Text

(Cpnpp), Units 1 & 2, Inservice Testing Plan for Pumps & Valves Fourth Interval, Revision 0
	ML24171A013
Person / Time
Site:	Comanche Peak
Issue date:	06/18/2024
From:	Hicks J; Vistra Operations Company
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	CP-202400235, TXX-24051
	Download: ML24171A013 (1)
	v • d • e

Comanche Peak Nuclear Power Plant Jack Hicks Senior Manager, Fleet Licensing P .O. Box 1002 6322 North FM 56 Glen Rose, TX 76043

CP-202400235 TXX-24051 June 18, 2024

ATTN: Document Control Desk Ref 10 CFR 50.55a(f)(7)

U.S. Nuclear Regulatory Commission Washington , DC 20555-0001

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446

Subject:

CPNPP Units 1 & 2 lnservice Testing Plan for Pumps & Valves Fourth Interval, Revision 0

Dear Sir or Madam :

In accordance with the ASME OM Code-2017 Edition , enclosed for your information is a copy of the lnservice Testing (1ST) Plan for Pumps & Valves for the Comanche Peak Nuclear Power Plant , Units 1 and 2 , associated with the fourth ten-year 1ST interval that began on May 22, 2024. This copy of the 1ST plan is being supplied for information only.

This communication contains no new commitments regarding CPNPP Units 1 and 2.

Should you have any questions , please contact Nie Boehmisch at (254) 897-5064 or nicholas .boehmisch@luminant.com.

Sincerely ,

Jack Hicks

Enclosure:

CPNPP Units 1 & 2 lnservice Testing Plan for Pumps & Valves Fourth Interval , Revision 0

cc:

NRC Regional Administrator, Region IV NRC Project Manager, CPNPP NRC Senior Resident Inspector , CPNPP NRC Resident Inspector , CPNPP

6555 SIERRA DRIVE IRVING , TEXAS 75039 o 214-812-4600 VISTRACORP.COM COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 INSERVICE TESTING PLAN FOR PUMPS & VALVES FOURTH INTERVAL

ADDRESS:

COMANCHE PEAK NUCLEAR POWER PLANT 6322 NORTH FM 56 GLEN ROSE, TEXAS 76043

COMMERCIAL DATES:

UNIT 1 - AUGUST 13, 1990 UNIT 2 - AUGUST 3, 1993 CPNPP/IST

COMANCHE PEAK NUCLEAR POWER PLANT INSERVICE TESTING PLAN FOR PUMPS & VALVES FOURTH INTERVAL EFFECTIVE LISTING FOR SECTIONS, TABLES, AND FIGURES

BELOW IS A LEGEND FOR THE EFFECTIVE LISTING OF SECTIONS, TABLES, AND FIGURES:

Revision 0 May 22, 2024

CPNPP/IST EL-1 Revision 0 CPNPP/IST

Section 1 Revision 0

Section 2 Revision 0

Table 0 Revision 0

Section 3 Revision 0

Valve Table Index Revision 0

Table 1 Revision 0 Table 2 Revision 0 Table 3 Revision 0 Table 4 Revision 0 Table 5 Revision 0 Table 6 Revision 0 Table 7 Revision 0 Table 8 Revision 0 Table 9 Revision 0 Table 10 Revision 0 Table 11 Revision 0 Table 12 Revision 0 Table 13 Revision 0 Table 14 Revision 0 Table 15 Revision 0 Table 16 Revision 0 Table 17 Revision 0 Table 18 Revision 0 Table 19 Revision 0 Table 20 Revision 0

Appendix A Revision 0

EL-1 Revision 0 EL-2 Revision 0

CPNPP/IST EL-2 Revision 0 CPNPP/IST Plan

TABLE OF CONTENTS Page

1.0 GENERAL INFORMATION ......................................................................................... 1-1 1.1 Introduction ...................................................................................................... 1-1 1.2 Code Edition and Addenda ............................................................................. 1-1 1.3 Dates of Test Interval ...................................................................................... 1-1 1.4 Approval Status ............................................................................................... 1-2 1.5 References ...................................................................................................... 1-3

2.0 INSERVICE PUMP TESTING PLAN .......................................................................... 2-1 2.1 Pump Testing Code ......................................................................................... 2-1 2.2 Scope .............................................................................................................. 2-1 2.3 Pump Testing Table Format ............................................................................ 2-1 TABLE 0 - INSERVICE PUMP TESTING PLAN

3.0 INSERVICE VALVE TESTING PLAN ......................................................................... 3-1 3.1 Valve Testing Code ......................................................................................... 3-1 3.2 Scope .............................................................................................................. 3-1 3.3 Valve Testing Table Format ............................................................................ 3-2 3.4 References ...................................................................................................... 3-5 VALVE TABLE INDEX TABLE 1 - AUXILIARY FEEDWATER TABLE 2 - COMPONENT COOLING WATER TABLE 3 - CHILLED WATER (SAFETY & NON-SAFETY)

