CP-201101031, Transmittal of Unit 1 Inservice Inspection Program Plan, Revision 0 (Unit 1: ASME Code XI 1998 Edition, 1999 and 2000 Addenda, Interval Start - August 13, 2010, Third Interval)

Transmittal of Unit 1 Inservice Inspection Program Plan, Revision 0 (Unit 1: ASME Code XI 1998 Edition, 1999 and 2000 Addenda, Interval Start - August 13, 2010, Third Interval)

ML11220A167
Person / Time
Site:	Comanche Peak
Issue date:	08/02/2011
From:	Flores R, Madden F Luminant Power, Luminant Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201101031, TXX-11092
Download: ML11220A167 (174)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Rafael.Flores@Luminant.com Glen Rose, TX 76043 Luminant T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201101031 Ref. # 10CFR50.55a(g)

Log# TXX-11092 August 02, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NO. 50-445 TRANSMITTAL OF UNIT 1 INSERVICE INSPECTION PROGRAM PLAN, REVISION 0 (UNIT 1: ASME CODE XI 1998 EDITION, 1999 AND 2000 ADDENDA, INTERVAL START - AUGUST 13, 2010, THIRD INTERVAL)

Dear Sir or Madam:

Enclosed is one copy of Revisi6n 0 to the Unit I Inservice Inspection (ISI) Program Plan for updating your manual. This transmittal does not contain a request for relief from ASME Code requirements.

This communication contains no new commitments regarding Comanche Peak Unit 1.

Should you have any questions, please contact Mr. Paul Passalugo at (254) 897-6250.

Sincerely, Luminant Generation Company LLC Rafael Flores By: 2c2- I-] -U trredW. Madden Director, Oversight & Regulatory Affairs A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Lie'-

Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

U. S. Nuclear Regulatory Commission TXX-11092 Page 2 of 2 08/02/2011 Enclosure - Revision 0 to Unit 1 ISI Plan, Third Interval c- E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Luis Ponce, TDLR Jack Ballard, ANII, Comanche Peak

ENCLOSURE TO TXX-11092 Revision 0 to Unit 1 ISI Plan, Third Interval

LUMINANT POWER COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP) 6322 NORTH FM 56 GLEN ROSE, TEXAS 76043 UNIT 1 - THIRD INTERVAL ASME SECTION XI INSERVICE INSPECTION PROGRAM PLAN REVISION 0 - MARCH 11,2011 COMMERCIAL OPERATION: AUGUST 13, 1990 THIRD INTERVAL START DATE: AUGUST 13, 2010 Prepared By: -7121 ISI Engineer 1-0 IS IV9LL 7/2.L lit Reviewed By:

Technical Reviewer Reviewed By: ViA ANII1 Approved By: q,, 7/29111 Shaw Site Director, Eng eeing and Technical Sdrv Approved By: __--/?&ZIil Luminant BOP Manager 6 '-i 6 1< "7f4-

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE OF CONTENTS

[SECTION DESCRIPTION PAGE Revision Summary Sheet iv 1.0 Introduction and Plant Background 1-1 1.1 Introduction 1-1 1.2 Plant Background 1-2 2.0 Basis of Inservice Inspection Program Plan 2-1 2.1 ASME Section XI Code of Record 2-1 2.2 ASME Code Classifications and System Boundaries 2-1 2.3 ASME Code Exemptions 2-2 2.4 Code of Federal Regulations 10CFR50.55a 2-6 Modifications, Limitations and Augmented Examination Requirements 2.5 Inspection Intervals and Scheduling 2-11 2.6 Successive and Additional Examinations 2-13 2.7 Augmented Examinations 2-13 2.8 Risk-Informed Inservice Inspection Application 2-14 2.9 Records and Reports 2-22 2.10 Authorized Nuclear Inservice Inspector 2-22 2.11 List of Abbreviations 2-22 3.0 Inservice Inspection Program Drawings 3-1 3.1 Inservice Inspection Boundary Drawings 3-1 3.2 Inservice Inspection Isometric Drawings 3-3 4.0 Nondestructive Examinations 4-1 4.1 Visual Examination 4-1 4.2 Surface Examination 4-2 4.3 Volumetric Examination 4-2 ii Revision 0

Comanche Peak Unit I Third Interval ISI Program Plan TABLE OF CONTENTS (con't)

SECTION DESCRIPTION PAGE 4.4 Personnel Qualification Requirements 4-3 4.5 Ultrasonic Calibration Blocks 4-3 4.6 Valve Groups 4-8 4.7 Eddy Current Testing 4-10 5.0 Inservice Inspection Examination Summary Tables 5-1 5.1 Summary Tables for ASME Section XI Inservice 5-1 Inspection Examinations 5.2 Summary Tables for Risk-Informed Inservice 5-2 Inspection Examinations on Class 1 and 2 Piping Welds 6.0 Alternative Requirements to ASMIE Section XI 1998 6-1 Edition through 2000 Addenda 6.1 Adoption of Code Cases 6-1 6.2 Use of Subsequent Editions of ASME Section XI 6-10 6.3 10CFR50.55a Modifications, Limitations and 6-10 Augmented Examination Requirements 6.4 Inservice Inspection Requests for Alternatives and 6-10 Relief Requests 7.0 Request for Alternatives and Relief Request Index 7-1 8.0 Request for Alternatives and Relief Requests 8-1 9.0 System Pressure Testing 9-1 9.1 Purpose 9-1 9.2 Pressure Test Description 9-1 9.3 Pressure Test Requirements 9-2 9.4 Insulated Bolted Connections 9-2 iii Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan REVISION

SUMMARY

SHEET SECTION EFFECTIVE PAGE(S) REVISION DATE 1.0 1-1 0 3/11/11 1.1 1-1 to 1-2 0 3/11/11 1.2 1-2 0 3/11/11 2.0 2-1 0 3/11/11 2.1 2-1 0 3/11/11 2.2 2-1 to 2-2 0 3/11/11 2.3 2-2 to 2-5 0 3/11/11 2.4 2-6 to 2-11 0 3/11/11 2.5 2-11 to 2-13 0 3/11/11 2.6 2-13 0 3/11/11 2.7 2-13 to 2-14 0 3/11/11 2.8 2-14 to 2-21 0 3/11/11 2.9 2-22 0 3/11/11 2.10 2-22 0 3/11/11 2.11 2-22 to 2-24 0 3/11/11 3.0 3-1 0 3/11/11 3.1 3-1 to 3-3 0 3/11/11 3.2 3-3 to 3-5 0 3/11/11 4.0 4-1 0 3/11/11 4.1 4-1 0 3/11/11 4.2 4-2 0 3/11/11 4.3 4-2 to 4-3 0 3/11/11 4.4 4-3 0 3/11/11 4.5 4-3 to 4-7 0 3/11/11 4.6 4-8 to 4-10 0 3/11/11 4.7 4-10 0 3/11/11 iv Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan REVISION

SUMMARY

SHEET (con't)

SECTION EFFECTIVE PAGE(S) REVISION DATE 5.0 5-1 0 3/11/11 5.1 5-1 to 5-2 and 5-4 to 5-22 0 3/11/11 5.2 5-2 to 5-3 and 5-23 to 5-24 0 3/11/11 6.0 6-1 0 3/11/11 6.1 6-1 to 6.10 0 3/11/11 6.2 6-10 0 3/11/11 6.3 6-10 0 3/11/11 6.4 6-10 to 6-11 0 3/11/11 7.0 7-1 0 3/11/11 8.0 See Table 7.0-1 for Revision Status for Requests for Alternatives and Relief Requests 9.0 9-1 0 3/11/11 9.1 9-1 0 3/11/11 9.2 9-1 0 3/11/11 9.3 9-2 0 3/11/11 9.4 9-2 0 3/11/11 v

Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION

1.0 INTRODUCTION

AND PLANT BACKGROUND 1.1 Introduction 1.1.1 This Inservice Inspection (ISI) Program Plan outlines the requirements for the inspection of Class 1, 2, and 3 pressure retaining components and their supports at the Comanche Peak Nuclear Power Plant, Unit 1 (CPNPP-1), including common and Unit 2 systems required to support Unit 1 operations. The ISI Program Plan was developed to provide the details necessary for performing the inservice inspection on Code Class 1, 2, and 3 components and their supports at CPNPP-1 in accordance with the 1998 Edition through the 2000 Addenda of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI, Subsections IWA, IWB, IWC, IWD, IWF, and applicable Mandatory and Nonmandatory Appendices (the Code). This ISI Program Plan also demonstrates compliance with the Code of Federal Regulations, 10CFR50.55a.

1.1.2 This ISI Program Plan does not include the requirements for the examination and testing of ASME Class CC and MC components and Class MC component supports. These requirements are included in a separate Containment Inservice Inspection Program Plan.

1.1.3 The extent, frequency and acceptance standards for snubber testing will be in accordance with CPNPP Technical Requirements Manual TR 15.5.3 1. The inservice inspection of snubber attachment hardware is addressed by both TR 15.5.31 and this Inservice Inspection Program Plan.

1.1.4 The eddy current testing of steam generator tubes is addressed in Technical Specification 5.5.9.

1.1.5 The rules of ASME Section XI, Article IWA-4000, "Repair/Replacement Activities", are addressed in CPNPP Document Nos. STA-731 and EPG-73 1, "Repair/Replacement Activities".

1.1.6 This ISI Program Plan will become effective on August 13, 2010, which represents the beginning of third interval for CPNPP-1.

1.1.7 The key features of this ISI Program Plan are the Introduction and Plant Background, Basis for the ISI Program, List of Inservice Inspection Drawings, List of Nondestructive Examination Methods, ISI Summary Tables, List of Code Alternatives, Requests for Alternatives and Relief Requests. The details of the ISI Program referenced in this ISI Program Plan are contained in documents that are available at CPNPP- 1. These documents include, but are not limited to, piping and system flow diagrams, piping isometric drawings, a database listing of 1-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan each item (weld, valve, bolt, nut, etc.) and component support in the ISI Program, and documents supporting implementation of the ISI Program.

1.1.8 Luminant Power (Owner)/Designated Agent is responsible for preparation and maintenance of this ten-year ISI Program Plan, including any required reference drawings and boundary drawings. The Owner/Designated Agent prepares each Outage Plan, which defines the scope of examinations, determines the extent of any examinations, and defines the method of each exam. After each outage, this Plan is normally revised by the Owner/Designated Agent to reflect the completed examinations, with a summary report prepared and submitted to the Regulatory and Enforcement Authorities. The Owner/Designated Agent is responsible for any associated craft labor required for the examinations, including access provisions, insulation removal; weld preparation, and other aspects. The Owner/Designated Agent is responsible for the evaluation of the ISI examination records, including evaluations of indications and any associated corrective actions.

A contractor working under the guidance of the Owner/Designated Agent, in most cases, performs the examinations. The contractor submits procedures and personnel certifications for performance of the examinations to the Owner/Designated Agent for review and approval. A contractor ISI Program Manager and a suitable number of examination teams, supplied with the required NDE equipment, are provided to complete the scheduled examinations for the outage. The contractor conducts the examinations, reviews the data, and makes suitable recommendations to the Owner/Designated Agent.

1.2 Plant Background 1.2.1 The Comanche Peak Nuclear Power Plant (CPNPP) is a two unit plant containing pressurized water reactors, each with an electrical output of approximately 1150 MWe. CPNPP was constructed to the ASME Boiler and Pressure Vessel Code, Section 11I, 1974 Edition, including Summer 1974 Addenda for piping and Winter 1974 Addenda for component supports.

1.2.2 The first ten-year interval at CPNPP-1 began on August 13, 1990 and ended on August 12, 2000. The Code of Record for the first ten-year interval was ASME Section XI, 1986 Edition, no Addenda.

1.2.3 The second ten-year interval at CPNPP-1 began on August 13, 2000 and ended on August 12, 2010. The Code of Record for the second ten-year interval was ASME Section XI, 1998 Edition through 2000 Addenda.

1-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 2.0 BASIS OF INSERVICE INSPECTION PROGRAM PLAN 2.1 ASME Section XI Code of Record In accordance with 10CFR50.55a(g) CPNPP-1 is required to update the ASME Section XI Code ISI program once every ten year interval. Typically, the ISI program is required to comply with the latest edition and addenda of the Code incorporated by reference in 10CFR50.55a one year prior to the start of the interval per 10CFR50.55a(g)(4)(ii).

However, on July 14, 2009, the Luminant Generation Company submitted a request to the Nuclear Regulatory Commission (NRC) asking for the continued use of the 1998 Edition through 2000 Addenda of ASME Section XI that was used during the second inspection interval. This will apply until the update of Comanche Peak Nuclear Power Plant Unit 2 (CPNPP-2) for the third interval, which is scheduled to begin on August 3, 2014. At that time, both CPNPP-l and CPNPP-2 will be updated to the same edition of the Code that is applicable. On April 28, 2010, the NRC approved this request (see Letter No. CP-201000690 from the NRC) provided CPNPP-1 meets the following two commitments:

Commitment No. 3891111: The licensee will revise the current procedures to prohibit the use of paragraph IWA-4340 until the next code of record update for CPNPP, Unit 1.

Commitment No. 3891114: The licensee will revise the current procedures to invoke the use of paragraph IWA-4540(c) until the next code of record update for CPNPP, Unit 1. (Based on what is written in 10CFR50.55a(b)(2)(xxvi),

Luminant will use the 1998 Edition of ASME Section XI when invoking paragraph IWA-4540(c).)

Letter No. CP-201000690 from the NRC also noted that CPNPP-1 is subject to the limitations and modifications of 10CFR50.55a(b)(2). These limitations and modifications are addressed in Section 2.4 of this ISI Program Plan.

2.2 ASME Code Classifications and System Boundaries Per 10CFR50.55a(g)(4), the specific components required to be included in an ISI Program per ASME Section XI are those components and component supports which are classified as ASME Code Class 1, 2, and 3. ASME Code classification and system boundaries of the piping and other components subject to examination have been identified as required by Subsection IWA-1400(a) of the Code. Section 3.2 of the CPNPP FSAR defines the various safety classes of piping and components in accordance with Regulatory Guide 1.26 and ANSI Standard N18.2.

2-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan The ASME Code Class of components at CPNPP- 1 was established by NRC Regulatory Guide 1.26, Revision 3, "Quality Group Classification and Standards", 10CFR50.2, "Reactor Coolant PressureBoundary" definition, and 10CFR50.55a. As discussed in Regulatory Guide 1.26, the Quality Group Classification System consists of four Quality Groups, A through D. The definition of Quality Group A is included in 10CFR50.2.

Exceptions to the requirements of the 10CFR50.2 definition are included 10CFR50.55a(c). The definitions of Quality Groups B, C, and D are included in Regulatory Guide 1.26. Quality Groups B and C and are also discussed in 10CFR50.55a(d) and (e), respectively. ANSI N18.2, "Nuclear Safety Criteria for the design of Stationary Pressurized Water Reactor Plants", dated November 1973 can also be used for guidance in determining ASME Code Class.

Typically components classified Quality Group A are designed per ASME Section InI, Class 1 and are examined and tested per ASME Section XI, Subsection IWB; components classified Quality Group B are designed per ASME Section III, Class 2 and are examined and tested per ASME Section XI, Subsection IWC, and components classified Quality Group C are designed per ASME Section III, Class 3 and are examined and tested per ASME Section XI, Subsection IWD. Components designed per ASME Section III, Class 2 or 3 considered to be optionally classified as ASME Code Class may be excluded from the Section XI ISI Program per IWA-1320(e).

The classification of piping subject to Section XI requirements are shown on the Inservice Inspection Boundary Drawings listed in Section 3.1 of this Inservice Inspection Program.

Pursuant to 10CFR50.55a, the inservice inspection requirements of ASME Section XM have been assigned to these components within the constraints of existing plant design.

These plant piping boundary drawings show the class interfaces and the ISI examination boundaries.

2.3 ASME Code Exemptions 2.3.1 Code Class 1 The following Code Class I components (or parts of components) are exempted from the volumetric and surface examination requirements of Subsection LWB-2500 of the Code by Paragraph IWB-1220:

(a) components that are connected to the reactor coolant system and part of the reactor coolant pressure boundary, and that are of such a size and shape so that upon postulated rupture the resulting flow of coolant from the reactor coolant system under normal plant operating conditions is within the capacity of makeup systems which are operable from on-site emergency power. The emergency core cooling systems are excluded from the calculation of makeup capacity.

2-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan (b)(1) Piping of NPS 1 and smaller, except for steam generator tubing; (b)(2) Components and their connections in piping of NPS 1 and smaller; (c) Reactor vessel head connections and associated piping, NPS 2 and smaller, made inaccessible by control rod drive penetrations.

(d) Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

2.3.2 Code Class 2 The following Code Class 2 components or parts of components are exempted from the volumetric and surface examination requirements of Subsection IWC-2500 of the Code by Paragraph IWC-1220:

2.3.2.1 Components Within Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) Systems or Portions of Systems:

(a) For systems, except high pressure safety injection systems in pressurized water reactor plants:

(1) Piping NPS 4 and smaller (2) Vessels, pumps, and valves and their connections in piping NPS 4 and smaller (b) For high pressure safety injection systems in pressurized water reactor plants:

(1) Piping NPS 1 1/2 and smaller (2) Vessels, pumps, and valves and their connections in piping NPS 1 1/2 and smaller (c) Vessels, piping, pumps, and valves, other components, and component connections of any size in statically pressurized, passive (i.e., no pumps) safety injection systems of pressurized water reactor plants.

(d) Piping and other components of any size beyond the last shutoff valve in open ended portions of systems that do not contain water during normal plant operating conditions.

2-3 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 2.3.2.2 Components Within Systems or Portions of Systems Other Than RHR, ECC, and CHR Systems:

(a) For systems, except auxiliary feedwater systems pressurized water reactor plants:

(1) Piping NPS 4 and smaller (2) Vessels, pumps, and valves and their connections in piping NPS 4 and smaller (b) For auxiliary feedwater systems in pressurized reactor plants:

(1) Piping NPS 1 1/2 and smaller (2) Vessels, pumps, and valves and their connections in piping NPS 1 1/2 and smaller.

(c) Vessels, piping, pumps, valves, other components, component connections of any size in systems or of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig and at a temperature equal to or less than 200'F (93°C).

(d) Piping and other components of any size beyond last shutoff valve in open ended portions of systems do not contain water during normal plant operating conditions.

