector of Site Operations Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165Mr. Robert P. GruberExecutive Director Public Staff NCUC 4326 Mail Service Center Raleigh, North Carolina 27699-4326Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carolina 27626-0510Mr. Herb Council, ChairBoard of County Commissioners of Wake County

P. O. Box 550 Raleigh, North Carolina 27602Mr. Tommy Emerson, ChairBoard of County Commissioners of Chatham County

P. O. Box 87 Pittsboro, North Carolina 27312Mr. Christos Kamilaris, ManagerSupport Services Shearon Harris Nuclear Power Plant Carolina Power & Light Company P. O. Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165Mr. David H. Corlett, SupervisorLicensing/Regulatory Programs Shearon Harris Nuclear Power Plant Carolina Power & Light Company P. O. Box 165, Mail Zone 1 New Hill, NC 27562-0165Mr. John H. O'Neill, Jr.Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

Washington, DC 20037-1128