TABLE 4 - CHEMICAL AND VOLUME CONTROL TABLE 5 - CONTAINMENT SPRAY TABLE 6 - DEMINERALIZED & REACTOR MAKEUP WATER TABLE 7 - DIESEL GENERATOR AUXILIARIES TABLE 8 - FEEDWATER TABLE 9 - MAIN STEAM TABLE 10 - REACTOR COOLANT TABLE 11 - RESIDUAL HEAT REMOVAL TABLE 12 - SPENT FUEL POOL COOLING TABLE 13 - SAFETY INJECTION TABLE 14 - SERVICE WATER TABLE 15 - VENTILATION (CONTROL ROOM AIR CONDITIONING)

TABLE 16 - VENTS & DRAINS TABLE 17 - MISCELLANEOUS CONTAINMENT ISOLATION VALVES TABLE 18 - SAFETY & RELIEF VALVES TABLE 19 - MOTOR OPERATED VALVES TABLE 20 - AIR OPERATED VALVES

APPENDIX A RISK INFORMED RELIEF REQUEST FOR PUMPS AND VALVES ........................ A-1 RELIEF REQUEST FOR SAFEGUARDS PUMPS .................................................... P-1

COMANCHE PEAK - UNITS 1 AND 2 i Rev. 0 CPNPP/IST Plan

COMANCHE PEAK NUCLEAR POWER PLANT UNIT 1 & 2 INSERVICE TESTING PLAN FOR PUMPS & VALVES FOURTH INTERVAL

1.0 GENERAL INFORMATION

1.1 Introduction

Inservice Testing Plan for Pumps & Valves, hereafter referred to as the IST Plan, has been prepared to summarize the test program for certain pumps and valves pursuant to the requirements of the Code of Federal Regulations, 10CFR50.55a(f)(4); and as modified by Relief Request A-1, Request for Alternative from 10CFR50.55a(f)(4)(i) and (ii) for Inservice Testing Frequency Under 10CFR50.55a(a)(3)(i), and by the Nuclear Regulator Commission (NRC)

Safety Evaluation Report (SER) on the CPNPP RI-IST Program. This testing plan is applicable to CPNPP Units 1 & 2. The content and distribution of the IST Plan are controlled and users are cautioned to ve rify the control status of their copy prior to use. To obtain a copy of this document, contact Distribution Control at the Main Document Control Center. An el ectronic copy can be accessed via CPNPP Electronic License Basis Documents (CPNPP ELBD).

Inservice Testing of Snubbers, as required by OM Code ISTD, is addressed separately in document Unit 1 and Unit 2 Snubber Inservice Program Plan.

1.2 Code Edition and Addenda

This IST Plan meets the requirements of the ASME OM Code 2017 Edition, except in specifically identified instances where an alternative to the Code requirements is proposed or where it has been determined that conformance with certain Code requirements is impractical. In these instances, a request for relief from the Code requirement(s), including proposed alternatives to the requirement(s), has been prepared for Nuclear Regulatory Commission review and approval pursuant to 10CFR50.55(f)(5) or 10CFR50.55a(z).

See Section 2.0, Inservice Pump Testing Plan, and Section 3.0, Inservice Valve Testing Plan for a more detailed discussion of Code edition.

1.3 Dates of Test Interval

Implementation of the 1989 Edition IST Plan was completed on CPNPP Unit 1 before that unit was returned to power following the third refueling outage. This superseded the original Unit 1 Inservice Testing Plan for Pumps and Valves developed for the first inspection interval. The original Unit 1 IST Plan was implemented per the requirements of the 1986 Edition of Section XI. This 1989 Edition IST Plan constituted an update of the original Unit 1 IST Plan to a later approved Code edition as allowed by 10CFR50.55a(f)(4)(iv) and as approved by the NRC staff. This IST Plan was to remain in effect for Unit 1 for the 120 month interval following the date of the Unit 1 commercial operation (August 13, 1990).

An exemption from regulation 10CFR50.55a(f)(4)( ii) to the ten year test interval for

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Unit 1 was granted by the NRC on June 21, 1995. The extension allowed Unit 1 to remain under the 1989 Edition until the conclusion of the ten year test interval for Unit 2 (August 3, 2003).

This IST Plan was in effect for Unit 2 for the 120 month interval following the date of the Unit 2 commercial operation (August 3, 1993 to August 2, 2003).

The IST Plan for Unit 1 and 2 first interval end date was extended from August 2, 2003 to not later than August 2, 2004 (see TXX-03075, dated April 11, 2003).

The risk informed inservice testing (RI-IST) was approved by the NRC on August 14, 1998 (Reference 10). The RI-IST Program was incorporated in the first interval program plan Rev. 15, and was implemented on December 4, 2000.

The start date IST Plan second interval for Unit 1 and 2 was August 3, 2004, and the end date for the second interval is August 2, 2013 (see TXX-04134).