2.3.2.3 Inaccessible Welds Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

2.3.3 Code Class 3 2.3.3.1 Examination Requirements The examination requirements of ASME Section XI, Subsection IWD shall apply to pressure retaining components and their welded attachments on Class 3 systems in support of the following functions:

(a) reactor shutdown (b) emergency core cooling (c) containment heat removal (d) atmosphere cleanup (e) reactor residual heat removal (f) residual heat removal from spent fuel storage pool 2-4 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 2.3.3.2 Components Exempt From Examination The following components or parts of components are exempted from the VT-i visual examination requirements of Subsection IWD of the Code by Paragraph IWD-1220:

(a) Piping NPS 4 and smaller (b) Vessels, pumps and valves and their connections in piping NPS 4 and smaller (c) Components that operate at a pressure of 275 psig or less and at a temperature of 200'F (93°C) or less in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling.

(d) Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

2.3.4 Code Class 1, 2 and 3 Supports Supports exempt from the examinations requirements of Subsection IWF of the Code by Paragraph IWF-1230 are those connected to piping and other items exempted from volumetric, surface, VT-i or VT-3 visual by paragraphs IWB-1220, IWC-1220 and IWD-1220. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground, or encapsulated by guard pipe are also exempt from the examination requirements of Subsection IWF-2000.

2-5 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 2.4 Code of Federal Regulations 10CFR50.55a Modifications. Limitations and Augmented Examination Requirements The following mandatory and optional Code of Federal Regulations Limitations, Modifications and Augmented Examination Requirements are included in 10CFR50.55a as published on September 10, 2008 and amended on October 2, 2008. Only those 10CFR50.55a Limitations, Modifications and Augmented Examination Requirements applicable to the 1998 Edition through 2000 Addenda of Section XI nondestructive examination requirements for Class 1, 2, and 3 components and component supports are listed. These Limitations, Modifications and Augmented Examination Requirements were reviewed for inclusion in the ISI Program and dispositioned as follows:

2.4.1 10CFR50.55a(b)(2)(i) - Limitations on Specific Editions and Addenda CPNPP-1 will not implement the option in 10CFR50.55a(b)(2)(i), to utilize ASME Section XI, 1974 Edition with Addenda through Summer 1975 and ASME Section XI, 1977 Edition with Addenda through Summer 1978.

2.4.2 10CFR50.55a(b)(2)(ii) - Pressure-Retaining Welds in ASME Code Class 1 Piping (applies to Table IWB-2500 and IWB-2500- 1 and Category B-J)

CPNPP-1 will not utilize the option in 10CFR50.55a(b)(2)(ii), to examine Class 1 piping per ASME Section XI, 1974 Edition with the Summer 1975 Addenda.

Because CPNPP-1 has a RI-ISI application for Class 1 piping, this modification is not applicable.

2.4.3 10CFR50.55a(b)(2)(iii) - Steam Generator Tubing (modifies Article IWB-2000)

As allowed by 10CFR50.55a(b)(2)(iii), steam generator tubing at CPNPP-1 will be examined in accordance with plant Technical Specification 5.5.9 in lieu of Article IWB-2000.

2.4.4 10CFR50.55a(b)(2)(iv) - Pressure Retaining Welds in ASME Code Class 2 Piping (applies to Tables IWC-2520 or IWC-2520-1, Category C-F)

CPNPP-1 will not utilize the option in 10CFR50.55a(b)(2)(iv), to examine Class 2 piping per ASME Section XI, 1974 Edition with the Summer 1975 Addenda and the 1983 Edition through the Summer 1983 Addenda. Because CPNPP-1 has a RI-ISI application for Class 2 piping, this modification is not applicable.

2.4.5 10CFR50.55a(b)(2)(viii) - Examination of Concrete Containments The CPNPP-1 design includes a concrete containment subject to ASME Section XI, Subsection IWL requirements. Therefore the mandatory modifications in 10CFR50.55a(b)(2)(viii)(E) and (F) apply to CPNPP-1. Subsection IWL requirements are addressed in a separate CPNPP Containment ISI Program Plan.

2-6 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 2.4.6 10CFR50.55a(b)(2)(ix) - Examination of Metal Containments and the Liners of Concrete Containments The CPNPP-1 design includes a metal containment subject to ASME Section XI, Subsection IWE requirements. Therefore the mandatory modifications in 10CFR50.55a(b)(2)(ix)(A), (B) and (F) through (D) apply to CPNPP-1.

Subsection iWE requirements are addressed in a separate CPNPP Containment ISI Program Plan.

2.4.7 10CFR50.55a(b)(2)(x) - Quality Assurance 10CFR50.55a(b)(2)(x) does not apply for CPNPP-1. The CPNPP QA Program is based on 10CFR50 Appendix B and does not rely on NQA-1.

2.4.8 10CFR50.55a(b)(2)(xii) - Underwater Welding The requirements for performing underwater welding as stated in 10CFR50.55a(b)(2)(xii) are not addressed in the CPNPP-1 ISI Program. Repair and Replacement activities are addressed in CPNPP Document Nos. STA-731 and EPG-73 1, "Repair/Replacement Activities".

2.4.9 10CFR50.55a(b)(2)(xiv) - Appendix VIII Personnel Qualification As allowed by 10CFR50.55a(b)(2)(xiv), for Appendix VIII Qualified Personnel, CPNPP-1 will use the annual practice requirements in VII-4240 of Section XI Appendix VII in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training (when deemed appropriate) as discussed in 10CFR50.55a(b)(2)(xiv). When utilizing this option, the annual practice requirements will be performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks. All training will be completed no earlier than 6 months prior to performing ultrasonic examinations. The implementation of ASME Section XI, Appendix VII and VIII requirements is addressed in vendor written practices that are reviewed and approved by CPNPP.

2.4.10 10CFR50.55a(b)(2)(xv) - Appendix VIII Specimen Set and Qualification Requirements CPNPP-1 will implement the optional Appendix VIII specimen set and qualification provisions in paragraphs (b)(2)(xv)(A) to (b)(2)(xv)(M) in accordance with 10CFR50.55a(b)(2)(xv). ASME Section XI, Appendix VIII is implemented through participation in the Utility Performance Demonstration Initiative (PDI). EPRI, as the administrator of the PDI Program, maintains a Comparison Document that provides a line by line comparison of the PDI program, Appendix VIII, and 10CFR50.55a and reports the compliance status as well as describing any variances that would necessitate requests for relief by PDI Program users. Note that the alternative requirements of Code Case N-695 will be utilized in lieu of those in Appendix VIII, Supplement 10. In addition, the alternative requirements of Code Case N-696 will be utilized in lieu of those in Appendix VIII, Supplements 2, 3 and 10.

2-7 Revision 0

Comanche Peak Unit I Third Interval ISI Program Plan 2.4.11 10CFR50.55a(b)(2)(xvi) - Appendix VIII Single Side Ferritic Vessel and Piping and Stainless Steel Piping Examination As required by 10CFR50.55a(b)(2)(xvi)(A) and 10CFR50.55a(b)(2)(xvi)(B),

CPNPP-1 examinations performed from one side of a ferritic vessel weld and examinations performed from one side of a ferritic or stainless steel pipe will be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. The implementation of ASME Section XI, Appendix VIII requirements is addressed in vendor written practices that are reviewed and approved by CPNPP.

2.4.12 10CFR50.55a(b)(2)(xviii)(A) - Certification of NDE Personnel As required by 10CFR50.55a(b)(2)(xviii)(A), Level I and II nondestructive examination personnel at CPNPP- I will be recertified on a 3-year interval in lieu of the 5-year interval specified in lWA-2314(a) and IWA-2314(b) of the 1998 Edition through 2000 Addenda. The certification of nondestructive examination personnel is addressed in CPNPP Document No. NDE-101, "Nondestructive Personnel Training, Qualification and Certification".

2.4.13 10CFR50.55a(b)(2)(xviii)(B) - Certification of NDE Personnel As required by 10CFR50.55a(b)(2)(xviii)(B), paragraph IWA-2316 of the 1998 Edition through 2000 Addenda will only be used to qualify personnel that observe for leakage during system leakage and hydrostatic tests conducted in accordance with IWA-521 l(a) and (b). The certification of visual examination personnel is addressed in CPNPP Document No. NDE-101, "Nondestructive Personnel Training, Qualification and Certification".

2.4.14 10CFR50.55a(b)(2)(xviii)(C) - Certification of NDE Personnel As required by 10CFR50.55a(b)(2)(xviii)(C), when qualifying visual examination personnel for VT-3 visual examinations under paragraph IWA-2317 of the 1998 Edition through 2000 Addenda, the proficiency of the training must be demonstrated by administering an initial qualification examination and administering subsequent examinations on a 3-year interval. The certification of visual examination personnel is addressed in CPNPP Document No. NDE-101, "Nondestructive Personnel Training, Qualification and Certification".

2.4.15 10CFR50.55a(b)(2)(xix) - Substitution of Alternative Methods As required by 10CFR50.55a(b)(2)(xix), CPNPP-1 will apply the rules in IWA-2240, "Alternative Examinations," of Section XI, 1997 Addenda in lieu of the IWA-2240 requirements in Section XI, 1998 Edition through 2000 Addenda for the substitution of alternative examination methods.

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Comanche Peak Unit 1 Third Interval ISI Program Plan 2.4.16 10CFR50.55a(b)(2)(xx)(A) - System Leakage Tests As required by 10CFR50.55a(b)(2)(xx)(A), when performing system leakage tests in accordance IWA-5213(a) per the 1998 Edition with 2000 Addenda at the Callaway Plant, a 10-minute hold time after attaining test pressure will be required for Class 2 and Class 3 components that are not in use during normal operating conditions, and no hold time is required for the remaining Class 2 and Class 3 components provided that the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or 10 minutes for uninsulated components. Hold times are addressed in CPNPP Documents STA-725 and EPG-725, "Pressure Testing".

2.4.17 10CFR50.55a(b)(2)(xxi)(A) - Table IWB-2500-1 Examination Requirements As required by 10CFR50.55a(b)(2)(xxi)(A), the provisions of Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels, Items Nos. B3.120 and B3.140 of Inspection Program B in the 1998 Edition will be applied by CPNPP-1.

As an option, allowed by 10CFR50.55a(b)(2)(xxi)(A), a visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1, 1998 Edition with 2000 Addenda, with a limiting assumption on the flaw aspect ratio (i.e., a/l = 0.5), may be performed in place of an ultrasonic examination.

CPNPP-1 does not intend to exercise this option and will continue performing ultrasonic examinations on the nozzle inner radii.

2.4.18 10CFR50.55a(b)(2)(xxi)(B) - Table IWB-2500-1 Examination Requirements The requirements of 10CFR50.55a(b)(2)(xxi)(B) for Table LWB-2500-1, Examination Category B-G-2, Item B7.80, Pressure Retaining Control Rod Drive (CRD) Housing Bolting are not applicable to CPNPP-1. The CPNPP-1 design has threaded connections with canopy seals rather than Item No. B7.80 CRD bolting. In addition, the Conoseal bolting on four (4) instrumentation penetrations is classified as Item B7.10 bolting. As such, there is no Item B7.80 CRD bolting in CPNPP-1.

2.4.19 10CFR50.55a(b)(2)(xxv) - Mitigation of Defects by Modification Prohibiting the use of IWA-4340 for the mitigation of defects by modification as stated in 10CFR50.55a(b)(2)(xxv) is not addressed in the CPNPP-1 ISI Program.

Repair and Replacement activities are addressed in CPNPP Document Nos.

STA-731 and EPG-731, "Repair/Replacement Activities".

On April 28, 2010, the NRC approved a request to continue using the 1998 Edition through 2000 Addenda of ASME Section XI provided CPNPP-1 meets two commitments (see Letter No. CP-201000690 from the NRC). Commitment No. 3891111 states the following, "The licensee will revise the current procedures to prohibit the use of paragraph IWA-4340 until the next code of record update for CPNPP, Unit 1." This commitment matches the criteria in 10CFR50.55a(b)(2)(xxv).

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Comanche Peak Unit 1 Third Interval ISI Program Plan 2.4.20 10CFR50.55a(b)(2)(xxvi) - Pressure Testing Class 1, 2, and 3 Mechanical Joints Placing restrictions on the pressure testing of replaced components and appurtenances per IWA-4540(c) as stated in 10CFR50.55a(b)(2)(xxvi) is not addressed in the CPNPP-1 ISI Program. Repair and Replacement activities are addressed in CPNPP Document Nos. STA-731 and EPG-731, "Repair/Replacement Activities".

On April 28, 2010, the NRC approved a request to continue using the 1998 Edition through 2000 Addenda of ASME Section XI provided CPNPP-1 meets two commitments (see Letter No. CP-201000690 from the NRC). Commitment No. 3891114 states the following, "The licensee will revise the current procedures to invoke the use of paragraph IWA-4540(c) until the next code of record update for CPNPP, Unit 1." Based on what is written in 10CFR50.55a(b)(2)(xxvi), Luminant will use the 1998 Edition of ASME Section XI when invoking paragraph IWA-4540(c).

2.4.21 10CFR50.55a(b)(3)(v) - Subsection ISTD, Article IWF-5000 Per 10CFR50.55a(b)(3)(v) licensees may use Subsection ISTD, "Inservice Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Power Plants,"

ASME OM Code, 1995 Edition through the 2004 Edition, in place of the requirements for snubbers in Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their technical specifications or licensee-controlled documents. As of the start of the third interval, CPNPP- 1 is performing snubber testing per Technical Requirements Manual 15.5.3 1. As such, CPNPP-1 is not invoking 10CFR50.55a (b)(3)(v) at this time.

2.4.22 10CFR50.55a(g)(4) - Examination of Class MC Supports As required by 10CFR50.55a(g)(4), components which are classified as Class MC pressure retaining components and their integral attachments, and components which are classified as Class CC pressure retaining components and their integral attachments will meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Section XI. As discussed in the 10CFR50.55a Final Rule published in 2004, page 58818, Item 13, "Miscellaneous Public Comments on Proposed Rule," the term "integral attachment" will include supports. Subsection IWE and IWL requirements are addressed in a separate CPNPP Containment ISI Program Plan.

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Comanche Peak Unit 1 Third Interval ISI Program Plan 2.4.23 10CFR50.55a(g)(4)(iii) - Examination of Piping Welds in High Pressure Safety Injection Systems CPNPP-1 will not implement the option in 10CFR50.55a(g)(4)(iii) to perform surface examinations on High Pressure Safety Injection System welds specified in Table IWB-2500-1, Examination Category B-J, Item Numbers B9.20, B9.21, and B9.22. Because CPNPP-1 has a RI-ISI application for Class 1 piping, this modification is not applicable.

2.4.24 10CFR50.55a(g)(6)(ii)(B) - Submittal of Containment Inservice Inspection Programs 10CFR50.55a(g)(6)(ii)(B) states that licensees do not have to submit their containment inservice inspection programs to the NRC staff for approval. As such, the containment inservice inspection requirements for ASME Section XI Subsections IWE and IWL contained in the Containment Inservice Inspection Program Plan are maintained at CPNPP.

2.4.25 10CFR50.55a(g)(6)(ii)(C) - Implementation of Appendix VIII to Section XI The implementation schedule for ASME Section XI, Appendix VIII as stated in 10CFR50.55a(g)(6)(ii)(C) was previously met during the Second Interval at CPNPP-1. No further action is required.

2.4.26 10CFR50.55a(g)(6)(ii)(D) - Reactor Vessel Head Inspections CPNPP-1 will meet the criteria of 10CFR50.55a(g)(6)(ii)(D) for the performance of reactor vessel head inspections. These examinations are addressed in the CPNPP-1 Augmented Inservice Inspection Plan.

2.4.27 10CFR50.55a(g)(6)(ii)(E) - Reactor Coolant Pressure Boundary Visual Inspections CPNPP-1 will meet the criteria of 10CFR50.55a(g)(6)(ii)(E) for the performance of reactor coolant pressure boundary visual inspections. These examinations are addressed in the CPNPP-1 Augmented Inservice Inspection Plan.

2.5 Inspection Intervals and Scheduling 2.5.1 Inspection Intervals Per IWA-2430 of ASME Section XI, the inservice examinations and system pressure tests required by IWB, IWC, and IWD, and the examinations and tests of IWF shall be completed during each of the inspection intervals for the service lifetime of the power unit. The inspections shall be performed in accordance with the schedule of Inspection Program A of IWA-2431 or optionally, Inspection Program B of IWA-2432. Because the Code of Federal Regulations, 10CFR50.55a(g)(4)(ii) specifies 120 month inspection intervals for inservice inspections, Inspection Program B will be employed.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Per IWA-2430(d), for components inspected under Program B, each of the inspection intervals may be extended or decreased by as much as one year.

Adjustments shall not cause successive intervals to be altered by more than one year from the original pattern of intervals.

Per IWA-2430(e), in addition to the interval adjustment allowed per IWA-2430(d), for power units that are out of service continuously for 6 months or more, the inspection interval during which the outage occurred may be extended for a period equivalent to the outage and the original pattern of intervals extended accordingly for successive intervals.

CPNPP-1 entered its third interval on August 13, 2010. To date, CPNPP-1 has not exercised the options provided in IWA-2430(d) or IWA-2430(e) for the extension or decrease of the ten-year inspection intervals.

2.5.2 Inspection Scheduling Per IWA-2420, inspection plans shall be prepared for the first inservice interval and subsequent inspection intervals. Per 1WA-2420(b), an implementation schedule for performance of examinations and tests shall be prepared for each inspection plan.

Subarticles IWB-2400, IWC-2400, IWD-2400, and IWF-2400 include the requirements for the scheduling of examination and tests for Class 1 components, Class 2 components, Class 3 components, and Class 1, 2, and 3 component supports, respectively.

Per IWB-2410, inservice examinations and system pressure tests of Class 1 components may be performed during plant outages such as refueling shutdowns or maintenance shutdowns. The term "may" allows the examinations and system pressure tests to be performed during system operation. Per IWC-2410, IWD-2410, and IWF-2410, inservice examinations and system pressure tests of Class 2, Class 3 and Class 1, 2, and 3 component supports, respectively may be performed during either system operation or plant outages.

Specific scheduling criteria are included in IWB-2412, IWC-2412, IWD-2412, and IWF-2410 for plants which are employing Inspection Program B.

These paragraphs reference Tables 1WB-2412-1, lWC-2412-1, IWD-2412-1, and IWF-2410-2, which include minimum and maximum percentages of examinations required to be completed by inspection period. Table 2.5-1 in this ISI Program Plan summarizes this information for the third interval at CPNPP-1.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Per IWB-2412, examinations listed in IWB-2412(a)(1) to (5) as specified in Table TWB-2500-1 are not required to meet the criteria in Table IWB-2412-1.

In the event that an Examination Category includes less than three components or items, the components or items may be examined in any two periods; or if in any one period if there is only one item or component in lieu of the requirements of Table IWB-2412-1.

TABLE 2.5-1 INSPECTION PROGRAM B COMPONENT/COMEPONENT SUPPORT SCHEDULING Inspection Inspection Inspection Period, Minimum Maximum Interval Period Calendar Years of Examinations Examinations Plant Service Completed, % Completed, %

3 1 23 16 50 3 2 27 501 75 3 3 30 100 100 If the first period completion percentage for any examination category exceeds 34%, at least 16% of the required examinations shall be performed in the second period.

2.6 Successive and Additional Examinations 2.6.1 Successive Examinations Successive examinations for Class 1, 2, and 3 items and their supports shall be performed in accordance with ASME Section XI IWB-2420, IWC-2420, IWD-2420 and IWF-2420, respectively.

2.6.2 Additional Examinations Additional examinations for Class 1, 2, and 3 items and their supports shall be performed in accordance with ASME Section XI IWB-2430, IWC-2430, IWD-2430 and IWF-2430, respectively.

2.7 Augmented Examinations Augmented inservice inspection programs address examinations that go beyond what is required by ASME Section XI. In some instances, augmented programs may require examinations on components that are not normally subject to ISI per ASME Section XI.

In other instances, the augmented programs may stipulate supplemental examination criteria on components that are already addressed by ASME Section XI. These augmented examinations satisfy commitments to such items as NRC documents, 2-13 Revision 0'

Comanche Peak Unit 1 Third Interval ISI Program Plan industry initiatives and plant internal positions. The augmented examination commitments for CPNPP-l are documented in the "Augmented Inservice Inspection Plan". Additional information on the examination of Alloy 600 items is provided in the "Strategic Plan for Alloy 600".

2.8 Risk-Informed Inservice Inspection Application Provided below is a general description of the Risk-Informed Inservice Inspection (RI-ISI) Program at CPNPP-1 and description of the RI-ISI "Living Program" update. The application of the RI-ISI Program for the third interval is addressed by Request for Alternative No. A-1.

2.8.1 Initial RI-ISI Application ASME Section XI Examination Categories B-F, B-J, C-F-i, and C-F-2 originally contained the requirements for the nondestructive examination (NDE) of Class 1 and 2 piping welds. In 2001, a risk-informed methodology for the inservice inspection of Class 1 and 2 piping welds was applied at CPNPP-1. The risk-informed inservice inspection process used in this application is described in Electric Power Research Institute (EPRI) Topical Report (TR) 112657, Rev. B-A "Revised Risk-Informed Inservice Inspection Evaluation Procedure." The RI-ISI application was also conducted in a manner consistent with ASME Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method B."

This risk-informed application met the intent and principles of Regulatory Guide

1. 174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant-Specific Changes to the Licensing Basis" and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection of Piping".

The original RI-ISI template, "Risk-Informed Inservice Inspection Program Plan

- Comanche Peak Steam Electric Station Units 1 and 2 (Revision 1)" was submitted to the NRC for approval per 10CFR50.55a(a)(3)(i) in Letter No. TXX-01026, dated February 15, 2001. Based upon the information provided in the RI-ISI template, the request to implement the RI-ISI methodology on Class 1 and 2 piping welds was approved by the NRC in a letter dated September 28, 2001 (TAC Nos. MB 1201 and MB 1202). Approval was based on the alternative providing an acceptable level of quality and safety.

Other non-related portions of the ASME Section XI Code were unaffected by the RI-ISI application. EPRI TR-1 12657 provides the requirements for defining the relationship between the RI-ISI program and the remaining unaffected portions of ASME Section XI.

This Section of the ISI Program Plan provides an overview of the EPRI RI-ISI methodology and explains the application.

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Comanche Peak Unit 1 Third Interval ISI Program Plan The tasks involved in the RI-ISI application were as follows:

Task 1: Scope and Exemption Determination Task 2: Consequence Evaluation Task 3: Degradation Mechanism Assessment Task 4: Service History Review Task 5: Segment Risk Ranking Task 6: Element Selection Task 7: Risk Impact Evaluation Task 8: Program Submittal/ Risk-Informed Template Details on performance of these RI-ISI tasks are provided in the following paragraphs.

Task 1: Scope and Exemption Determination Per EPRI TR-112657 and ASME Code Case N-578-1, the EPRI risk-informed methodology may be applied to piping welds in Class 1, 2, 3, and non-classed systems, to individual Classes or combination of Classes, or to individual systems. For CPNPP-1, the RI-ISI methodology was applied to piping welds in Class 1 and 2 systems. This corresponded to ASME Section XI Examination Categories B-F, B-J, C-F-1, and C-F-2. Classification boundaries were not changed or otherwise affected by the RI-ISI application. In addition, the ASME Section XI exemption criteria, as addressed in IWB-1220 and IWC-1220, were not affected. Therefore, piping that was previously exempted per ASME Section XI remained exempt in the RI-ISI application.

Task 2: Consequence Evaluation Calculations were prepared documenting the pipe rupture consequence evaluation, and indicating the consequence category assigned to each piping segment, as well as the technical basis for those assignments. The consequence evaluation used insights from the plant's Individual Plant Examination (WPE) and Individual Plant Examination External Events (IPEEE) submittals. Pipe breaks at various locations were postulated to cause an initiating event, reduce or disable plant mitigating ability, effect containment performance, or any combination of the above effects. Potential spatial effects (e.g., steam spray, flooding, etc.) were also evaluated for the postulated pipe breaks. The consequence rank was based 2-15 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan on these effects and on their impact on the plant core damage frequency (CDF) or large early release frequency (LERF). Results of the consequence evaluation were ultimately summarized in the risk ranking tables that are discussed in Task 5.

Task 3: Degradation Mechanism Assessment Detailed calculations were prepared documenting the evaluation of each piping segment with respect to the EPRI criteria for susceptibility to the various potential degradation mechanisms, and identifying specifically which degradation mechanisms are or are not applicable to each piping segment. The degradation mechanisms identified in the EPRI methodology as being applicable to nuclear plant piping are shown in Table 2.8-1. Specific criteria for susceptibility to these degradation mechanisms are spelled out in EPRI TR-112657. Once the degradation mechanisms were assigned to each piping segment in accordance with the EPRI criteria, the pipe rupture potential was established using the criteria shown in Table 2.8-1. The degradation mechanism evaluation was conducted in the form of a checklist for each system or portion of system included in the scope of the program. The results were documented in an engineering calculation. Results of the degradation mechanism assessment were ultimately summarized in the risk ranking tables that are discussed in Task 5.

TABLE 2.8-1 DEGRADATION MECHANISM CATEGORIES Pipe Expected Degradation Mechanisms To Rupture Leak Which The Segment is Potential.Conditions Susceptible Flow Accelerated Corrosion (FAC)

Water Hammer(1 )

Thermal Fatigue (TASCS, Thermal Transients)

Stress Corrosion Cracking (IGSCC, TGSCC, PWSCC, Small ECSCC)

MEDIUM Localized Corrosion (MIC, Crevice Corrosion and Pitting)

Erosion-Cavitation LOW None No Degradation Mechanisms Present (1) Water hammer in concert with any of the degradation mechanisms listed under "Medium" Pipe Rupture Potential.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Task 4: Service History Review To supplement the degradation mechanism assessment performed under Task 3, a service history and susceptibility review was performed. This entailed a review of databases (plant and industry) and station documents to characterize operating experience with respect to piping pressure boundary degradation. This review also included an appraisal of previous water hammer events. Various plant documents were reviewed as part of this effort including Outage Summary Reports, Licensee Event Reports (LERs), and corrective action documents.

Task 5: Segiment Risk Ranking Once the degradation mechanism assessment and consequence evaluation were completed, the results were used to perform a risk ranking of the piping segments within the scope of the RI-ISI effort. The piping segments were classified in accordance with the RI-ISI Risk Matrix (see Table 2.8-2), with the highest risk elements in the upper right hand comer of the matrix, and the lowest risk elements in the lower left hand comer.

TABLE 2.8-2 RI-ISI RISK MATRIX Consequence Assessment CONSEQUENCE CATEGORY CCDP and CLERP Potential Failure Potential NONE LOW MEDIUM HIGH Assessment O-- HIGH ...0 W MEDIUM H1GE HIG 3 (3 a, (Cat 5) "

Is

• " / ,' " 5"," / _ _

0O L WW,,/ O-A.W0 MEDIUM HIGH Z-D MEDIUM ""'(C~ - 4-,,,6),'v(Cat. 5)//*

/: /" /,Y "/7_ _ _

LW1 /W -, / ,QW, MEDIUM

(.at.7) /(Ct, 7) ,&, ', (Cat. 4)

The resulting risk ranking, along with the applicable input from the consequence evaluation and degradation mechanism assessment, were documented in risk ranking tables that included a summary table, matrix table, and report table.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Task 6: Element Selection Once the above tasks were completed, the project team convened an element selection meeting during which specific piping elements (generally welds) were selected for RI-ISI examination. The objective of this meeting was to select inspection locations in a way that minimized risk, cost, and radiation exposures.

Examination element selections were conducted such that:

• 25% of the elements in the high risk region (i.e., risk categories 1, 2 and 3) were chosen for inspection.

• 10% of the elements in the medium risk region (i.e., risk categories 4 and 5) were chosen for inspection,

• No elements are required to be selected in the low risk region (i.e., risk categories 6 and 7), but all locations regardless of risk category will continue to receive pressure/leakage testing.

Important considerations in the element selection process were inspectability, distribution of inspections among systems and segments, plant-specific inspection results, and radiation exposure. Elements that were selected for examination were indicated as such by underlining them in the risk ranking report table.

Task 7: Risk Impact Evaluation Once the element selection under Task 6 was completed, the new set of locations that will be inspected under the RI-ISI program were compared to the locations that were inspected per ASME Section XI prior to the application of the RI-ISI methodology. A risk comparison was performed to ensure that the changes due to the new program resulted in either a reduction in risk, or at worst a negligible increase in risk, in accordance with applicable regulatory guidelines (Regulatory Guides 1.174 and 1.178). This was achieved by verifying that the cumulative impacts of all changes due to the inspection program result in either negligible increases in Core Damage Frequency and Large Early Release Frequency or actual decreases in the risk measurements. The risk impact evaluation was performed using a simplified risk quantification method as described in EPRI TR-1 12657, which has been accepted by the NRC. Results of the evaluation, which indicated a decrease in total risk, were documented in a risk impact analysis.

Task 8: Program Submittal/Risk-Informed Template Utilizing the results of the foregoing tasks, a plant-specific request for acceptable alternative inspection was generated in accordance with regulatory requirements.

The request provided the background, justification and inspection recommendations as determined by the RI-ISI application, and was prepared in 2-18 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan accordance with a template for risk-informed inservice inspection program submittals. This template was developed by industry, NEI and the NRC to streamline the RI-ISI submittal and NRC review process. The risk-informed inservice inspection template was submitted to and approved by the NRC.

2.8.2 Nondestructive Examination Requirements For the risk-informed process, examination requirements shall be in accordance with EPRI Topical Report No. TR- 112657. In some cases, the examination volumes required in the Topical Report are different than those required by ASME Section XI. For example, the examination volume required to examine for thermal fatigue is expanded per the Topical Report to ensure that the potential degradation mechanism is detected, if it exists. CPNPP- 1 will perform RI-ISI examinations in accordance with the Topical Report for Class 1 and 2 piping welds.

2.8.3 Examination Categories and Code Item Numbers As previously discussed, the requirements of EPRI Topical Report No. TR-112657 supersede those of ASME Section XI for Class 1 and 2 piping welds in the risk-informed ISI application. Accordingly, the Examination Categories and Item Numbers provided by ASME Section XI (i.e., Examination Categories B-F, B-J, C-F-i, and C-F-2) have been superseded. Since TR-1 12657 does not provide new Examination Category and Code Item Numbers, guidance has been taken from ASME Section XI Code Case N-578-1 for the assignment of these new numbers. As such, Class 1 and 2 piping welds have been reassigned to Examination Category R-A and Code Item Nos. R1.10 through R1.20, as applicable 2.8.4 Risk-Informed Inservice Inspection "Living Program" Evaluation When CPNPP-1 submitted their initial RI-ISI application to the NRC for approval, the following standard clause was included in the template submittal:

"The RI-ISI program is a living program requiring feedback of new relevant information to ensure the appropriate identification of high safety significant piping locations. As a minimum, risk ranking of piping segments will be reviewed and adjusted on an ASME period basis. In addition, significant changes may require more frequent adjustment as directed by NRC Bulletin or Generic Letter requirements, or by industry and plant specific feedback."

Most U.S. nuclear power plants have implemented RI-ISI Programs with this standard clause to perform periodic reviews and updates. To address this issue, NEI 04-05, "Living Program Guidance To Maintain Risk-Informed Inservice Inspection Programs For Nuclear Plant Piping Systems" was developed. As part 2-19 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan of the ISI Program Update for Interval 3 at CPNPP-1, a RI-ISI Living Program Evaluation was performed in accordance with NEI 04-05. The objective of this evaluation was to review plant and industry activities that could impact the bases of the CPNPP-1 RI-ISI application as it enters the third interval. Any changes to the original RI-ISI parameters were evaluated to determine their impact on the RI-ISI application.

In accordance with NEI 04-05, the following aspects were considered during the evaluation:

" Plant Examination Results

• Piping Failures.

- Plant Specific Failures

- Industry Failures

• PRA Updates

" Plant Design Changes

- Physical Changes

- Programmatic Changes

- Procedural Changes

" Changes in Postulated Conditions

- Physical Conditions

- Programmatic Conditions The RI-ISI Living Program evaluation resulted in the following five issues being addressed in the RI-ISI application:

1) During the first period of the second ISI interval, the ISI Program was based on the 1986 Edition of ASME Section XI. Beginning with the second period of the second ISI interval through the first period of the third ISI interval, the ISI Program is in accordance with the 1998 Edition through 2000 Addenda of ASME Section XI. One of the changes in the new edition and addenda of the Code is that the exemption size for Class 2 auxiliary feedwater piping decreased from 4" NPS to 1 1/22" NPS. As a result, the 4" NPS Class 2 auxiliary feedwater lines from the outboard isolation valves to where they connect to the four main feedwater lines were added to the ISI Program and consequently added to the RI-ISI Program.

2) In PRA Revision 3B dated May 2005, consequence segments 1-SIO1, 1-ACC03A, 1-ACC03B, 1-RHR08A, 1-FW-03A, 1-FW-03B, 1-FW-03C, and 1-FW-03D changed consequence rank from Medium to High. As a result of this change, fourteen segments changed from a risk rank of Low to a risk rank of Medium.

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Comanche Peak Unit 1 Third Interval ISI Program Plan

3) In PRA Revision 3C dated June 2007 consequence segments 1-CT-09A, 1-CT-09B, 1-CVCS06, 1-CVCS07, and 1CVCS08 changed consequence rank from Medium to High. Consequence segment 1CVCS 16 changed.

consequence rank from Medium to Low. Consequence segments 1-RHR03A, 1-RHER08A, and 1-RHR-08B changed consequence rank from High to Medium. Consequence segments 1-SI01 and 1-S102 changed consequence rank from High to Low. As a result of these changes, eighteen Risk Segments changed from a risk rank of Low to a risk rank of Medium, eleven Risk Segments changed from a risk rank of Medium to a risk rank of Low, and one Risk Segment changed from Risk Category 6a to Risk Category 7a, but remained risk rank Low.

4) In PRA Revision 3D dated June 2009 consequence segments 1-CT-03A, 1-CT-03B, 1-CT-04A, 1-CT-04B, 1-CT-05A, and 1-CT-05B, changed consequence rank from Medium to High due to the testing frequency changing from quarterly to once every 18 months. Consequence segments 1-CT07 and 1-CVCS 16 changed consequence rank from Low to Medium.

Consequence segments 1-CT09A, 1-CT09B, and 1-RHR-03B changed consequence rank from High to Medium. Consequence segments 1-CVCS06, 1-CVCS07 and 1-CVCS08 changed consequence rank from High to Low. As a result of these changes, twelve Risk Segments changed from a risk rank of Low to a risk rank of Medium, twenty-one Risk Segments changed from a risk rank of Medium to a risk rank of Low, and six Risk Segments changed from Risk Category 7a to Risk Category 6a, but remained risk rank Low. Maximum CCDP used as the Upper Bound in the Risk Impact Analysis changed to 7.48ER-03. Max CLERP changed to 9.55E-04

5) In Period 2, replacement of the steam generators and some MOVs resulted in numerous welds being deleted, added, or re-designated.

The RI-ISI Program was reevaluated for the five issues using the applicable portions of the same risk-informed process that originally established the risk-informed inspection program. The reevaluation was performed by inserting the new information at the appropriate levels of the analysis. All of the cases that were evaluated in the risk impact analysis during the original RI-ISI application were reevaluated using the new information that was determined for the current application. A new Risk Impact Analysis was performed, and the revised program continues to represent a risk reduction when compared to the last deterministic Section XI inspection program. The original program represented a reduction of 9.73E-09 in regards to CDF and 3.91E-09 in regards to LERF, while the revised program represents a reduction of 8.3E-09 in regards to CDF and 1.06E-09 in regards to LERF.

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Comanche Peak Unit 1 Third Interval ISI Program Plan 2.9 Records and Reports Records and documentation of information and examination results, which provide the basis for evaluation and facilitate the comparison of examination results from previous and subsequent examinations, shall be maintained as permanent plant records at CPNPP in accordance with Article IWA-6000 of the Code. As a minimum, this documentation shall include the applicable records described in Subsection IWA-6340.

2.10 Authorized Nuclear Inservice Inspector In accordance with Subsection IWA-1400, paragraph (f), of the Code, Owner/Designated Agent has maintained a contract with an Authorized Inspection Agency (AIA) for an Authorized Nuclear Inservice Inspector (ANII) to provide inspection services as described in Subsection IWA-21 10 of the Code. The ANII is afforded the opportunity to verify examinations and review the Plan, examination procedures, examination records, certification records, and other associated documents.