The start date of the third interval IST Plan for Unit 1 and Unit 2 was August 3, 2013, and the end date for the third interval is August 2, 2023.

The start date of the fourth interval IST Plan for Unit 1 and Unit 2 was May 22, 2024, and the end date for the fourth interval is August 2, 2033.

1.4 Approval Status

The first interval IST Plan was submitted to the NRC staff on July 2, 1992 via TXX-92302 requesting:

1. Approval to update the Unit 1 IST program to the requirements of the 1989 Edition of ASME Section XI as described in this IST Plan;

2. Approval of a proposed schedule for phasing in the implementation of this IST Plan for Unit 1; and,

3. Approval of the Relief Requests cont ained in Appendix A of this IST Plan for use in the testing of Unit 1 and Unit 2.

Relief Request A-1 and V-8 were submitted to the NRC for final approval Via TXX-98153. These relief requests allowed for risk informing IST.

By safety evaluation dated January 29, 1993 for Unit 1 and NUREG-0797, Supplemental Safety Evaluation Report (SSER) No. 26 dated February, 1993 for Unit 2, the NRC staff granted the following approvals.

1. Approval to update the Unit 1 IST program to the requirements of the 1989 Edition of ASME Section XI and approval to test Unit 2 to the requirements of the Code. (Approval had not specifically been requested to test Unit 2 to the requirements of the 1989 Code since regulation 10CFR50.55a already seemed to permit it; approval was granted nonetheless.)

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2. Approval of the schedule described in Section 1.3 above for phasing in the implementation of this IST Plan for Unit 1.

3. Approval of the Relief Requests cont ained in Appendix A of this IST Plan for use in the testing of Unit 1 and Unit 2 with the exception of Relief Request V5 which was denied. (See Appendix A for specific information.)

As pointed out in the safety evaluation and SSER, the NRC staff review of this IST Plan did not include verification that all pumps and valves within the scope of 10CFR50.55a and ASME Section XI (Now ASME OM Code) are contained in the IST program. Additionally, for the components included in the IST program, all applicable testing requirements were not verified.

1.5 References

1. Code of Federal Regulations, 10C FR50.55a, Codes and Standards.

2. ASME OM Code 2017 Edition, Operation and Maintenance of Nuclear Power Plants.

3. USNRC Generic Letter No. 89-04, Guidance on Developing Acceptable Inservice Testing Programs, April 3, 1989.

4. USNRC, Minutes of the Public Meetings on Generic Letter 89-04, October 25, 1989.

5. USNRC Staff Guidance Letter, NRC Staff Guidance for Complying with Certain Provisions of 10CFR50.55a(g), Inservice Inspection Requirements, November 1976.

6. USNRC Staff Guidance Letter, NRC Staff Guidance for Preparing Pump and Valve Testing Program Descriptions and Associated Relief Requests Pursuant to 10CFR50.55a(g), January 1978.

7. NUREG-0800, USNRC Standard Review Plan, July 1981. (Section 3.9.6, Inservice Testing of Pumps and Valves)

8. Karassik, Igor J., et al. Pump Handbook, second edition. New York:

McGraw-Hill Book Company, 1986.

9. NUREG-1482, Revision 3 Guidelines for Inservice Testing at Nuclear Power Plants.

10. USNRC Letter dated August 14, 1998, Approval of Risk-Informed Inservice Testing (RI-IST) Program for Comanche Peak Steam Electric Station, Unit 1 and 2 (TAC NOS. M94165, MA94166, MA1972, and MA1973). (Relief Request A-1.)

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2.0 INSERVICE PUMP TESTING PLAN

2.1 Scope

The scope of the Inservice Pump Testing Plan is derived from the requirements of ASME OM Code 2017, as modified by 10CFR50.55a(f)(4). As modified by Risk Informed IST Program Plan and previously NRC approved by Relief Request A-1.

The pumps selected for inclusion in this testing plan are pumps which are provided with an emergency power source and are:

a) Required in shutting down a reactor to the safe shutdown condition, or

b) Required in maintaining the safe shutdown condition, or

c) Required in mitigating the consequences of an accident.

Excluded from this testing plan are:

a) Drivers, except where the pump and driver form an integral unit and the pump bearings are in the driver, and

b) Pumps that are supplied with emergency power solely for operating convenience.

c) Skid mounted pumps that are tested as part of the major components and are justified to be adequately tested.

The pumps in the scope of this testing plan are described in the CPNPP Final Safety Analysis Report (FSAR), Section 3.9N.3.2 and 3.9B.3.2, Pump and Valve Operability Assurance and are tabulated in FSAR Tables 3.9N-9 and 3.9B-8, Active Pumps. This similar listing of pumps can be found in Table 0 of this IST Plan.

On August 17, 2017, the NRC required the scope of IST programs to extend beyond ASME Class 1, 2, and 3 pumps and valves, to the pumps and valves within the scope of the ASME OM Code while allowing non-ASME class pumps and valves in the scope of the ASME OM Code to be tested under an Augmented IST Program. A review for additional IST Program scope was performed and documented in AI-TR-2021-002083-5.

2.2 Pump Testing Table Format

Detailed information and testing requirements for the pumps included in this IST Plan are summarized in Table 0. The guidance presented in References 1.5.2, 1.5.8 and 1.5.9 was used to the greatest extent possible in formatting this table.

Following is a discussion of the types of information presented in Table 0.

1. Pump Identification - The pump identification field includes the pump name (system name) and pump number. The pump name is the common noun

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name for the pump and conveys some sense of the pump function. The pump number is a unique identifier applied to each pump. Pumps are listed in Table 0 in alphabetical order by system name. See Flow Diagram M1-0200, Mechanical Symbols and Notes, for a discussion of pump numbering conventions and abbreviations. The pump names and pump numbers shown in Table 0 are the same names and numbers used on the respective flow diagrams to identify the pumps.

2. Flow Diagram Number - The flow diagram number field indicates on which drawing the pump may be found. The flow diagram numbers are prefixed by M1 to indicate a Unit 1 drawing and by M2 to indicate a Unit 2 drawing. The suffix (if any) indicates the drawing sheet number.

3. Code Class - The code class field indicates the ASME Boiler and Pressure Vessel Code,Section III classification for the pump.

4. Pump Type - The pump type field indicates the classification of the pump.

The pumps are classified for the purpose of determining the Code required test parameters to be measured as well as for determining the Code limits for those test parameters. The pump classifications are taken from the Code itself.

Two basic pump classifications are used: centrifugal and positive displacement. Centrifugal pumps are further classified by the pump/driver arrangement and positive displacement pumps are further classified by the mechanical construction of the machine. The pump type acronyms are listed below along with their meanings.

C/DC (Centrifugal pump direct coupled to its driver): This is the most common centrifugal pump arrangement in which the pump and driver are mounted independent of each other (usually horizontally) and are connected by a flexible coupling. In this pump type, the pump and driver bearings are separate.

C/VLS (Centrifugal vertical line shaft pump): This arrangement is a special case of the direct coupled centrifugal pump. As the name suggests, the pump and driver are arranged vertically. However, unlike the typical direct coupled centrifugal pump, the vertical line shaft pump has a pumping element suspended at the end of a very long line shaft and has bearings which are inaccessible. Also, the vertical line shaft pump shares bearings with the driver in that the motor thrust bearing also acts as a thrust bearing for the pump.

C/DC/VLS (Centrifugal vertical line shaft direct coupled): This arrangement is also a special case of a vertically arranged pump. This pump has a short pump shaft, and has an accessible inboard bearing housing near the coupling end of the pump; the pump shaft and suction areas are inaccessible due to being submerged.

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C/CC (Centrifugal pump close coupled to its driver): In this arrangement, no coupling is provided and the pump and driver form an integral unit. The pumping element is attached directly to the motor shaft and the pump bearings are actually the motor bearings. Orientation may be either horizontal or vertical.

PD/RECIP (Reciprocating positive displacement pump): This is a positive displacement pump in which fluid is moved by a back and forth motion of the pressure-producing member(s). The output from a reciprocating pump will be pulsating and flow through the pump is controlled by integral check valves. (There are no reciprocating pumps in the CPNPP IST Plan.)

PD/ROT (Rotary positive displacement pump): This is a positive displacement pump in which fluid is moved by a rotating motion of the pressure-producing member(s). The output from a rotary pump is non-pulsating and flow through the pump is controlled by the geometry of the pump casing and rotor(s).

5. Test Parameters - The test parameters field indicates those quantities which the Code requires to be established or determined at each inservice test. The test parameters include speed, discharge pressure, differential pressure, flow rate and bearing vibration. Vibration is further classified as pump bearing vibration and driver bearing vibration. Not all test parameters are applicable to all pumps. Rather, the parameters to be established or determined for any pump are dependent on the pump type and are specified per the requirements of ASME OM Code 2017 Edition, Subsection ISTB. In Table 0, Code required test parameters are indicated with an X. Test parameters which are not applicable to a particular pump are indicated N/A. Required test parameters for which relief is requested are indicated by a footnote with the specific Relief Request number. (All pump and valve relief requests are contained in Appendix A of this IST Plan.)

6. Test Schedule - The test schedule field indicates the frequency of inservice tests for each pump in the RI-I ST Plan. High Safety Significant pumps for which fluid inventory is normally provided are tested nominally every three months per the requirements of ASME OM Code 2017 Edition, Subsection ISTB-3400, and are indicated in Table 0 by 3 MO. High Safety Significant pumps lacking required fluid inventory (e.g., pumps in dry sumps) are tested at least once every two years per the requirements of ASME OM Code 2017 Edition, Subsection ISTB-3430, and are indicated in Table 0 by 2 YR. Low Safety Significant pumps are tested nominally every six years (on a staggered test basis) unless indicated otherwise per the requirements of Relief Request A-1, and are indicated in Table 0 by 6 YR.