2.11 List of Abbreviations Listed below are abbreviations that are used in the CPNPP- 1 ISI Program:

2.11.1 Plant System Abbreviations AFW - Auxiliary Feedwater CC - Component Cooling Water CH - Chilled Water CS - Chemical and Volume Control CT - Containment Spray DD - Demineralized & Reactor Make-up Water DO - Diesel Oil FW - Feedwater MS - Main Steam RC - Reactor Coolant RH - Residual Heat Removal SF - Spent Fuel SI - Safety Injection SW - Service Water 2-22 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 2.11.2 Non-Destructive Examination Method Abbreviations EVT - Enhanced Visual Examination MT - Magnetic Particle Examination PT - Liquid Penetrant Examination UT - Ultrasonic Examination VT - Visual Examination VT-1 - Visual Examination per IWA-2211 VT-2 - Visual Examination per IWA-2212 VT-3 - Visual Examination per IWA-2213 2.11.3 RI-ISI Degradation Mechanism Abbreviations CC - Crevice Corrosion ECSCC - External Chloride Stress Corrosion Cracking FAC - Flow Accelerated Corrosion IGSCC - Intergranular Stress Corrosion Cracking MIC - Microbiologically Induced Corrosion PIT - Pitting PWSCC - Primary Water Stress Corrosion Cracking TASCS - Thermal Stratification Cycling and Striping TGSCC - Transgranular Stress Corrosion Cracking TT - Thermal Transients 2.11.4 Miscellaneous Abbreviations ANII - Authorized Nuclear Inservice Inspector ASME - American Society of Mechanical Engineers BRHL - Brown & Root Hanger Location (Drawings)

BRP - Brown & Root Piping (Drawings)

CADD - Computer Aided Design Drawings CDF - Core Damage Frequency CHR - Containment Heat Removal CPNPP - Comanche Peak Nuclear Power Plant CRC - Corrosion Resistant Cladding DWG - Drawing 2-23 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 2.11.4 Miscellaneous Abbreviations (con't)

ECC - Emergency Core Cooling EPRI - Electric Power Research Institute FSAR - Final Safety Analysis Report GHH - Gibbs & Hill Hanger (Drawings)

ISI - Inservice Inspection LER - Licensee Event Report LERF - Large Early Release Frequency N/A - Not Applicable NDE - Nondestructive Examination NPS - Nominal Pipe Size NRC - Nuclear Regulatory Commission PDI - Performance Demonstration Initiative PRA - Probabilistic Risk Assessment PSI - Preservice Inspection PTLR - Pressure Temperature Limit Report PWR - Pressurized Water Reactor QA - Quality Assurance RB - Reactor Building RHR - Residual Heat Removal RI-ISI - Risk-Informed Inservice Inspection RPV - Reactor Pressure Vessel RR - Relief Request SG - Steam Generator SWOL - Structural Weld Overlay TB Turbine Building TR - Topical Report 2-24 Revision 0

Comanche Peak Unit I Third Interval ISI Program Plan SECTION 3.0 INSERVICE INSPECTION PROGRAM DRAWINGS This section provides a listing of the various drawings applicable to the CPNPP-1 ISI Program.

3.1 Inservice Inspection Boundary Drawings The systems or portions of systems subject to the examination requirements of the ISI Program for CPNPP-1 and the associated Class 1, 2, and 3 boundaries are documented on ISI Boundary Drawings. The ISI Boundary Drawings are listed in Table 3.1-1.

TABLE 3.1-1 INSERVICE INSPECTION BOUNDARY DRAWINGS SYSTEM SHEET NO. [REVISION NO.

1 2 2 2 Auxiliary Feedwater 3 2 4 2 5 4 1 3 2 3 3 3 4 2 5 2 Chemical and Volume Control 6 2 7 3 8 2 9 2 10 4 11 3 12 3 1 3 2 2 3 3 Chilled Water 4 2 5 3 6 3 7 2 3-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 3.1-1 (con't)

INSERVICE INSPECTION BOUNDARY DRAWINGS SYSTEM SHEET NO. REVISION NO.

1 2 2 2 3 4 4 2 5 2 Component Cooling 7 4 81 91 10 2 11 2 12 3 1 4 2 4 Containment Spray 4 3 Demineralized & Reactor Make-up 1 3 Water 2 3 1 2 Diesel Generator Auxiliary 1 1 2 2 Feedwater 3 2 4 2 1 2 2 4 Main Steam 3 2 4 2 5 1 1 2 Reactor Coolant 2 2 3 2 1 2 Residual Heat Removal 2 4 3-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 3.1-1 (con't)

INSERVICE INSPECTION BOUNDARY DRAWINGS SYSTEM I SHEET NO. I REVISION NO.

1 2 2 1 3 2 4 1 Safety Injection 5 1 6 1 7 2 8 3 9 3 1 2 Spent Fuel Cooling and Cleanup

__ __ __ _ _ _ _ _2 j2 1 3 2 2 Station Service Water 3 3 4 3 5 2 3.2 Inservice InsDection Isometric Drawings ISI isometric drawings have been developed to identify the ISI examination areas for examinations required by ASME Section XI tables IWB-2500, IWC-2500, and IWF-2500 (Code Class 1 and 2 only). These drawings are maintained current by CPNPP. Revisions to these ISI isometric drawings are prepared and approved in accordance with site implementing procedures. These drawings are CADD and controlled by Engineering Programs and the ISI Engineer. No specific ISI isometric drawings have been created to reflect the ASME Code Class 2 AFW lines, which were added in 2004 when updating the CPNPP-1 ISI Program to the 1998 Edition through 2000 Addenda of ASMEE Section XI. Weld numbers for examinations in the ISI Program were taken directly from weld numbers shown on the plant Brown & Root piping drawings.

Plant Brown & Root Piping (BRP) drawings, Brown & Root Hanger Location (BRHL) drawings, Gibbs & Hill Hanger (GHH) drawings and vendor drawings for vessels, pumps, and valves are specifically used to identify examination areas for examinations as required by ASME Section XI Tables IWD-2500 and IWF-2500 (Code Class 3) and also to provide references for Class 1 and 2 examinations.

The ISI isometric drawings for Class 1 and 2 components at CPNPP-1 are listed in Table 3.2-1.

3-3 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 3.2-1 INSERVICE INSPECTION ISOMETRIC DRAWINGS CLASS 1 DRAWING REV. DRAWING REV. DRAWING REV.

NO. NO. NO. NO. NO. NO.

TBX-1-1100 1 TBX-1-4200 2 TBX-1-4400 3 TBX-1-1100A 2 TBX-1-4201 1 TBX-1-4401 1 TBX-1-1200 2 TBX-1-4202 1 TBX-1-4402 2 TBX-1-1300 1 TBX-1-4203 1 TBX-1-4403 1 TBX-1-1300A 2 TBX-1-4204 1 TBX-1-4404 1 TBX-1-1400 1 TBX-1-4205 1 TBX-1-4405 1 TBX-1-2100 2 TBX-1-4206 1 TBX-1-4406 1 TBX-1-3100 2 TBX-1-4207 1 TBX-1-4407 1 TBX-1-4100 2 TBX-1-4208 1 TBX-1-4408 1 TBX-1-4101 1 TBX-1-4300 2 TBX-1-4409 1 TBX-1-4102 1 TBX-1-4301 1 TBX-1-4410 1 TBX-1-4103 1 TBX-1-4302 1 TBX-1-4500 2 TBX-1-4104 1 TBX-1-4303 1 TBX-1-4501 2 TBX-1-4105 1 TBX-1-4304 1 TBX-1-4502 2 TBX-1-4106 1 TBX-1-4305 1 TBX-1-4503 2 TBX-1-4107 1 TBX-1-4306 2 TBX-1-4504 2 TBX-1-4108 1 TBX-1-4307 1 TBX-1-4505 2 TBX-1-4109 1 TBX-1-4308 1 TBX-1-4600 1 TBX-1-4110 1 TBX-1-4309 1 TBX-1-5100 1 TBX-1-4111 2 TBX-1-5100A 1 TBX-1-5100B 0 TBX-1-5100C 0 3-4 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 3.2-1 INSERVICE INSPECTION ISOMETRIC DRAWINGS CLASS 2 DRAWING [REV. fDRAWING 1REV. [DRAWING REV.

NO. [NO. NO. NO. [ NO. jNO.

TBX-2-1100 2 TBX-2-2534 1 TBX-2-2573 1 TBX-2-11 10 1 TBX-2-2535 1 TBX-2-2574 0 TBX-2-1120 1 TBX-2-2536 2 TBX-2-2575 0 TBX-2-1140 1 TBX-2-2537 1 TBX-2-2576 1 TBX-2-1 150 1 TBX-2-2538 2 TBX-2-2577 0 TBX-2-1160 1 TBX-2-2538A 1 TBX-2-2578 0 TBX-2-1 190 1 TBX-2-2539 1 TBX-2-2579 0 TBX-2-2100 4 TBX-2-2539A 1 TBX-2-2580 0 TBX-2-2101 5 TBX-2-2540 2 TBX-2-2581 0 TBX-2-2102 3 TBX-2-2541 1 TBX-2-2582 0 TBX-2-2200 4 TBX-2-2542 1 TBX-2-2583 2 TBX-2-2201 6 TBX-2-2550 2 TBX-2-2584 0 TBX-2-.2202 3 TBX-2-2551 1 TBX-2-2585 0 TBX-2-2300 5 TBX-2-2560 2 TBX-2-2586 0 TBX-2-2301 5 TBX-2-2561 2 TBX-2-3 100 1 TBX-2-2302 3 TBX-2-2562 1 TBX-2-3110 1 TBX-2-2400 5 TBX-2-2563 1 TBX-2-3 140 1 TBX-2-2401 5 TBX-2-2564 1I __________

TBX-2-2402 3 TBX-2-2565 1 ___________

TBX-2-2500 2 TBX-2-2566 I ________ ___

TBX-2-2501 2 TBX-2-2566A 1 _______

TBX-2-2520 1 TBX-2-2567 1 ___

TBX-2-2521 1 TBX-2-2568 2 ___

TBX-2-2530 1 TBX-2-2569 1 ___

TBX-2-2531 1 TBX-2-2570 2 ______ ___

TBX-2-2532 1 TBX-2-2571 1 ___________

TBX-2-2533 1 TBX-2-2572 0 ___________

3-5 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 4.0 NONDESTRUCTIVE EXAMINATIONS This section describes the various nondestructive examinations available to CPNPP-1. The three types of examination methods employed for Inservice Inspection are visual, surface and volumetric. Each of these types describes a general technique which, in some cases, permits a selection of different methods within that type. The methods allow the owner to select the most effective examination methodology based on factors such as component accessibility, radiation levels and component material of construction. This section of the ISI Program Plan also addresses ultrasonic calibration blocks, valve groupings, component support examinations and eddy current testing of steam generator tubing.

4.1 Visual Examination Visual examination is divided into three different methods: VT-1, VT-2, and VT-3.

4.1.1 VT-1 (IWA-2211)

VT-1 examinations are conducted to detect discontinuities and imperfections on the surfaces of components, including such conditions as cracks, wear, corrosion, or erosion.

4.1.2 VT-2 (IWA-2212)

(a) VT-2 examinations are conducted to detect evidence of leakage from pressure retaining components, with or without leakage collection systems, as required during the conduct of system pressure test.

(b) VT-2 examinations shall be conducted in accordance with IWA-5000. For direct examination, the Table IWA-2210-1 maximum examination distance shall apply to the distance from the eye to the surfaces being examined.

4.1.3 VT-3 (IWA-2213)

VT-3 examinations are conducted to determine the general mechanical and structural condition of components and their supports by verifying parameters such as clearances, settings, and physical displacement; and to detect discontinuities and imperfections, such as loss of integrity at bolted or welded connections, loose or missing parts, debris, corrosion, wear, or erosion. VT-3 includes examinations for conditions that could affect operability or functional adequacy of snubbers and constant load and spring type supports.

4-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 4.2 Surface Examination A surface examination indicates the presence of surface discontinuities. It may be conducted by a magnetic particle, a liquid penetrant, or an eddy current method. Any linear indication that exceeds the allowable linear surface flaw standards shall be recorded.

4.2.1 Magnetic Particle Examination (IWA-2221)

The magnetic particle (MT) examination shall be conducted in accordance with Article 7 of Section V of the ASME Boiler and Pressure Vessel Code. MT of coated materials shall be conducted in accordance with Article 7, Appendix I of Section V.

4.2.2 Liquid Penetrant Examination (IWA-2222)

The liquid penetrant examination shall be conducted in accordance with Article 6 of Section V of the ASMIE Boiler and Pressure Vessel Code.

4.2.3 Eddy Current Examination (IWA-2223)

Eddy current examination for detection of surface flaws shall be conducted in accordance with Appendix IV of the Code.

4.3 Volumetric Examination A volumetric examination indicates the presence of discontinuities throughout the volume of material.

4.3.1 Radiographic Examination (IWA-2231)

Radiographic techniques, employing penetrating radiation such as X-rays, gamma rays, or thermalized neutrons, may be utilized with appropriate image-recording devices, such as photographic film or papers, electrostatic systems, direct image orthicons, or image converters. For radiographic examinations employing either X-ray equipment or radioactive isotopes and photographic films, the procedure shall be as specified in Article 2 of Section V of the ASME Boiler and Pressure Vessel Code.

In the second interval, new ASME Code Class I and 2 piping welds installed during IRF12 for the Steam Generator Replacement Project used digitized radiography that was reconciled to Article 2 of Section V of ASME Boiler and Pressure Vessel Code, 2004 Edition, 2005 Addenda.

4-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 4.3.2 Ultrasonic Examination (IWA- 2232)

Ultrasonic examination shall be conducted in accordance with Appendix I of Section XI of the ASME Boiler and Pressure Vessel Code.

4.3.3 Eddy Current Examination (IWA-2233)

Eddy current examination shall be conducted in accordance with Section V, Article 8, Appendix II of the ASME Boiler and Pressure Vessel Code. For Inspection Program for Steam Generator Tubing refer to ASME Section XI Subsection IWB-2413 and paragraph 4.7 below.

4.4 Personnel Oualification Requirements Personnel performing nondestructive examinations shall be qualified and certified using a written practice prepared in accordance with ANSI/ASNT CP- 189, dated 1995, as required by IWA-2300 of Section XI and as modified by 10CFR50.55a(b)(2)(xviii). The written practice for CPNPP is documented in Procedure No. NDE 1.01, "Nondestructive Examination Personnel Training, Qualification and Certification."

Personnel performing Appendix VIII ultrasonic examinations shall meet the qualification requirements of Appendix VIII, as modified by 10CFR50.55a(b)(2)(xiv),

10CFR50.55a(b)(2)(xv) and 10CFR50.55a(b)(2)(xvi).

4.5 Ultrasonic Calibration Blocks The ultrasonic calibration blocks that are utilized at CPNPP-1 are listed in Table 4.5-1.

TABLE 4.5-1 ULTRASONIC CALIBRATION BLOCKS CALIBRATION BLOCK SIZE/ MATERIAL SYSTEM/

BLOCK NO. PIPE SCHEDULE COMPONENT TBX-1 12.25"L x 6.00"W x SA-533 Gr. B, Pressurizer 3.50"T Class-1 C.S.

8.OOL x 3.00"W x Reactor Coolant 3.00"T A C Pipe (1982)

TBX-3 3" sch. 160 A376 Type-316 Piping Control Rod Drive TBX-4 4" sch. 160 A376 Typre-304 Mech. Housings TBX-5 6" sch. 160 A376 Type-304 Piping TBX-6 6" sch. 40S A376 Type-304 Piping Letdown Reheat TBX-7 8" sch. 40S A376 TIe-304 Heat Exchanger 4-3 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 4.5-1 ULTRASONIC CALIBRATION BLOCKS CALIBRATION BLOCK SIZE/ MATERIAL SYSTEM/

BLOCK NO. PIPE SCIIEDULE COMPONENT Excess Letdown TBX-8 8" sch. 140 A376 Typte-316 Heat Exchanger TBX-9 10" sch. 140 A376 Type-304 Regenerative Heat Exchanger TBX-10 10" sch. 40S A312 Type-316 Piping TBX-11 12" sch. 40S A312 Type-316 Piping TBX-12 12" sch. 140 A376 Type-304 Piping TBX-13 14" sch. 140 A376 Type-316 Piping TBX-14 14" sch. 40 A358 Type-316 Piping TBX-15 16" sch. 40S A312 Type-304 Piping 9.00"L x 4.00"W x Seal Water Heat TBX- 16 .48TA240

.468"T Type- 304Exhne Exchanger TBX-17 8" sch.80 A106 Grade-B C.S. Piping TBX-18 8" sch. 160 A312 Type-304 Piping TBX-19 14" sch. 160 A312 Type-304 Piping TBX-20 16" sch. 80 A106 Grade-B C.S. Piping TBX-21 18" sch. 80 A106 Grade-B C.S. Piping TBX-22 24" sch.80 A106 Grade-B C.S. Piping TBX-23 1.50" sch. 160 A376 Type-316 Piping TBX-24 2" sch. 160 A376 Type-316 Piping R.V. Stud & R.C.

TBX-25 7" Lg. Stud SA-540 C.S. Pump Bolting (1982)

22. 10"L x 6.00"W x SA-533 Grade-A Reactor Vessel 6.30"T Class-1 C.S. Bottom Head 20.8"L x 6.00"W x SA-533 Grade-A Steam Generator 4.00"T Class-1 C.S. Secondary side 19.10"L x 6.00"W x SA-508 Grade-A Steam Generator TBX-28 5.45"T Class-i C.S.Tueet Channel Head to Tubesheet

30. 10"L x 6.00"W x SA-533 Grade-A Reactor Vessel 8.60"T Class-1 C.S. Closure Head TBX-30 13.00"L1.0TSA-240 x 4.00"W x Type-304Exhge Residual Heat 1.00"T Exchanger 9.00"L x 4.00"W Horizontal letdown x.625"T Heat Exchanger 9.00"L x 4.00"W x Volume Control TBX-32 .312"TSA-240 Type-304Tank 4-4 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 4.5-1 ULTRASONIC CALIBRATION BLOCKS CALIBRATION BLOCK SIZE/ MTERIAL SYSTEM!

BLOCK NO. PIPE SCHEDULE COMPONENT TBX-33 32" x 1.25T SA-106 Grade-B 32" Main Steam C.S.

TBX-34 6" sch. 120 SA-333 Grade-B Piping

___________ _ ____________C.S._ _ _ _ _ _ _

TBX-35 6" sch.80 SA-333 Grade-B Piping

______ ______ ______C.S._ _ _ _ _ _ _ _ _

TBX-36 6" sch. 160 SA-106 Grade-B Piping C.S.

TBX-37 8" sch. 160 SA-106 Grade-B Piping

_______________~~ C.S. _ _ _ _ _ _ _ _

TBX-38 18" sch. 140 SA-1 06 Grade-B Piping

______________ ~C.S. _ _ _ _ _ _ _ _

TBX-39 24 sch. 100 SA-106 Grade-B Piping C.S.