A (Group A pump test): Testing for pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations as defined by ISTB-5121, 5221, 5321 and Table ISTB-3000-1.

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B (Group B pump test): Testing for pumps in standby systems that are not operated routinely except for testing as defined by ISTB-5122, 5222, 5322 and Table ISTB-3000-1.

CPT (Comprehensive pump test): Testing for pumps as defined by ISTB-5123, 5223, 5323 and Table ISTB-3000-1.

PPVT (Pump Periodic Verification Test): Testing for pumps as defined by ISTB-1400(d) and Appendix V.

When a Group A test is required, a comprehensive test or preservice test may be substituted. When a Group B test is required, a Group A, comprehensive test or preservice test may be substituted. When a comprehensive test is required, a preservice test may be substituted. As allowed by ASME OM Code 2017 edition. Subsection ISTB-5000.

Pump Curves may be used for testing where it is impractical to adjust a centrifugal or vertical line shaft pump to a specific reference value as allowed by OMN-16 Rev. 2 of the 2017 Edition of the ASME OM.

7. Footnotes - Footnotes containing additional pump testing information are located at the back of Table 0 and are referenced in Table 0 by the footnote number in parentheses.

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3.0 INSERVICE VALVE TESTING PLAN

3.1 Scope

The scope of the Inservice Valve Testing Pl an is derived from the requirements of ASME OM Code 2017 Edition, Subsection ISTC, Appendix I, II, III and IV as modified by 10CFR50.55a(f)(4) and the Risk Informed IST Program Plan as allowed by previously NRC approved, Relief Request A-1. The valves selected for inclusion in this testing plan are those active or passive valves and pressure relief devices (and their actuating and position indicating systems) which are required to perform a specific function:

a) In shutting down a reactor to the safe shutdown condition, or

b) In maintaining the safe shutdown condition, or

c) In mitigating the consequences of an accident.

Excluded from this testing plan are:

a) Valves used only for operating convenience such as vent, drain, instrument and test valves, or

b) Valves used only for system control, such as pressure regulating valves, or

c) Valves used only for system or component maintenance.

d) Skid mounted valves which are tested as part of the major component.

e) Category A and Category B Safety and Relief Valves are excluded from the requirements of ISTC-3700 and ISTC-3500, valve testing requirements.

Further, the valve actuating system test scope does not include external control and protection systems responsible for sensing plant conditions and providing signals for valve operation.

The active valves and pressure relief devices in the scope of this testing plan are described in the CPNPP Final Safety Analysis Report (FSAR), Sections 3.9N.3.2 and 3.9B.3.2, Pump and Valve Operability Assurance, and are tabulated in FSAR Tables 3.9N-10 and 3.9B-10, Active Valves. Pressure relief devices that only protect systems/components that perfo rm a safety function as described above are not tabulated in FSAR Tables 3.9N-10 and 3.9B-10. These valves will continue to be tested within the required test interval of 10 years during the fourth interval. Consistent with the philosophy discussed in Reference 1, these specific thermal relief valves do not require the two additional valve tests following as-found set-pressure determination failures. However, if performance data indicates that more frequent testing is needed to assure valve function, then the

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testing frequency should be modified. In lieu of tests, valve replacement may be performed as an alternative to testing. This philosophy only applies to thermal relief valves whose only function is to protect systems/components that have a safety function. These valves are identified in the IST Plan by having a safety function position listing of N/A.

The passive valves and pressure relief devices in the scope of this testing plan were identified by review and are those valves and pressure relief devices which perform a nuclear safety function but are not active and for which leakage testing or position indicator testing is required.

A listing of the above described active and passive valves and pressure relief devices can be found in Tables 1 through 20 of this IST Plan.

On August 17, 2017, the NRC required the scope of IST programs to extend beyond ASME Class 1, 2, and 3 pumps and valves to the pumps and valves within the scope of the ASME OM Code while allowing non-ASME class pumps and valves in the scope of the ASME OM Code to be tested under an Augmented IST Program. A review for additional IST Program scope was performed and documented in AI-TR-2021-002083-5.

3.2 Valve Testing Table Format

Detailed information and testing requirements for the valves included in this IST Plan are summarized in Tables 1 through 20. A separate table has been prepared for each plant system which contains valves in the scope of the plan.

The tables are arranged in alphabetical order by system name:

Auxiliary Feedwater Table 1

Component Cooling Water Table 2

Chilled Water (Safety & Non-Safety) Table 3

Chemical and Volume Control Table 4

Containment Spray Table 5

Demineralized and Reactor Makeup Water Table 6

Diesel Generator Auxiliaries Table 7

Feedwater Table 8

Main Steam Table 9

Reactor Coolant Table 10

Residual Heat Removal Table 11

Spent Fuel Pool Cooling Table 12

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Safety Injection Table 13

Service Water Table 14

Ventilation (Control Room Air Conditioning) Table 15

Vents and Drains Table 16

Miscellaneous Containment Isolation Valves Table 17

Safety & Relief Valves Table 18

Motor Operated Valves Table 19

Air Operated Valves Table 20

The guidance in References 1.5.2, 1.5.8 and 1.5.9 was used to the greatest extent possible in formatting the tables. Following is a discussion of the types of information presented in the tables.

1. Valve Groups - Valves are grouped by system, safety significance, valve type, actuator type, manufacturer, model number. Each group has a unique Group Number to facilitate the implementation of the risk informed Inservice Test Program.

2. Valve Identification - Valve identification includes the valve number field and a brief description of the valve safety function (in the Remarks field).

In each table, the valves are arranged in numerical order by the four digit location number which forms the root of each valve number. See Flow Diagram M1-0200, Mechanical Symbols and Notes, for a discussion of valve numbering conventions and abbr eviations. The valve numbers shown in Tables 1 through 19 are the same numbers used on the respective flow diagrams to identify the valves.

For valves which exist in both Unit 1 and Unit 2 and for which the test requirements are the same, the unit designator prefixes have been dropped from the valve numbers in the tables. The valve numbers in this case should be understood to be prefixed by 1 (or CP1) and 2 (or CP2),

as appropriate. If a valve is in a comm on system, exists in one unit only, is numbered differently between units or has different test requirements between units, then the unit designator is shown.

3. Flow Diagram Number - The flow diagram number field indicates on which drawing the valve may be found. The flow diagram numbers are prefixed by M1 to indicate a Unit 1 drawing and by M2 to indicate a Unit 2 drawing. The suffix (if any) indicates the drawing sheet number. Drawing coordinates are indicated in parentheses below the flow diagram number for ease in locating a valve.

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4. Risk Ranking - A valve will either be ranked as High or Low Safety Significant. This was determined through the CPNPP Individual Plant Examination utilizing Probability Risk Assessment techniques and through the RI-IST Expert Panel.

5. Size - The size field indicates the nominal valve size in inches.

6. Code Class - The code class field indicates the ASME Boiler and Pressure Vessel Code,Section III classification for the valve.

7. Category - The category field indicates the classification of the valve according to characteristics described in 2017 Edition, Subsection ISTC-1300. See the Valve Table Index at the end of this section for a listing of valve categories and their meanings.

8. Function - The function field indicates the manner in which a valve accomplishes its required safety function(s). A denotes an active valve and P denotes a passive valve with the terms defined as follows:

Active valves - valves which are required to change obturator position to accomplish their required safety function(s).

Passive valves - valves which maintain obturator position and are not required to change obturator position to accomplish their required safety function(s).

Obturator - valve closure member (disk, gate, plug, ball, etc.)

9. Safety Function Position - The safety function position field indicates the position (open or closed) to which a valve must move or remain in to accomplish its required safety function(s). The open and closed positions are indicated by O and C respectively.

10. Test Parameters/Schedule - The test parameters/schedule field denotes the Code test requirements and test frequencies for valves in the IST Plan.

The test parameters include leak test, exercise test, fail-safe test and position indicator test. Not all test parameters are applicable to all valves.

Rather, the parameters to be tested for any valve are dependent on the valve/actuator type, category, and function. Valves which have both an open and closed safety function position and for which the test requirements or frequencies are different in the two positions, have their open and closed test requirements identified separately. Test parameters which are not applicable to a particular valve are indicated N/A.

Check valves are exercise tested in both the open and closed direction regardless of safety function position or valve safety significance. Non-safety function exercise tests for high safety significant check valves shall be performed at least once every two years. Non-safety function exercise

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tests for low safety significant check valves shall be performed at the frequency specified in Relief Request A-1.

Required test parameters or test frequencies for which relief is requested are indicated by the specific Relief Request number. (All pump and valve relief requests are contained in Appendix A of this IST Plan.) In cases where the performance of a valve full-stroke exercise test is limited to cold shutdowns or refueling outages, a table footnote is provided which justifies this determination. See the Valve Table Index at the end of this section for a listing of test parameter and schedule acronyms and their meanings.

11. Footnotes - Footnotes containing additional valve testing information are located at the back of each system valve table and are referenced in the tables by the footnote number in parentheses.

3.3 References

1. NUREG/CP-0152, Proceedings of the Fourth NRC/ASME Symposium on Valve and Pump Testing, July 15-18, 1996, pages 3B-19 through 3B-21.

2. NUREG-1482, Rev. 3, Guidelines for Inservice Testing at Nuclear Power Plants.

3. USNRC Letter dated August 14, 1998, Approval of Risk Informed Inservice Testing (RI-IST) Program for Comanche Peak Steam Electric Station, Unit 1 and 2 (TAC NOS. M94165, MA94166, MA1972, and MA1973). (Relief Request A-1.)