13.00"L x 4.00"W x SA-515-74B Grade- Pressurizer Skirt 1.502"T 70 Weld TBX-41 12" sch.30 SA-106 Grade-B R.C. Drain Tank C.S. Heat Exchanger SA-333 Grade-B Excess Letdown C.S. Heat Exchanger R.C. Drain Tank TBX-43 12" sch. 20 A-312 Type-304 Heat Exchanger TBX-44 3" sch. 80 SA-312 Type-304 Piping TBX-45 4" sch. 80 SA-312 Type-304 Piping TBX-46 14" sch.40 SA-312 Type-304 Piping TBX-47 14" x .500"T SA-312 Type-304 Piping TBX-48 16" sch. 30 SA-312 Type-304 Piping TBX-49 18" x .375"T SA-312 Type-304 Piping TBX-50 24" sch. 20 SA-312 Type-304 Piping TBX-51 12" sch. 80 SA-312 Type-304 Piping TBX-52 24"L x 6.812" dia. SA-540 Gr. B24 RPV Stud (1993)

TBX-53 9.25"L x 2.125" dia. SA-193 Gr. B7 SI Pump Stud RC Pump (1993) Stud TBX-54 35"L x 4.5" dia. SA-540 Gr. B24 (1993)

TBX-55 5.5" x 4.5" x 5.8" SA-508 Cl. 2 Pr Spr Nozzle IR TBX-56 11" x 4.5" x 9.93" SA-508 Cl. 2 SG FW Nozzle IR Reactor Coolant TBX-57 12" x 12" x 2.7" A-351 Gr. CF8M Pe (1993)

Pie(993) 4-5 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 4.5-1 ULTRASONIC CALIBRATION BLOCKS CALIBRATION BLOCK NO.

BLOCK SIZE/

PIPE SCHEDULE f M SYSTEM/

COMPONENT TBX-58 7-1/2" x 7" x 8" SA-508 Cl. 2 Pr. Surge Nozzle IR Pr. Sfty /Rlf TBX-59 7" x 7" ____

x 7"____

___ _____ SA-508

___ ____ Cl.

___ 2 ___Nozzle Pr.Sft IR JR 16.07"L x New SG Primary TBX-60 16.24"/7.65"W x SA-508 Cl. 3a Nozzle IR 6.0"T NozzleIR 15.29"L x TBX-61 13.39"/7.76"W x SA-508 Cl. 3a NewzSG FW 4.0"T Nozzle IR TBX-62 11.81"L x 6.0"W x 3OTSA-508 C1. 3a New SG T Shell to 3.0"T TS New SG FW/AFW 17.32"L x 6.0"W x Nozzle to Vessel &

T5.0"T SG Elliptical Head to Upper Shell 17.32"L x 6.0"W x New SG TS to TBX-64 5OTSA-508 5.0"T Cl. 3a CanlHa Channel Head TBX-65 13.78"L x Pipe x SA-336 F 316 LN New SG Safe-end 4.83"T TBX-RV-1 45.00"LlO" x 11.00"W x SA-533 Gr. B Cl. 1Blc Basic 11" RPV 1 1.00"T Block TBX-RV-2 36.00"L x 9.00"W x 9.OTSA-533 Gr. B Cl. 1Blc Basic 9" RPV 9.00"T Block TBX-RV-3 28.00"L x 6.00"W x 7.OTSA-533 Gr. B Cl. 1Blc Basic 7" RPV 7.00"T Block TBX-RV-4____

TBX-RV-4 20.00"L x 6.00"W x 5.OSA-533 Gr. B Cl. 1 Basic lc5" RPV 5.00"T Block TBX-RV-5 33.00"L1.OTSA-533 x 11.00"W x Gr. B Cl. 1 RPV Lgfin Flange 11.00"T Ligainent TBX-RV-6 10.00"L x 6.00"W x SA-503 Cl. 2 RPV Safe End 3.00"T 41.50"L x 7.00"W x TBX-RV-7 1515.25"T.00"W ASTM A508 Cl. 2 RPV Shell TCX-RV-1 45.00"L1.OTSA-533 xI 1.00"W x Gr. B Cl. 1Blc Basic 11" RPV 11.00"T Block TCX-RV-2 36.00"L x 9.00"W x 9.OTSA-533 Gr. B Cl. 1Blc Basic 9" RPV 9.00"T Block 28.00"L x 6.00"W x Basic 7" RPV TCX-RV-3 7."TSA-533 Gr. B C. 1Block 4-6 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 4.5-1 ULTRASONIC CALIBRATION BLOCKS CALIBRATION BLOCK SIZE/ SYSTEM/

BLOCK NO. PIPE SCHEDULE COMPONENT 20.00"L x 6.00"W x Basic 5" RPV TCX-RV-4 5.OTSA-533 5.00"T Gr. B Cl. 1Blc Block TCX-RV-5 x 11.00"W 33.00"L11.00"T x RPV Flange TCX-RV-5____ 0TSA-533 Gr. B Cl. 1 Lgmn Ligament TCX-RV-6 10.00"L x 600W x SA-503 Cl. 1 RPV Safe End 3.00"T SS-CB- 1 1/2"T toStpSA-312 3"T x 3"W Typre 304Blc Stainless Steel Alt Step Block CS-BC-1 1/2"T to 3"T x 3W SA-516 Gr. 70 Carbon Steel Block Step Dissimilar Metal DM-CB-1 9"L x 4"W x 2"T SA-312/ SA-516 Alt Block 14.00"L x 2.00"W xAlBoc PDI-01 14 14.00"T

.00"T A-508 C1. 2 RPV Block PDI-02 9.5"L x 2.00"W x 4 SA-516 Gr. 70 C.S. Piping Alt Steps Block PDI-03 9.5"L x 2.00"W x 4 SA-312 Type 304 S.S. Piping Alt Steps Block PDI-04 9.5"L x 2.00"W x 4 SA-312 Type 316 S.S. Piping Alt Steps Block SAP 10294 6.797"dia x 57.687" SA-540 Gr. B24 RPV Closure Stud long 12.00"L x 12.00"W x Steam Generator 1.5"T Inner Radius SWOL of Pressurizer Safety Ax 8-02 8" Axial and Flat A-240 Type 316 (3), Sayean (3), Spray and Relief Nozzles SWOL of Cx 8-02 8" Circumferential A-240 Type 316 Pressurizer Safety (3), Spray and Relief Nozzles SWOL of Ax 16-02 16" Axial and Flat A-240 Type 316 Pressurizer Surge Nozzle SWOL of Cx 16-02 16" Circumferential A-240 Type 316 Pressurizer Surge Nozzle 4-7 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 4.6 Valve Groups As allowed by ASME Section XI Tables IWB-2500-1 and JWC-2500-1, valves may be grouped such that examinations are performed by one valve per group. Shown below are the groups for Class 1 and 2 valves.

4.6.1 Class 1 Valve Groups Class 1 valve bodies exceeding 4" NPS have been grouped according to size, constructional design, manufacturing method, and function in accordance with Table IWB-2500-1, Category B-M-2, Note (3) of the Code. These groups are delineated below. Examinations are limited to at least one valve within each group. In addition, these examinations are only required to be performed if the component is disassembled for maintenance, repair or volumetric examination.

Examination of the internal pressure boundary shall include the internal pressure retaining surfaces made accessible for examination by disassembly. If a partial examination is performed and a subsequent disassembly of that valve allows a more extensive examination, an examination shall be performed during the subsequent disassembly. A complete examination is required only once during the interval.

Group 1 - 6" Forged Pressurizer Relief Valves 1-8010A 1-8010B 1-801OC Group 2 - 12" Forged Gate Valves Isolating the RC System from the RHR System 1-8701A 1-8701B 1-8702A 1-8702B Group 3 - 10" Forged Check Valves Isolating the RC System from the SI System 1-8948A 1-8948B 1-8948C 1-8948D 1-8956A 1-8956B 1-8956C 1-8956D 4-8 Revision 0

Comanche Peak Unit I Third Interval ISI Program Plan Group 4 - 6" Forged Check Valves Isolating the RC System from the SI System 1-8818A 1-8818B 1-8818C 1-8818D 1-8949A 1-8949B 1-8949C 1-8949D 1-8841A 1-8841B 4.6.2 Class 2 Valve Groups Class 2 valve body welds have been grouped according to design, size, function and service in a system in accordance with Table IWC-2500-1, Category C-G, Note (1) of the Code. Examinations may be limited to all the welds in one valve in the same group or distributed among any of the valves of that same group.

Group 1 - 8"Forged Gate Valves, MS Safety Isolation 1MS-026 1MS-063 1MS-098 lMS-134 Group 2 - 18" Forged Gate Valves, Main Feedwater Isolation 1FW-071 1FW-077 1FW-083 1FW-089 Group 3 - 6" Forged Check Valves, Feedwater 1FW-195 1FW-196 1FW-197 1FW-198 1FW-199 1FW-200 1FW-201 1FW-202 Group 4 - Group 4 auxiliary feedwater isolation gate valves were removed from the plant in the second interval during the steam generator replacement project 4-9 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan Group 5 - 2" Forged Gate Valves, Containment Spray Isolation 1CT-0026 1CT-0028 1CT-0078 1CT-0084 Group 6 - 2" Forged Gate Valve, Safety Injection 1SI-0048 4.7 Eddy Current Testing Eddy current testing of the steam generators shall be governed by Plant Technical Specifications. Results of the examinations shall be evaluated against acceptance criteria contained in Technical Specification 5.5.9. The steam generator tube examinations are addressed in ASME Section XI, Table IWB-2500-1, Examination Category B-Q, Item No. B 16.20. The criteria for reporting requirements, the corrective actions including expanded examination of samples shall be governed by the Technical Specifications. Other examination parameters shall be in accordance with ASME Section XI.

The original four steam generators were replaced with four new steam generators in 1RF12 (spring 2007) per FDA-2003-002426.

The following License Amendment Requests (LAR) numbers have been taken for eddy current testing:

98-009 Implementation of 1.0 volt repair criteria 98-006 Revision to SG tube plugging criteria 00-004 Steam generator tube repair using laser welded sleeves01-012 Steam generator tube repair using leak tight sleeves 4-10 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 5.0 INSERVICE INSPECTION EXAMINATION

SUMMARY

TABLES This section provides a summary listing of all items subject to inservice inspection during the Third Inspection Interval at CPNPP- 1.

5.1 Summary Tables for ASME Section XI Inservice Inspection Examinations The Class 1, 2 and 3 components and component supports requiring examination per ASME Section XI are shown in Table 5.1-1. ASME Section XI Inservice Inspection Summary Table 5.1-1 provides the following information:

5.1.1 Examination Category This column lists the Examination Category as identified in ASME Section XI, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

5.1.2 Item Number This column lists the Code Item No. as defined in ASME Section XI, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

5.1.3 Description of Components Examined This column lists a description of the components examined as identified in ASME Section XI, Tables IWB-2500-1, IWC-2500-1, 1WD-2500-1, and IWF-2500-1.

5.1.4 Number of Components This column lists the total population of components potentially subject to examination. The number of components actually examined during the inspection interval will be based upon the Code requirements for the subject item number.

5.1.5 Examination Method(s)

The column lists the examination method(s) required by ASME Section XI, Tables IWB-2500-1, lWC-2500-1, IWD-2500-1, and IWF-2500-1.

5-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 5.1.6 Request Number(s)

This column provides a listing of applicable Requests for Alternatives or Relief Requests. If a request number is identified, see the corresponding Request for Alternative or Relief Request in Section 8.0 of this ISI Program Plan.

5.2 Summary Tables for Risk-Informed Inservice Inspection Examinations on Class 1 and 2 Piping Welds As discussed in Section 2.8 of this ISI Program Plan, during the second interval CPNPP submitted letter TXX-01026 to the NRC requesting relief from ASME Section XI Code examination requirements for Class 1 and 2 piping welds (Examination Categories B-F, B-J, C-F-1, and C-F-2) inservice inspections by implementing a Risk-Informed Inservice Inspection (RI-ISI) Program. The request was approved by the NRC in a letter dated September 28, 2001 (TAC Nos. MB 1201 and MB 1202). An updated Request for Alternative is being submitted for the third interval in accordance with 10CFR50.55a(a)(3)(i).

As part of this application, the Class 1 and 2 circumferential piping welds were assigned alternate Examination Category and Code Item Numbers that are consistent with ASME Section XI Code Case N-578-1. For this new numbering system, the following should be noted:

The numbering system established in Code Case N-578-1 is similar to the one used in Code Case N-578. However, the Code Case N-578-1 numbering system is more complete, and more accurately reflects the technical criteria established in EPRI Topical Report No. TR-1 12657. For these reasons, the numbering system established in Code Case N-578-1 will be used instead of the one shown in Code Case N-578.

• In accordance with the 1998 Edition through 2000 Addenda of ASME Section XI, longitudinal Class 1 and 2 piping welds no longer require examination beyond the length of the welds that are normally examined during inspection of the intersecting circumferential welds. Therefore, there is no need to separately address these welds in the risk-informed application.

The alternate risk-informed Examination Category and Code Item Numbers are shown in Table 5.2-1. The Class 1 and 2 circumferential piping welds that were previously listed in Table 5.1-1 have been moved to Table 5.2-1. Note that the total number of Class 1 and 2 circumferential piping welds in the ISI Program remains unchanged. Only the designations have been changed to reflect the Examination Category and Code Item Numbers established in Code Case N-578-1.

The Risk-Informed Inservice Inspection Summary Table 5.2-1 provides the following information:

5-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 5.2.1 Examination Category This column lists the Examination Category as identified in ASME Section XI Code Case N-578-1.

5.2.2 Item Number This column lists the Code Item Number as defined in ASME Section XI Code Case N-578-1.

5.2.3 Description of Components Examined This column provides a description of the elements to be examined, which are classified by their potential degradation mechanism.

5.2.4 Number of Elements This column lists the total population of components that are subject to examination. The number of components actually examined during the inspection interval will be based upon the Risk-Informed Inservice Inspection requirements for the subject item number.

5.2.5 Examination Method(s)

The column lists the examination method(s) required by EPRI Topical Report No. TR-112657 5.2.6 Relief Request Number This column provides a listing of applicable Request for Alternatives or Relief Requests. If a request number is identified, see the corresponding Request for Alternative or Relief Request in Section 8.0 of this ISI Program Plan.

5-3 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Shell Welds B 1.11 Circumferential 3 Volumetric B 1.12 Longitudinal 9 Volumetric B-A Head Welds Pressure Retaining B 1.21 Circumferential 0 Volumetric Welds in Reactor B 1.22 Meridional 0 Volumetric Vessel B 1.30 Shell-to Flange Weld 1 Volumetric B 1.40 Head-to-Flange Weld 0 Volumetric and Surface B 1.50 Repair Welds in the Beltline Region 0 Volumetric 5-4 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Pressurizer Shell to Head Welds B2.11 Circumferential 2 Volumetric B2.12 Longitudinal 2 Volumetric Pressurizer Head Welds B2.21 Circumferential 0 Volumetric B2.22 Meridional 0 Volumetric Steam Generator (Primary Side) Head Welds B-B B2.31 Circumferential 0 Volumetric Pressure Retaining B2.32 Meridional 0 Volumetric Welds in Vessels Other than Reactor B2.40 Tubesheet to Head Weld 4 Volumetric Vessels Heat Exchangers (Primary Side) Head Welds B2.51 Circumferential 0 Volumetric B2.52 Meridional 0 Volumetric Heat Exchangers (Primary Side) Shell B2.60 Tubesheet-to-Head Welds 0 Volumetric B2.70 Longitudinal Welds 0 Volumetric B2.80 Tubesheet-to-Sheet Welds 0 Volumetric 5-5 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B3.10 Nozzle-to-Vessel Welds N/A Volumetric B3.20 Nozzle Inside Radius Section (Examined with B3.90) N/A Volumetric Pressurizer B3.30 Nozzle-to-Vessel Welds N/A Volumetric B-D B3.40 Nozzle Inside Radius Section N/A Volumetric/

Full Penetration N/A VT-1 Visual Welded Nozzles in Steam Generator (Primary Side)

Vessels, B3.50 Nozzle-to-Vessel Welds N/A Volumetric Inspection B3.60 Nozzle Inside Radius Section N/A Volumetric Program A N/A VT-i Visual Heat Exchangers (Primary Side)

B3.70 Nozzle-to-Vessel Welds N/A Volumetric B3.80 Nozzle Inside Radius Section N/A Volumetric 5-6 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination] Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B3.90 Nozzle-to-Vessel Welds 8 Volumetric B3.100 Nozzle Inside Radius Section (Examined with B3.90) 8 Volumetric Pressurizer B3.110 Nozzle-to-Vessel Welds 6 Volumetric B-D B3.120 Nozzle Inside Radius Section 6 Volumetric Full Penetration We (See Note 1)

Welded Steam Generator (Primary Side)

N essinB3.130 Nozzle-to-Vessel Welds 0 Volumetric B3.140 Nozzle Inside Radius Section 8 Volumetric Inspection (See Note 1)

Program B Heat Exchangers (Primary Side)

B3.150 Nozzle-to-Vessel Welds 0 Volumetric B3.160 Nozzle Inside Radius Section 0 Volumetric 5-7 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B5.10 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds B5.20 Less than NPS 4 Nozzle-to-Safe End Butt Welds B5.30 Nozzle-to-Safe End Socket Welds Pressurizer B-F B5.40 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds See Note 2 See Note 2 A-1 Pressure B5.50 Less than NPS 4 Nozzle-to-Safe End Butt Welds And Table And Table Retaining B5.60 Nozzle-to-Safe End Socket Welds 5.2-1 5.2-1 Dissimilar (For All Item (For All Item Metal Welds Steam Generator Numbers) Numbers)

In Vessel B5.70 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds Nozzles B5.80 Less than NPS 4 Nozzle-to-Safe End Butt Welds B5.90 Nozzle-to-Safe End Socket Welds Heat Exchangers B5.100 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds B5.110 Less than NPS 4 Nozzle-to-Safe End Butt Welds B5.120 Nozzle-to-Safe End Socket Welds 5-8 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B6.10 Closure Head Nuts 54 VT-1 Visual B6.20 Closure Studs, in place 54 Volumetric B6.30 Closure Studs, when removed 54 Surface or Volumetric B6.40 Threads In Flange 54 Volumetric B6.50 Closure Washers, Bushings 54 VT-1 Visual B-G-1 Pressurizer B6.60 Bolts and Studs 0 Volumetric Pressure Retaining B6.70 Flange Surface, when connection disassembled 0 VT-i Visual Bolting B6.80 Nuts, Bushings, and Washers 0 VT-1 Visual Greater Than 2 in. In Steam Generator Diameter B6.90 Bolts and Studs 0 Volumetric B6.100 Flange Surface, when connection disassembled 0 VT-1 Visual B6.1 10 Nuts, Bushings, and Washers 0 VT-1 Visual Heat Exchangers B6.120 Bolts and Studs 0 Volumetric B6.130 Flange Surface, when connection disassembled 0 VT-1 Visual B6.140 Nuts, Bushings, and Washers 0 VT-1 Visual 5-9 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category J Number Description of Components Examined Components Method(s) Number(s)

Piping B6.150 Bolts and Studs 0 Volumetric B6.160 Flange Surface, when connection disassembled 0 VT-1 Visual B6.170 Nuts, Bushings, and Washers 0 VT-1 Visual B-G-1 Pressure Retaining Pumps Bolting B6.180 Bolts and Studs 4 (96 bolts) Volumetric Greater Than B6.190 Flange Surface, when connection disassembled 4 VT-i Visual 2 in. In B6.200 Nuts, Bushings, and Washers 0 VT-1 Visual Diameter (cont'd)

Valves B6.210 Bolts and Studs 0 Volumetric B6.220 Flange Surface, when connection disassembled 0 VT-i Visual B6.230 Nuts, Bushings, and Washers 0 VT-1 Visual 5-10 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B7.10 Bolts, Studs and Nuts 4 (CET) VT-1 Visual Pressurizer B7.20 Bolts, Studs and Nuts 1 (16 bolts) VT-I Visual Steam Generator B7.30 Bolts, Studs and Nuts 8 (128 bolts) VT-i Visual Heat Exchangers B-G-2 B7.40 Bolts, Studs and Nuts 0 VT-i Visual Pressure Retaining Bolting, ii 2in and Less In B7.50 Bolts, Studs and Nuts 12 VT-1 Visual Diameter Pumps B7.60 Bolts, Studs and Nuts 4 (48 bolts) VT-i Visual Valves B7.70 Bolts, Studs and Nuts 25 (4 groups) VT-I Visual B7.80 CRD Housings Bolts, Studs and Nuts 0 VT-1 Visual (See Note 3) 5-11 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

NPS 4 or Larger B9.11 Circumferential Welds See Note 2 See Note 2 Less Than NPS 4 And Table And Table B-J B9.21 Circumferential Welds 5.2-1 5.2-1 A-1 Pressure Retaining (For All Item (For All Item Welds in Piping Branch Pipe Connection Welds Numbers) Numbers)

B9.31 NPS 4 or Larger B9.32 Less Than NPS 4 B9.40 Socket Welds Pressure Vessels B-K Welded B 10.10 Welded Attachments Ppn 1 Surface Attachments in Attac s B 10.20 Welded Attachments 13 Surface For Class 1 Vessels, Piping, Pumps Pumps,and Pumps, and Valves B 10.30 Welded Attachments Vle 0 Surface Valves B 10.40 Welded Attachments 0 Surface 5-12 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

B-L-1 Pump Casing Pumps Welds B12.10 Pump Casing Welds 4 VT-1 Visual B-L-2 Pumps Pump Casings B 12.20 Pump Casing 4 VT-3 Visual B-M-1 Valves B 12.30 Valves, Less than NPS 4, Valve Body Welds 0 Surface Valve Body Welds B 12.40 Valves Exceeding NPS 4, Valve Body Welds 0 Volumetric B-M-2 Valves Valve Body B 12.50 Valves Exceeding NPS 4, Valve Internal Surfaces 25 (4 groups) VT-3 Visual B-N-1 Reactor Vessel Interior of B13.10 Vessel Interior 1 (1 per VT-3 Visual Reactor Vessel period) 5-13 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel (BWR)

B-N-2 B 13.20 Interior Attachments Within Beltline Region N/A VT-1 Visual Welded Core B 13.30 Interior Attachments Beyond Beltline Region N/A VT-3 Visual Support Structures B 13.40 Core Support Structure N/A VT-3 Visual And Interior Attachments to Reactor Vessel (PWR)

Reactor Vessels B 13.50 Interior Attachments Within Beltline Region 0 VT-1 Visual B 13.60 Interior Attachments Beyond Beltline Region 1 VT-3 Visual B-N-3 Removable Core Reactor Vessel (PWR)

Support Structures B 13.70 Core Support Structure 1 VT-3 Visual Reactor Vessel B-O B14.10 Welds in CRD Housing 25 (10% of Volumetric Pressure Retaining peripheral or Surface Welds in housings)

Control Rod Housing 5-14 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

B-P AlP B15.10 Pressure Retaining Components Class 1 VT Visual A ll PressuretoP esr Rtiigto -Pressure Retaining B 15.70 Components Boundary WQB 16.10 Steam Generator Tubing in Straight Tube Design N/A Volumetric Steam Generator B 16.20 Steam Generator Tubing in U-Tube Design 4 Steam Volumetric Tubing Generators C-A C1.10 Shell Circumferential Welds 3 Volumetric Pressure Retaining Welds C1.20 Head Circumferential Welds 5 Volumetric In Pressure Vessels C1.30 Tubesheet-to-Shell Weld 1 Volumetric 5-15 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Nozzles in Vessels < 1A in. Nominal Thickness C2.11 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 0 Surface Weld Nozzles Without Reinforcing Plate in Vessels > 1/2 in.

C2.21 Nominal Thickness 6 Volumetric Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) And Surface C2.22 Weld 1 Volumetric C-B Nozzle Inside Radius Section Pressure Retaining Nozzle Welds C2.31 Nozzles With Reinforcing Plate in Vessels > 1 in. 0 Surface In Vessels C2.32 Nominal 0 Volumetric Thickness C2.33 Reinforcing Plate Welds to Nozzle and Vessel 0 VT-2 Visual Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle)

Welds When Inside of Vessel is Accessible Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle)

Welds When Inside of Vessel is Inaccessible 5-16 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Pressure Vessels Welded Attachments 4 Surface Welded C3.10 for Pipin2 Attachments C3.20 Welded Attachments 77 Surface Class 2 Pumps Vessels, Piping, C3.30 Welded Attachments 2 (7 sup'ts) Surface Pumps, and Vle ValvesValves C3.40 Welded Attachments 0 Surface C-D Pressure Vessels C4.10 Bolts and Studs 0 Volumetric Pressure Retaining Pipin Reting Bolting GreaterPms C4.20 Bolts and Studs 0 Volumetric than 2 Pumps than 2 C4.30 Bolts and Studs 1 (32 bolts) Volumetric In. In Diameter Vle Valves C4.40 Bolts and Studs 0 Volumetric 5-17 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Piping Welds > 3/8 in. Nominal Wall Thickness for C5.11 Piping > NPS 4 Circumferential Weld C-F-1 Piping Welds > 1/5 in. Nominal Wall Thickness for See Note 2 See Note 2 Pressure Retaining C5.21 Piping > NPS 2 And Table And Table Welds in And < NPS 4 5.2-1 5.2-1 A-1 Austenitic Circumferential Weld (For All Item (For All Item Stainless Steel Numbers) Numbers)

Or High Alloy C5.30 Socket Welds Piping Piping Branch Connections of Branch Piping > NPS 2 C5.41 Circumferential Weld 5-18 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Pipin2 Welds > 3/8 in. Nominal Wall Thickness for C5.51 Piping > NPS 4 Circumferential Weld Piping Welds > 1/5 in. Nominal Wall Thickness for See Note 2 See Note 2 C-F-2 C5.61 Piping > NPS 2 And Table And Table Pressure Retaining And < NPS 4 5.2-1 5.2-1 A-1 Welson Circumferential Weld (For All Item (For All Item Cabn rNumbers) Numbers)

Low Alloy Steel C5.70 Socket Welds Piping Piping Branch Connections of Branch Piping > NPS 2 C5.81 Circumferential Weld 5-19 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

C-G Pumps Pressure C6.10 Welded Attachments 0 Surface Retaining Welds in Valves Pumps and Valves C6.20 Valve Body Welds 21 (5 groups) Surface C-H Class 2 All Pressure C7. 10 Pressure Retaining Components Pressure VT-2 Visual Retaining Boundary Components Pressure Vessels D1.10 Welded Attachments 6 VT-1 Visual D-A Welded Pipin2 Attachments D1 .20 Welded Attachments 163 VT-1 Visual For Class 3 Vessels, Piping, Pumps Pumps D1.30 Welded Attachments 2 VT-i Visual And Valves Valves D 1.40 Welded Attachments 0 VT-1 Visual 5-20 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.1-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

D-B Class 3 All Pressure D2.10 Pressure Retaining Components Pressure VT-2 Visual Retaining Boundary Components F1.10 Class 1 Piping Supports 293 VT-3 Visual F1.20 Class 2 Piping Supports 711 VT-3 Visual F-A Supports (See Note 4) 12 T3Vsa F1.30 Class 3 Piping Supports 1021 VT-3 Visual F1.40 Supports Other Than Piping Supports 97 VT-3 Visual (Class 1, 2, 3 and MC)

Notes:

1. In accordance with 10CFR50.55a(b)(2)(xxi)(A), the 1998 Edition of ASME Section XI without Addenda must be applied for Examination Category B-D, Item Numbers B3.120 and B3.140. Although the 1999 Addenda eliminated Item Numbers B3.120 and B3.140, these Code Item Numbers are applicable and are reflected in the CPNPP-1 ISI Program Plan for the third interval.

5-21 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan

2. During the second interval CPNPP submitted letter TXX-01026 to the NRC requesting relief from ASME Section XI Code examination requirements for Class 1 and 2 piping welds (Examination Categories B-F, B-J, C-F-i, and C-F-2) inservice inspections by implementing a Risk-Informed Inservice Inspection (RI-ISI) Program. The request was approved by the NRC in a letter dated September 28, 2001 (TAC Nos. MB 1201 and MB 1202). An updated Request for Alternative is being submitted for the third interval in accordance with 10CFR50.55a(a)(3)(i).

3. In accordance with 10CFR50.55a(b)(2)(xxi)(B), the 1995 Edition of ASME Section XI must be applied for Examination Category B-G-2, Item Number B7.80. However, a VT-i visual examination is only required on bolting that is reused. Note that Comanche Peak Unit 1 does not have any Item B7.80 bolting in CRD housings.

4. The examination and testing of snubbers, including attachment hardware, shall be conducted in accordance with Technical Requirements Manual TR 15.5.31. Note that there is an overlap between the Technical Requirements Manual Snubber Program and ISI Program for the examination of snubber attachment hardware. Currently, the attachment hardware is inspected as part of the snubber testing and inspection. In addition, examinations are performed on the entire component, including attachment hardware, as part of the ISI Program.

5-22 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.2-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

R1.11 Elements Subject to Thermal Fatigue 113 Volumetric R1.12 Elements Subject to High Cycle Mechanical Fatigue 0 Visual, VT-2 R1.13 Elements Subject to Erosion Cavitation 0 Volumetric R1.14 Elements Subject to Crevice Corrosion Cracking 0 Volumetric R-A R1.15 Elements Subject to Primary Water Stress Corrosion 0 Volumetric Risk Informed Cracking (PWSCC)

Piping A-1 Examinations R1.16 Elements Subject to Intergranular or Transgranular Stress 34 Volumetric Corrosion Cracking (IGSCC, TGSCC)

R1.17 Elements Subject to Localized Microbiological Corrosion 0 Visual, VT-3

[Microbiologically-Induced Corrosion (MIC) or Pitting] on Internal Surfaces, or Volumetric R1.18 Elements Subject to Flow Accelerated Corrosion (FAC) 0 Per FAC Program 5-23 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 5.2-1 CPNPP UNIT 1 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) j Number(s)

R-A R1.19 Elements Subject to External Chloride Stress Corrosion 0 Surface Risk Informed Cracking Piping (ECSCC) A-1 Examinations (cont'd) R1.20 Elements Not Subject to a Damage Mechanism 3395 Volumetric 5-24 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 6.0 ALTERNATIVE REQUIREMENTS TO ASME SECTION XI 1998 EDITION THROUGH 2000 ADDENDA This section lists the alternative requirements to ASME Section XI, 1998 Edition through 2000 Addenda, being adopted for the Third Interval Inservice Inspection Program at CPNPP-1. The alternative requirements presented are in accordance with ASME Section XI and 10CFR50.55a, as applicable.

6.1 Adoption of Code Cases This section addresses the adoption of Code Cases during the Third Inservice Inspection Interval at CPNPP-1. Code Cases adopted for Inservice Inspection use during the Third Interval are listed in Tables 6.1-1 and 6.1-2 of this Inservice Inspection Program Plan. In all cases, the use and adoption of Code Cases will be in accordance with ASME Section XI, IWA-2440 and 10CFR50.55a. Code Cases that have already been incorporated into ASME Section XI, 1998 Edition through 2000 Addenda, will be implemented via application of the Code. The methodology for adopting Code Cases is divided into the four categories clarified below.

6.1.1 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in Regulatory Guide 1.147, Revision 16 and later, will be adopted for use during the Third Inservice Inspection Interval by listing them in Table 6.1-1 of this Inservice Inspection Program Plan.

All conditions or limitations delineated in Regulatory Guide 1.147 for a particular Code Case will apply.

TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-460 Alternative Examination None Coverage for Class 1 and Class 2 Welds N-494-4 Pipe Specific Evaluation None Procedures and Acceptance Criteria for Flaws in Piping that Exceed the Acceptance Standards 6-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-498-4 Alternative Requirements for Prior to conducting the VT-2 examination 10-Year System Hydrostatic of Class 2 and Class 3 components not Testing for Class 1, 2, and 3 required to operate during normal plant Systems operation, a 10-minute holding time is required after attaining test pressure. Prior to conducting the VT-2 examination of Class 2 and Class 3 components required to operate during normal plant operation, no holding time is required, provided the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or 10 minutes for non-insulated components.

N-513-3 Evaluation Criteria for The repair or replacement activity Temporary Acceptance of temporarily deferred under the provisions Flaws in Moderate Energy of this Code Case shall be performed Class 2 or 3 Piping during the next scheduled outage.

N-528-1 Purchase, Exchange, or The requirements of 10 CFR Part 21, Transfer of Material Between "Reporting of Defects and Nuclear Plant Sites Noncompliance" are to be applied to the nuclear plant site supplying the material as well as to the nuclear plant site receiving the material that has been purchased, exchanged, or transferred between sites.

N-532-4 Repair/Replacement Activity None Documentation Requirements and Inservice Summary Report Preparation and Submission N-533-1 Alternative Requirements for Prior to conducting the VT-2 examination VT-2 Visual Examination of of Class 2 and Class 3 components not Class 1, 2, and 3 Insulated required to operate during normal plant Pressure-Retaining Bolted operation, a 10-minute holding time is Connections required after attaining test pressure. Prior to conducting the VT-2 examination of Class 2 and Class 3 components required to operate during normal plant operation, no holding time is required, provided the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or 10 minutes for non-insulated components.

6-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-552 Alternative Methods - To achieve consistency with the Qualification for Nozzle 10CFR50.55a rule change published Inside Radius Section from September 22, 1999 (64 FR 51370),

the Outside Surface incorporating Appendix VIII, (Note: This Code Case is "Performance Demonstration for permissible for PDI use.) Ultrasonic Examination Systems," to Section XI, add the following to the specimen requirements:

"At least 50 percent of the flaws in the demonstration test set must be cracks and the maximum misorientation must be demonstrated with cracks. Flaws in nozzles with bore diameters equal to or less than 4 inches may be notches."

Add to detection criteria, "The number of false calls must not exceed three."

N-554-3 Alternative Requirements for None Reconciliation of Replacement Items and Addition of New Systems N-566-2 Corrective Action for Leakage None Identified at Bolted Connections 6-3 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-597-2 Requirements for Analytical (1) Code Case must be supplemented by the Evaluation of Pipe Wall provisions of EPRI Nuclear Safety Analysis Thinning Center Report 202L-R2, April 1999, "Recommendations for an Effective Flow Accelerated Corrosion Program," (Ref. 6),

April 1999, for developing the inspection requirements, the method of predicting the rate of wall thickness loss, and the value of the predicted remaining wall thickness. As used in NSAC-202L-R2, the term "should" is to be applied as "shall" (i.e., a requirement).

(2) Components affected by flow-accelerated corrosion to which this Code Case are applied must be repaired or replaced in accordance with the construction code of record and Owner's requirements or a later NRC-approved edition of Section Im, "Rules for Construction of Nuclear Power Plant Components" of the ASME Code (Ref. 7) prior to the value of tp reaching the allowable minimum wall thickness, tn*, as specified in -

3622.1 (a)(1) of this Code Case. Alternatively, use of the Code Case is subject to NRC review and approval per 10CFR50.55a(a)(3).

(3) For Class 1 piping not meeting the criteria of -3221, the use of evaluation methods and criteria is subject to NRC review and approval per 10CFR50.55a(a)(3).

(4) For those components that do not require immediate repair or replacement, the rate of wall thickness loss is to be used to determine a suitable inspection frequency so that repair or replacement occurs prior to reaching allowable minimum wall thickness, tm.

(5) For corrosion phenomena other than flow-accelerated corrosion, use of the Code Case is subject to NRC review and approval. Inspection plans and wall thinning rates may be difficult to justify for certain degradation mechanisms such as MIC and pitting.

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Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-613-1 Ultrasonic Examination of None Penetration Nozzles in Vessels, Examination Category B-D, Item Nos.

B3.10 and B3.90, Reactor Nozzle-to-Vessel Welds, Figs.

IWB-2500-7(a), (b), and (c),

N-616 Alternative Requirements for (1) Insulation must be removed for VT-2 VT-2 Visual Examination of examination during the system pressure Classes 1, 2, and 3 Insulated test for any 17-4 PH stainless steel or 410 Pressure Retaining Bolted stainless steel stud or bolt aged at a Connections temperature below 1100'F or with hardness above R, 30.

(2) For A-286 stainless steel studs or bolts, the preload must be verified to be below 100 ksi or the thermal insulation must be removed and the joint visually examined.

(3) Prior to conducting the VT-2 examination of Class 2 and Class 3 components not required to operate during normal plant operation, a 10-minute holding time is required after attaining test pressure. Prior to conducting the VT-2 examination of Class 2 and Class 3 components required to operate during normal plant operation, no holding time is required, provided the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or 10 minutes for non-insulated components.