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COMANCHE PEAK - UNITS 1 AND 2 Rev. 0 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

The following pages contain requests for relief from certain Code test requirements which are identified in the Pump and Valve Testing Plans tables. The Relief Requests address instances where an alternative to the Code requirements is proposed or where it has been determined that compliance with certain Code requirements is impractical or presents a hardship or unusual difficulty without a compensating increase in the level of plant quality and safety. Relief Requests associated with the Inservice Pump Tes ting Plan have numbers prefixed with P.

Relief Requests associated with the Inservice Valve Testing Plan have numbers prefixed with V. Administrative Relief Requests have numbers prefixed with A. The guidance presented in References 1.5.2, 1.5.6 and 1.5.9 was used to the greatest extent possible in formatting the Relief Requests in this appendix.

NRC staff approval pursuant to 10CFR50.55a(a)(3) or (f)(5) is required prior to implementation of a Relief Request. The approval status of each Relief Request in this appendix is indicated individually as part of the Relief Request.

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RELIEF REQUEST NO. A-1

SYSTEM See Tables 0 through 19.

CODE CLASS See Tables 0 through 19.

CATEGORY See Tables 0 through 19.

COMPONENT NO. & See Tables 0 through 19. This change affects all current components COMPONENT in the CPNPP Inservice Testing (IST) Plan, and also adds some new DESCRIPTION components to the RI-IST Plan.

DESCRIPTION Risked Informed - Inservice Testing, Alternative from 10CFR50.55a(f)(4)(i) and (ii) for Inservice Testing Frequency: This alternative utilizes a risk-based approach to change the test frequencies of certain low safety significant components (LSSCs) in the ASME OM Code pump and valve inservice testing (IST) Program.

The extended frequencies are greater than those currently allowed by the ASME OM Code. The process used to identify candidates for frequency extension is discussed under Proposed Alternative and Basis for Alternative.

CURRENT TEST Test frequencies of 2 years or less, the specified frequency for each REQUIREMENTS inservice test is met if the test is performed within 1.25 times the interval specified in frequency. For test frequencies greater than 2 years, the specified frequency for each inservice test is met if the test is performed with the interval specified in frequency (1.25 times interval does not apply).

Regulation 10 CFR 50, Section 50.55a(f)(4)(i) states;

Inservice tests to verify operation readiness of pumps and valves, whose function is required for safety, conducted during the initial 120-month interval must comply with the requirements in the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section on the date 12 months prior to the date of issuance of the operating license subject to the limitations and modifications listed in paragraph (b) of this section.

Regulation 10 CFR 50, Section 50.55a(f)(4)(ii) states;

Inservice tests to verify operation readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month interval must comply with the requirements in the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of the 120-

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month interval, subject to the limitations and modifications listed in paragraph (b) of this section.

The ASME Code of record for CPNPP is the ASME OM Code 2004 Edition through 2006 Addenda. The Code specifies the following test frequencies:

Test Type Test Frequency (nominal) Code Reference

Pump Test 3 months OM ISTB

Valve Position Indication 2 years OM ISTC Verification

Valve Exercising Test 3 months OM ISTC

Valve Fail-Safe Test 3 months OM ISTC

Valve Leak Rate Test 2 yearsOM ISTC (Non-Containment Isolation Valves)

Frequency per Appendix J 10CFR50 App. J (Containment Isolation Valves)

Check Valve Exercise Test 3 months OM ISTC

Safety/Relief Valve Setpoint Test 5 years OM Appendix I (class 1, class 2 MSSV)

10 years (class 2, 3) OM Appendix I

PROPOSED In lieu of performing inservice tests on pumps and valves whose ALTERNATIVE function is required for safety at frequencies specified in the ASME Code, as required by 10 CFR 50.55a(f)(4)(i) during the 120-month operating interval, this alternative would allow the inservice test frequencies of those pumps and valves to be determined in accordance with an NRC approved Risk-Informed IST Program Description at CPNPP as follows:

(1) The safety significance of pumps and valves whose function is required for safety will be assessed in accordance with the NRC approved Risk-Informed IST Program Description. These components will be classified as either High Safety Significant

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Components (HSSCs) or Low Safety Significant Components (LSSCs). The inservice testing of those components classified as LSSC will be performed at extended test frequencies determined in accordance with the Risk-Informed IST Program Description. The inservice test methods for all pumps and valves whose function is important to safety will continue to be performed in accordance with the ASME Code.

(2) The safety significance assessment of pumps and valves will be updated, as specified in the Risk-Informed IST Program Description.

This alternative will also apply to 10CFR50.55a(f)(4)(ii) for successive 120-month IST intervals.

See Attachment 1 for the Risk-Informed Inservice Testing Program Description.

BASIS FOR Section 50.55a(a)(3) of 10 CFR states in part:

ALTERNATIVE Proposed alternatives to the requirements of paragraphs (c), (d), (e),

(f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation.

The applicant shall demonstrate that: (i) The proposed alternatives would provide an acceptable level of quality and safety.