N-624 Successive Inspections None N-639 Alternative Calibration Block Chemical ranges of the calibration block Material may vary from the materials specification if (1) it is within the chemical range of the component specification to be inspected, and (2) the phase and grain shape are maintained in the same ranges produced by the thermal process required by the I material specification.

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Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-647 Alternative to Augmented A VT-1 examination is to be used in lieu Examination Requirements of of the "detailed visual examination.""

IWE-2500 [Note: Draft Regulatory Guide DG-1070, "Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants", is being developed to provide acceptable guidelines for sampling criteria.]

N-648-1 Alternative Requirements for In place of a UT examination, licensees Inner Radius Examination of may perform a visual examination with Class 1 Reactor Vessel enhanced magnification that has a Nozzles resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria of Table IWB-3512-1 with limiting assumptions on the flaw aspect ratio. The provisions of Table IWB-2500-1, Examination Category B-D, continue to apply except that, in place of examination volumes, the surfaces to be examined are the external surfaces shown in the figures applicable to this table (the external surface is from point M to point N in the figure).

N-649 Alternative Requirements for None IWE-5240 Visual Examination N-652-1 Alternative Requirements to None Categories B-G-1, B-G-2, and C-D Bolting Examination Methods and Selection Criteria N-661-1 Alternative Requirements for (1) If the cause of the degradation has not Wall Thickness Restoration of been determined, the repair is only Class 2 and Class 3 Carbon acceptable until the next refueling outage.

Steel Piping for Raw Water (2) When through-wall repairs are made by Service welding on surfaces that are wet or exposed to water, the weld overlay repair is only acceptable until the next refueling I outage.

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Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-683 Method for Determining None Maximum Allowable False Calls When Performing Single-Sided Access Performance Demonstration in Accordance with Appendix VIII, Supplements 4 and 6 (Note: This Code Case is permissible for PDI use.)

N-685 Lighting Requirements for None Surface Examination N-686-1 Alternative Requirements for None Visual Examinations, VT-1, VT-2, and VT-3 N-695 Qualification Requirements None for Dissimilar Metal Piping Welds (Note: This Code Case is permissible for PDI use.)

N-696 Qualification Requirements None for Appendix VIII Piping Examinations Conducted from the Inside Surface (Note: This Code Case is permissible for PDI use.)

N-700 Alternative Rules for None Selection of Classes 1, 2, and 3 Vessel Welded Attachments for Examination N-705 Evaluation Criteria for None Temporary Acceptance of Degradation in Moderate Energy Class 2 or 3 Vessels N-706-1 Alternative Examination None Requirements of Table IWB-2500-1 and Table IWC-2500-1 for PWR Stainless Steel Residual and Regenerative Heat Exchangers 6-7 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan TABLE 6.1-1 ADOPTED CODE CASES CODE E TITLE CONDITIONS OF REGULATORY CASE GUIDE 1.147 N-722 Additional Examinations for Conditions are stated in PWR Pressure Retaining 10CFR50.55a(g)(6)(ii)(E) which mandates Welds in Class 1 Components the use of Code Case N-722.

Fabricated With Alloy 600/82/182 Materials N-729-1 Alternative Examination Conditions are stated in Requirements for PWR 10CFR50.55a(g)(6)(ii)(D) which mandates Reactor Vessel Upper Heads the use of Code Case N-729-1.

With Nozzles Having Pressure-Retaining Partial-Penetration Welds N-731 Alternative Class 1 System None Leakage Test Pressure Requirements N-739 Alternative Qualification None Requirements for Personnel Performing Class CC Concrete and Post-tensioning System Visual Examinations N-753 Vision Tests None 6-8 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan 6.1.2 Adoption of Code Cases Not Listed for Generic Use in Regulatory Guide 1.147 or Listed as Unacceptable in Regulatory Guide 1.193 Adoption of Code Cases that have been approved by the Board of Nuclear Codes and Standards, but that have not been listed for generic use in Regulatory Guide 1.147 or have been listed as unacceptable in Regulatory Guide 1.193, may be submitted in the form of a Request for Alternative in accordance with 10CFR50.55a(a)(3). Once approved by the NRC, these Requests for Alternatives will be available for use at CPNPP- 1.

Table 6.1-2 lists those Code Cases that are not listed for generic use in Regulatory Guide 1.147 or are listed as unacceptable in Regulatory Guide 1.193.

In addition to the requirements stated in the Code Cases, criteria may be stipulated in the Request for Alternative or may be agreed upon through subsequent correspondences with the NRC. CPNPP-1 will implement these additional requirements as applicable.

TABLE 6.1-2 CODE CASES SUBMITTED THROUGH REQUESTS FOR ALTERNATIVES CODE CASE TITLE REQUEST NUMBER NUMBER N-578-1 Risk-Informed Requirements for Class 1, 2, and 3 A-1 Piping 6.1.3 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 But Subsequently Annulled by ASME Section XI Under certain circumstances, it may be necessary to adopt a Code Case that has been listed for generic use in Regulatory Guide 1.147, but subsequently annulled by ASME Section XI. Therefore, CPNPP-1 endorses all revisions of Regulatory Guide 1.147 from Revision 16 up to and including the most recent revision.

Endorsement of these revisions of Regulatory Guide 1.147 does not commit CPNPP-1 to all Code Cases listed therein, but rather allows for selection of a previously accepted Code Case. The purpose of this endorsement is to identify all Code Cases that could potentially be incorporated into this Inservice Inspection Plan in accordance with IWA-2441.

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Comanche Peak Unit 1 Third Interval ISI Program Plan 6.1.4 Adoption of Code Cases Issued Subsequent to Filing this Inservice Inspection Plan Code Cases issued by ASME Section XI subsequent to filing this Inservice Inspection Plan will be proposed for use in amendments to this Inservice Inspection Program Plan in accordance with ASME Section XI, IWA-2441(d).

6.2 Use of Subsequent Editions of ASME Section XI In accordance with 10CFR50.55a(g)(3)(v), components, including supports, may meet the requirements set forth in subsequent editions of Codes and Addenda, or portions thereof, which are incorporated by reference in 10CFR50.55a(b), subject to the limitations and modifications listed therein. In addition, in accordance with 10CFR50.55a(g)(4)(iv), the use of these subsequent editions of Codes and Addenda are subject to Commission approval and portions of these editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

This Section of the Inservice Inspection Program Plan provides for the documentation of alternative requirements from approved subsequent Code editions that may be adopted during the Third Inservice Inspection Interval. Should this occur, this Inservice Inspection Program Plan will be amended for adoption of subsequent Code rules at that time.

6.3 10CFR50.55a Modifications, Limitations and Augmented Examination Requirements In certain instances, the criteria of ASME Section XI, 1998 Edition through 2000 Addenda is modified by limitations, modification or augmented examination requirements that are mandated by 10CFR50.55a. These limitations, modifications and augmented examination requirements are addressed in Section 2.4 of this Inservice Inspection Program Plan.

6.4 Inservice Inspection Requests for Alternatives and Relief Requests 6.4.1 Alternatives to examinations required by the Code may be authorized by NRC, as allowed by 10CFR50.55a(a)(3), provided that design, fabrication, installation, testing, and inspection performed in compliance with Codes and Section XI requirements would result in hardship without a compensating increase in the level of quality and safety, or provided that the proposed alternative examination will assure an acceptable level of quality and safety. Specific exceptions shall be documented in the form of a Request for Alternative and included in Section 8.0 of this Inservice Inspection Program Plan.

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Comanche Peak Unit 1 Third Interval ISI Program Plan 6.4.2 Section 8.0 of this Inspection Plan also includes Relief Requests written in accordance with 10CFR50.55a(g)(5) when specific ASME Section XI requirements for inservice inspection are considered impractical. If examination requirements are determined to be impractical during the course of the interval, relief requests shall be submitted in accordance with 10CFR50.55a(g)(5).

6.4.3 Relief Requests for limited coverage examinations shall be submitted in accordance with 10CFR50.55a(g)(5)(iv) throughout the interval, as limitations are identified. Due to ongoing changes in nondestructive examination procedures, techniques and requirements, CPNPP-1 considers that submitting Relief Requests for incomplete examinations when they are evaluated will provide a more accurate representation of the limitations.

6.4.4 For this Inspection Plan, the term "Request for Alternative" applies to those requests that are being submitted per 10CFR50.55a(a)(3)(i) or 10CFR50.55a(a)(3)(ii). These requests propose alternatives that provide an acceptable level of quality and safety, or address requirements that present a hardship without a compensating increase in the level of quality and safety. The term "Relief Request" will be reserved for those requests submitted per 10CFR50.55a(g)(5), for review per 10CFR50.55a(g)(6)(i). These requests address those examinations that are impractical to implement due to factors such as physical restrictions.

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Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 7.0 REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX It is impractical within the limitations of the CPNPP plant design, geometry and accessibility for CPNPP to meet certain requirements of Articles IWA, IWB, IWC, IWD and IWF of the Code.

Compliance with these requirements would result in hardships or unusual difficulties without a compensating increase in the level of plant quality or safety. Therefore, pursuant to 10CFR5 0.5 5a(g)(5)(iii), the relief requested from the Inservice Inspection requirements of 10CFR50.55a(g)(4)(I) is discussed in detail in this appendix. Relief is requested for the third 120 month interval of the CPNPP inservice inspection program.

Table 7.0-1 provides a summary listing and revision status of all Requests for Alternatives and Relief Requests related to the Third Interval Inservice Inspection Program at CPNPP-1. The actual Requests for Alternatives and Relief Requests are provided in Section 8.0 of this Inservice Inspection Program Plan.

TABLE 7.0-1 INSERVICE INSPECTION REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX REQUEST REV. SUBJECT SUBMITTAL STATUS NO. DATE/LETTER A-1 0 Continuation of Risk-Informed TXX-11038, To Be Submitted Inservice Inspection CP-201100356 Application on Class l and 2 Piping Welds I dated 8/02/11 I

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Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 8.0 REQUEST FOR ALTERNATIVES AND RELIEF REQUESTS This section of the Third Interval Inservice Inspection Program Plan contains the Requests for Alternatives and Relief Requests submitted for the third interval at CPNPP- 1.

10CFR50.55a Request Number A-1 Proposed Alternative in Accordance with 10CFR50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-ASME Code Components Affected Class 1 and Class 2 Piping Welds Applicable Code and Edition The CPNPP Unit 1 ISI program is based on the 1998 Edition of ASME Section XI with the 2000 Addenda.

Applicable Code Requirement

Table IWB-2500-1, Examination Category B-F and Category B-J Table IWC-2500-1, Examination Category C-F-1 and Category C-F-2 Reason For Request The continued use of a risk-informed process as an alternative for the selection of Class 1 and Class 2 Piping Welds for examination is requested.

Proposed Alternative and Basis for Use As an alternative to the Code Requirement, a Risk-Informed process will continue to be used for selection of Class 1 and Class 2 Piping Welds for examination.

The Unit 1 ISI program for the examination of Class 1 and Class 2 piping welds is currently in accordance with a risk-informed process submitted February 15, 2001. NRC approved this request on September 28, 2001 (TAC Nos. MB1201 and MB1202). In the original submittal, TXU Electric committed to review and adjust the risk ranking of piping segments as a minimum on an ASME period basis. The first period of implementation of the RI-ISI program was the first 8-1 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan period of Interval 2, which ended July, 2003. To satisfy the periodic review requirements, an evaluation and update was performed at the end of each period in accordance with the Nuclear Energy Institute document 04-05, "Living Program Guidance To Maintain Risk-Informed Inservice Inspection Programs For Nuclear Plant Piping Systems", published April, 2004. The updated program resulting from these reviews is the subject of this proposed alternative.

In accordance with the guidance provided by NEI 04-05, a table is provided as Attachment 1 identifying the number of welds added to and deleted from the originally approved RI-ISI program. The changes to the original program are attributable to several specific actions:

1) During the first period of the second ISI interval, the ISI Program was based on the 1986 Edition of ASME Section XI. Beginning with the second period of the second ISI interval through the first period of the third ISI interval, the ISI Program is in accordance with the 1998 Edition through 2000 Addenda of ASME Section XI. One of the changes in the new edition and addenda of the Code is that the exemption size for Class 2 auxiliary feedwater piping decreased from 4" NPS to 1 1/22" NPS. As a result, the 4" NPS Class 2 auxiliary feedwater lines from the outboard isolation valves to where they connect to the four main feedwater lines were added to the ISI Program and consequently added to the RI-ISI Program.

2) In PRA Revision 3B dated May 2005, consequence segments 1-SI01, 1-ACC03A, 1-ACC03B, 1-RHR08A, 1-FW-03A, 1-FW-03B, 1-FW-03C, and 1-FW-03D changed consequence rank from Medium to High. As a result of this change, fourteen segments changed from a risk rank of Low to a risk rank of Medium.

3) In PRA Revision 3C dated June 2007 consequence segments 1-CT-09A, 1-CT-09B, 1-CVCS06, 1-CVCS07, and 1CVCS08 changed consequence rank from Medium to High.

Consequence segment 1CVCS16 changed consequence rank from Medium to Low.

Consequence segments 1-RHR03A, 1-RHR08A, and 1-RHR-08B changed consequence rank from High to Medium. Consequence segments 1-SI01 and 1-SI02 changed consequence rank from High to Low. As a result of these changes, eighteen Risk Segments changed from a risk rank of Low to a risk rank of Medium, eleven Risk Segments changed from a risk rank of Medium to a risk rank of Low, and one Risk Segment changed from Risk Category 6a to Risk Category 7a, but remained risk rank Low.

4) In PRA Revision 3D dated June 2009 consequence segments 1-CT-03A, 1-CT-03B, 1-CT-04A, 1-CT-04B, 1-CT-05A, and 1-CT-05B, changed consequence rank from Medium to High due to the testing frequency changing from quarterly to once every 18 months.

Consequence segments 1-CT07 and 1-CVCS16 changed consequence rank from Low to Medium. Consequence segments 1-CT09A, 1-CT09B, and 1-RHR-03B changed consequence rank from High to Medium. Consequence segments 1-CVCS06, 1-CVCS07 and 1-CVCS08 changed consequence rank from High to Low. As a result of these changes, twelve Risk Segments changed from a risk rank of Low to a risk rank of Medium, twenty-one Risk Segments changed from a risk rank of Medium to a risk rank of Low, and six Risk Segments changed from Risk Category 7a to Risk Category 6a, but 8-2 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan remained risk rank Low. Maximum CCDP used as the Upper Bound in the Risk Impact Analysis changed to 7.48ER-03. Max CLERP changed to 9.55E-04

5) In Period 2, replacement of the steam generators and some MOVs resulted in numerous welds being deleted, added, or re-designated.

A new Risk Impact Analysis was performed, and the revised program continues to represent a risk reduction when compared to the last deterministic Section XI inspection program. The original program represented a reduction of 9.73E-09 in regards to CDF and 3.91E-09 in regards to LERF, while the revised program represents a reduction of 8.3E-09 in regards to CDF and 1.06E-09 in regards to LERF.

The Risk-Informed process continues to provide an adequate level of quality and safety for selection of the Class 1 and Class 2 Piping Welds for examination. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i) it is requested that the proposed alternative be authorized.

PRA Ouality See attached "Summary Statement of Comanche Peak Nuclear Power Plant (CPNPP) PRA Model Capability for Use in Risk-Informed Inservice Inspection Program Licensing Actions".

Duration of Proposed Alternative The alternative will be used for CPNPP Unit 1 until the end of that unit's third ten-year ISI program inspection interval, subject to the review and update guidance of NEI 04-05. The third inspection interval is currently scheduled to end August, 2020.

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Comanche Peak Unit 1 Third Interval ISI Program Plan CPNPP Unit 1 - Inspection Location Selection Comparison Between Original Approved and Updated RI-ISI Programs by Risk Category WeldWel Original Interval 3 Update System~l) Risk Consequence Failure Potential 2 Other(2)

Category Rank Rank DMs Rank Category Weld RI-ISI Other Count RI-ISI Count Count RCS 2 High High TASCS, Medium B-J 7 2 7 3 RCS 2 High High TASCS Medium B-J 13 4 _____ 13 4 RCS 2 High High T(S Medium B-F 1 0 1 1 (PWSCC)

RCS 2 High High TT Medium B-J 11 2 11 2 RCS 4(2) Medium High None Low B-F 19 14 20 8 (High) (PWSCC)

RCS 4 Medium High None Low B-J 205 29 223 26 RCS 5 Medium Medium TASCS Medium B-I 20 2 20 2 RCS 5 Medium Medium TT Medium B-I 45 5 44 5 RCS 5 Medium Medium "I Medium B-1 45 5 1 1 (PWSCC)

RCS 6 Low Medium None Low B-J 61 0 61 0 RCS 7 Low Low None Low B-I 15 0 15 0 B-I 47 0 47 0 Low Medium None Low CVCS 6 C-F-1 231 0 18 0 CVCS 6 Low Low TI' Medium B-I 8 0 8 0 B-I 30 0 30 0 7 Low Low None Low CVCS C-F-1 0 0 235 0 B-1 79 7 79 7 SIS 4 Medium High

_____C-F-I None Low 98 11 136 18 SIS 5 Medium Medium IGSCC Medium B-I 12 2 12 2 B-I 95 0 95 0 6 Low Medium None Low SIS C-F-I 596 0 425 0 SIS 6 Low Low IGSCC Medium B-I 22 0 22 0 B-I 119 0 119 0 Low Low None Low SIS 7 C-F- 1 106 0 340 0 8-4 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan CPNPP Unit 1 - Inspection Location Selection Comparison Between Original Approved and Updated RI-ISI Programs by Risk Category Risk Failure Potential Original Interval 3 Update System~') Consequence Code Weld Category Rank Rank DMs Rank Category Weld Count RI-ISI Other(2 ) Weld Count RI-ISI Other(2 )

B-J 12 2 12 2 Medium High None Low RHRS 4 C-F- 1 246 24 120 12 RHRS 6 Low Medium None Low C-F- 1 8 0 134 0 CSS 4 Medium High None Low C-F-1 10 1 176 18 CSS 6 Low Medium None Low C-F-I 178 0 125 0 CSS 7 Low Low None Low C-F- 1 234 0 357 0 4(l) Medium High None Low C-1-2 0 0 100 12 FWS___(1) (High) (FAC) (High)

S(3) Medium Medium TASCS, Medium C-F-2 8 1 8 (High) (FAC) (High)

Low None Low FWS 6_(3) (High) Medium (FAC) (High) C-1-2 435 0 277 0 MSS 6 Low Medium None Low C-F-2 165 0 170 0 0 0 38 (38 High None Low CF2 AFWMedium

_W _ _4(1) _ (High) (FAC) (High) C-F2_00J8 9 3181 111 3542 133 Notes change from origim 11: 22 I Systems were described in Table 3.1-2 of the original submittal, with the exception of AFW - Auxiliary Feedwater. This ASME Code Class 2 system consists of 4 segments with 81 elements.

2 The column labeled "Other" is generally used to identify augmented inspection program locations that are credited beyond those locations selected per the RI-ISI process, as addressed in Section 3.6.5 of EPRI TR-1 12657. This option was not applicable for the CPNPP RI-ISI application. The "Other" column has been retained in this table solely for uniformity purposes with other RI-ISI application template submittals.

3 Due to a change in ASME Section XI Code criteria, 4" NPS Class 2 auxiliary feedwater piping was added to the ISI Program, and therefore the RI-ISI Program, for the first time during the second RI- ISI period. As such, there were no welds associated with this piping during the original RI-ISI application.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Summary Statement of Comanche Peak Nuclear Power Plant (CPNPP) PRA Model Capability for Use in Risk-Informed Inservice Inspection Program Licensing Actions Introduction Comanche Peak Nuclear Power Plant (CPNPP) employs a multi-faceted approach to establishing and maintaining the technical adequacy and plant fidelity of the PRA models for the operating CPNPP units. This approach includes both a proceduralized PRA maintenance and update process, and the use of self-assessments and independent peer reviews. The following information describes this approach as it applies to the CPNPP PRA.

PRA Maintenance and Update The CPNPP risk management process ensures that the applicable PRA model remains an accurate reflection of the as-built and as-operated plants. This process is defined in the CPNPP risk management program, which consists of a governing procedure ECE-2.15 "Risk and Reliability Functions" and subordinate implementation documents. CPNPP desktop instruction R&R-DI-009, "Maintenance and Update of PRA Models" delineates the responsibilities and guidelines for updating the full power internal events PRA models at CPNPP. The overall CPNPP risk management program, including R&R-DI-009, defines the process for implementing regularly scheduled and interim PRA model updates, for tracking issues identified as potentially affecting the PRA models (e.g., due to changes in the plant, errors or limitations identified in the model, industry operational experience), and for controlling the model and associated computer files. To ensure that the current PRA model remains an accurate reflection of the as-built, as-operated plant, the following activities are routinely performed:

" Design changes and procedure changes are reviewed for their impact on the PRA model.

" Impacts to the design basis documents (or calculations when specifically cited by the PRA) are reviewed for their potential impact on the PRA model.

• Maintenance unavailabilities are captured.

• Plant specific initiating event frequencies, failure rates, and maintenance unavailabilities are updated approximately every 5-7 years.

In addition to these activities, CPNPP risk management procedures/desktop instructions provide the guidance for particular risk management and PRA quality and maintenance activities. This guidance includes:

• Documentation of the PRA model, PRA products, and bases documents.

• The approach for controlling electronic storage of Risk Management (RM) products including PRA update information, PRA models, and PRA applications.

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Comanche Peak Unit 1 Third Interval ISI Program Plan

" Guidelines for updating the full power, internal events PRA models for CPNPP.

" Guidance for use of quantitative and qualitative risk models in support of the On-Line Work Control Process Program for risk evaluations for maintenance tasks (corrective maintenance, preventive maintenance, minor maintenance, surveillance tests and modifications) on systems, structures, and components (SSCs) within the scope of the Maintenance Rule [10CFR50.65 (a)(4)].

In accordance with this guidance, regularly scheduled PRA model updates nominally occur on an approximately 5-7 year cycle; longer intervals may be justified if it can be shown that the PRA continues to adequately represent the as-built, as-operated plant. CPNPP performed a regularly scheduled update to the Rev. 3 CPNPP PRA model in 2004 and CPNPP is currently using the Rev. 3D of the PRA model, from 2009, that has incorporated minor changes since the Rev. 3 update.

PRA Self Assessment and Peer Review Several assessments of technical capability have been made, and continue to be planned, for the CPNPP PRA models. These assessments are as follows:

An independent PRA peer review was conducted under the auspices of the Westinghouse Owners Group (WOG) in 2002, following the Industry PRA Peer Review process [1].

In 2004 a self assessment of the Systems Analysis (SY) element of the PRA model was done against the ASME PRA Standard [2] prior to the 2004 update. No gaps were identified relative to technical adequacy.

In 2004 during the update process a self assessment was performed with two industry peer reviewers using the WOG peer review process. This review included an assessment of the PRA model maintenance and update process and the loss of offsite power calculation and convolution data.. Results confirmed the technical adequacy of the CPNPP PRA model, with certain changes to the model that were incorporated during the update, and that the model would be maintained in a manner that would support risk informed applications.

Following the Rev. 3 PRA model update a focused peer review was completed by two outside consultants utilizing the quantification elements of the ASME PRA standard

[2A]. The review focused on the RCP Seal LOCA model, the thermal hydraulic analyses associated with the RCP Seal LOCA scenarios, Loss of offsite power model changes, and the quantification process. No category A or B Facts & Observations (F&Os) were identified in the review and all other F&O items were resolved in a subsequent update.

During April 2006, the CPNPP PRA model results were evaluated in the WOG PRA cross-8-7 Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan comparisons study performed in support of implementation of the mitigating systems performance indicator (MSPI) process. Results of this cross-comparison are presented in WCAP-16464 [4]. Noted in this document was the fact that, after allowing for plant-specific features, there are no MSPI cross-comparison outliers for CPNPP.

In 2009, a gap analysis was performed against the available versions of the ASME PRA Standard [6] and Regulatory Guide 1.200, Rev. 1 [3]. The assessment reviewed the extent to which the gaps existed and a PRA model update is in progress and will address the gaps that were identified.

A summary of the disposition of the 2002 Industry Peer Review facts and observations (F&Os) for the CPNPP models was documented as part of the statement of PRA capability in the MSPI Bases Document [5]. As noted in that document all significance level A and B F&Os were addressed and closed out with the completion of the current model of record.

A gap analysis for the Rev. 3C CPNPP PRA models was completed in 2009 and was documented in R&R-PN-202 [8]. The gap analysis was performed against the available version of the ASME PRA Standard [6] and Regulatory Guide 1.200, Rev. 1 [3]. This gap analysis defined a number supporting requirements from the ASME Standard [6] for which potential gaps to the ASME PRA Standard were identified. The model of record Rev. 3D is the current model of record and only includes minor changes associated with the Unit 1 steam generator replacement and the Unit 1 and 2 power uprates since the Rev. 3C model and therefore the gap assessment remains valid. Additionally, EPRI TR-1018427 [7] defines the specific capability category requirements necessary for the PRA model to be used in the RI-ISI program. Therefore, the attached Appendix 1 "Status of Open Gaps to Capability Category Identified by EPRI TR-1018427" only lists the gaps that are defined as nonconforming to the RI-ISI program, by the EPRI TR. The appendix also includes a description of the gap's potential impact on the RI-ISI program and a discussion, if any necessary, of the sensitivity study performed.

General Conclusion Regarding PRA Capability The CPNPP PRA maintenance and update processes and technical capability evaluations described above provide a robust basis for concluding that the PRA is suitable for use in risk-informed licensing actions. As specific risk-informed PRA applications are performed, remaining gaps to specific requirements in the PRA standard will be reviewed to determine which, if any, would merit application-specific sensitivity studies in the presentation of the application results. The specific gaps that could impact the RI-ISI are discussed in the next section and are summarized in Appendix 1.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Assessment of PRA Capability Needed for Risk-Informed Inservice Inspection In the risk-informed in-service inspection (RI-ISI) program at CPNPP, the EPRI RI-ISI methodology [9] is used to define alternative in-service inspection requirements. Plant-specific PRA-derived risk significance information is used during the RI-ISI plan development to support the consequence assessment, risk ranking and delta risk evaluation steps.

The importance of PRA consequence results, and therefore the necessary scope of PRA technical capability, is tempered by two processes in the EPRI methodology.

First, PRA consequence results are binned into one of three conditional core damage probability (CCDP) and conditional large early release probability (CLERP) ranges before any welds are chosen for RI-ISI inspection. Table 2 illustrates the binning process.

I Table 2 - Consequence Results Binning Groups Consequence Category CCDP Range CLERP Range High CCDP > 1E-4 CLERP > 1E-5 Medium 1E-6 < CCDP < 1E-4 1E-7 < CLERP < lE-5 Low CCDP < 1E-6 CLERP < 1E-7 The risk importance of a weld is therefore not tied directly to a specific PRA result.

Instead, it depends only on the range in which the PRA result falls. The wide binning provided in the methodology generally reduces the significance of specific PRA results.

Secondly, the influence of specific PRA consequence results is further reduced by the joint consideration of the weld failure potential via a non-PRA-dependent damage mechanism assessment. The results of the consequence assessment and the damage mechanism assessment are combined to determine the risk ranking of each pipe segment (and ultimately each element) according to the EPRI Risk Matrix. The Risk Matrix, which equally takes both assessments into consideration, is reproduced below.

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Comanche Peak Unit 1 Third Interval ISI Program Plan POTENTIAL FOR CONSEQUENCES OF PIPE RUP TURE IMPACTS ON CONDITIONAL CORE DAMAGE PROBABILITY PIPE RUPTURE AND LARGE EARLY RELEASE PROBABILFTY PER DEGRADATION MECHANISM SCREENING CRITERIA INONE LOw. MEDIUM HIGH HIGH LOW NMF DI][1 lG Ii11HI FL'ow ACCELERATED CORROSION Category 7 Category,_,

r! 5 Catgori, CAlgory I MEDIUM LOW LOW MEDIU N1 11GH OTHERDEGRADATION MECHANISMS Category7 Category 6 :algorN.5 C a,-tegor--

LOW LOW LOW LOW .IMED I iM- I NO DE(GADATION MECHANISMS Category 7 Category7 Category6 @atego) l These facets of the methodology reduce the influence of specific PRA results on the final list of candidate welds.

The limited use of specific PRA results in the RI-ISI process is also reflected in the risk-informed license application guidance provided in Regulatory Guide 1.174 [ 10]. Section 2.2.6 of Regulatory Guide 1.174 provides the following insight into PRA capability requirements for this type of application:

There are, however, some applications that, because of the nature of the proposed change, have a limited impact on risk, and this is reflected in the impact on the elements of the risk model.

An example is risk-informed inservice inspection (RI-ISI). In this application, risk significance was used as one criterion for selecting pipe segments to be periodically examined for cracking. During the staff review it became clear that a high level of emphasis on PRA technical acceptability was not necessary. Therefore, the staff review of plant-specific RI-ISI typically will include only a limited scope review of PRA technical acceptability.

Further, Table 1.3-1 of the ASME PRA Standard' [6] identifies the bases for PRA capability categories. The bases for Capability Category I for scope and level of detail attributes of the PRA states:

Resolution and specificity sufficient to identify the relative importance of the contributors at the system or train level including associatedhuman actions.

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Comanche Peak Unit 1 Third Interval ISI Program Plan Based on the above, in general, Capability Category I should be sufficient for PRA quality for a RI-ISI application.

However, based on the EPRI TR-1018427 [7] a more specific list of capability category requirements has been developed for the RI-ISI program defining which of the ASME PRA Standard [6] supporting requirements should fall under categories I, II, or Ill. Reviewing the list of supporting requirements for the RI-ISI program listed in the TR it is noted that the internal flooding requirements are included, but at CPNPP the RI-ISI was developed using insights from the plant's deterministic flooding analysis in lieu of the PRA internal flooding model and its results. Therefore the internal flooding technical supporting requirements are not applicable to the PRA analysis for the CPNPP RI-ISI program.

Reviewing the CPNPP GAP Analysis [8] against the EPRI TR-1018427 [7], there are four potential gaps to the technical supporting requirements were identified in the PRA model; the gaps are listed in Appendix 1 of this letter. Two of the gaps, DA-CiI and LE-Flb, were determined to be caused by conservative data/analysis methods that have not been updated recently. As these gaps were determined to be conservative they have no negative impact to the RI-ISI program. The other two gaps, SY-A22 and DA-C15, are related to the use of hardware fault recovery and were subject to a sensitivity analysis to assess their impact to the RI-ISI program. The sensitivity study removed the recoveries for hardware failures and the results of the study showed no consequence segments increased in PRA risk ranking. Therefore, because there were no consequences risk ranking category increases seen in the sensitivity results, there is no impact from the two technical supporting requirement gaps, SY-A22 and DA-C15, to the RI-ISI program.

There were several other documentation issues that were identified in the gap analysis there were re-verified to be only documentation issues and not a gap for a technical supporting requirement. These are not included in Appendix 1 as they are documentation issues only and have no impact to the PRA results for the RI-ISI program.

The EPRI methodology further provides an alternate means to estimate the pipe rupture consequence, namely lookup tables. Although these lookup tables were not used, the impact of the loss of systems or trains is done in a generic (not plant-specific) fashion for this alternative method. This allowable alternative underscores the relatively low dependence of the process on specific PRA capabilities.

In addition to the above, it is noted that welds are not eliminated from the ISI program solely on the basis of risk information. The risk significance of a weld may fall from Medium Risk Ranking to Low Risk Ranking, resulting in it not being a candidate for inspection. However, it remains in the program, and if, in the future, the assessment of its ranking changes (either by damage mechanism or PRA risk) then it can again become a candidate for inspection. If a weld is determined, outside the PRA evaluation, to be susceptible to flow-accelerated corrosion (FAC), inter-granular stress corrosion cracking (IGSCC) or microbiological induced cracking 8-11 i Revision 0

Comanche Peak Unit 1 Third Interval ISI Program Plan (MIC) in the absence of any other damage mechanism, then it moves into an "augmented" program where it is monitored for those special damage mechanisms. That occurs regardless of what the Risk Ranking of the weld is determined to be.

Conclusion Regarding PRA Capabilitv for Risk-Informed ISI The CPNPP PRA model continues to be suitable for use in the RI-ISI application. This conclusion is based on:

• the PRA maintenance and update processes in place,

• the PRA technical capability evaluations that have been performed and are being planned, and

" the RI-ISI process considerations, as noted above, that demonstrate the relatively limited reliance of the process on PRA capability.

Table A-1 of Regulatory Guide 1.200 identifies the NRC staff position as "No objection" to Section 1.3 of the ASME PRA Standard, which contains Table 1.3-1.

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Comanche Peak Unit 1 Third Interval ISI Program Plan References

1. NEI-00-02, "Probabilistic Risk Assessment (PRA) Peer Review Process Guidance," Rev.

A3.

2. American Society of Mechanical Engineers, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications, ASME Ra-Sa-2002, New York, New York, April 2002.

2A American Society of Mechanical Engineers, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications, ASME Ra-Sa-2003, New York, New York, December 2003.

3. U.S. Nuclear Regulatory Commission, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Regulatory Guide 1.200, Rev. 1, January 2007.

4. WCAP-16464-NP, "Westinghouse Owner's Group Mitigating Systems Performance Index Cross Comparison," Revision 0, August 2005.

5. Comanche Peak Nuclear Power Plant, Reactor Oversight Program (ROP) Mitigating Systems Performance Index (MSPI) Bases Document, R&R-PN-112, Rev. 3, December 2008.

6. American Society of Mechanical Engineers, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications, ASME RA-Sb-2005, New York, New York, December 2005.

7. Electric Power Research Institute, Nondestructive Evaluation: Probabilistic Risk Assessment Technical Adequacy Guidance for Risk-Informed In-Service Inspection Programs, EPRI TR-1018427, Palo Alto, CA 2008.

8. Comanche Peak Nuclear Power Plant, R.G. 1.200 Compliance, R&R-PN-202, May 2009.

9. Revised Risk-Informed Inservice Inspection Evaluation Procedure, EPRI TR-1 12657, Revision B-A, December 1999.

10. U.S. Nuclear Regulatory Commission, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Regulatory Guide 1.174, Revision 1, November 2002.

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Comanche Peak Unit 1 Third Interval ISI Program Plan SECTION 9.0 SYSTEM PRESSURE TESTING 9.1 Purpose This section of the Inservice Inspection Program Plan identifies pressure test requirements for ASME Code Class 1, 2, and 3 pressure retaining components at CPNPP-1 as defined in Article IWA-5000 of the Code.

This section defines pressure test boundaries, establishes test frequencies, required tests and test pressures and temperature as required by the Code.

The system pressure test for repair/replacement activities shall be in accordance with Subarticle IWA-5120 of the Code.

9.2 Pressure Test Description Pressure retaining components within each system boundary are subject to the following applicable system pressure tests as referenced in the ASME Section XI, Table IWA-5210-1, under which conditions a VT-2 visual examination is performed in accordance with IWA-5240 to detect leakage.

9.2.1 IWA-5211(a)

A system leakage test is conducted while the system is in operation, during a system operability test, or while system is at rest conditions using an external pressurization source; 9.2.2 IWA-5211(b)

A system hydrostatic test conducted during a plant shutdown at an elevated test pressure as specified in IWB-5230, IWC-5230, or IWD-5222; and 9.2.3 IWA-5211(c)

A system pneumatic test conducted in lieu of either of the above system pressure tests for Class 2 or 3 components as permitted by IWC-5000 or IWD-5000. The requirements for system leakage and hydrostatic tests are applicable to pneumatic tests.

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Comanche Peak Unit 1 Third Interval ISI Program Plan 9.3 Pressure Test Requirements A system pressure test and accompanying VT -2 examination shall be performed in accordance with Articles 1WA-5000, 1WB-5000, IWC-5000 and IWD-5000 and the related tables, Tables IWA-5210-1, IWB-2500-1, IWC-2500-1 and IWD-2500-1 of the Code. The plant systems identified in the ISI boundary are found in Section 3.1 of this Inservice Inspection Program Plan. System pressure tests are subdivided into blocks which are tested in accordance with VT-2 packages and work orders which are scheduled and completed on an outage or period basis, as applicable.

9.4 Insulated Bolted Connections IWA-5242 states that borated systems controlling reactivity shall have insulation removed from pressure retaining bolted connections during VT -2 visual exams.

In lieu of performing this examination at plant start-up and after removing/reinstalling the insulation at these bolted connections, the alternative criteria of Code Case N-533-1 will be adopted. This alternate examination allows for removing the insulation and conducting the bolted joint examinations for Class 1, 2 and 3 systems during refueling.

At CPNPP-1, VT-3 certified personnel perform examinations of the bolted connections looking for evidence of leakage per the list of components provided in Preventative Maintenance (PM) Work Order (344681).

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