TU Electric requests NRC approval to implement the Risk-Informed Inservice Testing Program Description as an alternative to the requirements of 10 CFR 50.55a(f)(4)(i) and (ii). These regulations require that inservice tests on pumps and valves, whose function is required for safety, must comply with a specified ASME Code.

Specifically, TU Electric requests approval to utilize a risk-Informed inservice testing program to determine inservice test frequencies for valves and pumps that are identified as low safety significant, in lieu of testing those components at the frequencies specified in the ASME Code. The use of the Risk-Informed Inservice Testing Program Description will provide an acceptable level of quality and safety.

The current Code is based on a deterministic approach which considers a set of challenges to safety and determines how those challenges should be mitigated. The deterministic approach contains elements of probability, such as the selection of accidents to be analyzed as design basis accidents (e.g., the reactor vessel rupture is considered too improbable to be included) and the requirements for emergency core cooling (e.g., safety train redundancy).

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The Risk-Informed IST Program that would be implemented with this alternative incorporates a probabilistic approach to regulation which enhances and extends this traditional, deterministic approach, by:

(1) allowing consideration of a broader set of potential challenges to safety,

(2) providing a logical means for prioritizing these challenges based on risk significance, and

(3) allowing consideration of a broader set of resources to defend against these challenges.

First, the PRA model has identified a broader set of challenges to safety. The Risk-Informed Inservice Testing Program identified High Safety Significant Components (HSSCs) which were not in the previous ASME IST Program. Even though the components are outside the ASME Code class boundary, they will be tested commensurate with their safety significance. Where the ASME OM Code testing is practical, HSSCs not in the current ASME IST Program Plan will be tested in accordance with Appendix I for safety relief valves, Subsection ISTC for active valves and Subsection ISTB for pumps. Where ASME OM Code testing is not practical, alternative methods will be developed to ensure operational readiness.

Components in the current ASME IST Program which are determined to be HSSCs will continue to be tested in accordance with the current Program, which meets the requirements of the ASME OM Code, except where specific written relief has been granted. Components in the current ASME IST Program which are determined to be LSSC will also be tested in accordance with the ASME IST Program, except that the test frequency will initially be ex tended to once every 6 years. The extended test frequency will be staggered over 6 years as described in Attachment 1. No LSSC will be deleted from the ASME IST Program.

Second, the Risk-Informed Inservice Testing Program prioritizes these challenges based on the results of the CPNPP PRA. The risk rankings are then complemented with rankings based on consideration of other accident initiators (e.g. fires, tornadoes, and earthquakes) and plant operating modes. These rankings considered importance with respect to core damage prevention, and prevention of large early releases of radiation to the public. Attachment 1 (pages 5 through 20 of Enclosure 1 to TXX-98086) describes the program methodology.

Enclosure 3 to TXX-96371 (TU Electric letter dated June 3, 1996, from C. L. Terry to the NRC) provides the current list of LSSCs from the initial implementation of that methodology.

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Third, an Integrated Decision Process (IDP) allows a broader set of resources to be considered to defend against challenges to safety.

The IDP is composed of experienced individuals with expertise in the areas of ASME Code, plant operations, maintenance engineering, system engineering, design engineering, and probabilistic risk assessment. The IDP is responsible to ensure the risk ranking input information is consistent with plant design, operating procedures, and with plant-specific operating experience. At the end of the IDP review process every component in the CPNPP ASME IST Program is reviewed.

The risk-informed process will assure that a defense-in-depth philosophy is maintained.

As a living process, components will be reassessed periodically to reflect changes in plant configuration, component performance, test results, industry experience, and other factors. When the list of components is affected, changes will be provided to the NRC in regular Program updates.

There could be safety enhancements obtained by focusing resources on HSSCs and reducing the testing frequency on LSSCs. Extensive testing on LSSCs could have an adverse effect on safety. Reduction of testing should reduce component wear-out, operator burden, system unavailability, cost of te sting, and radiation exposure.

Reduced testing could also achiev e a more optimum balance between the positive impacts of testing and the negative effects of disturbing equipment from service and entering less than optimum plant configuration, such as valve misalignments.

RADIOLOGICAL Potential radiation exposure will be diminished due to less frequent CONCERNS (ALARA) testing.

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ATTACHMENT TO R/R A-1 RISK-INFORMED INSERVICE TESTING PROGRAM DESCRIPTION (RI-IST)

The proposed alternative is a risk informed pr ocess to determine the safety significance and testing strategy of components in the ASME Inservice Testing (IST) Program, and identify non-ASME IST components (pumps & valves) modeled in the Probabilistic Risk Analysis (PRA) that are determined to be High Safety Significant Com ponents (HSSCs). The process consists of the following elements.

1) Utilization of the Probabilistic Risk Analysis (PRA) techniques to identify component importance measure values. (PRA Techniques)

2) Categorize components based on importance measures determined by the PRA techniques. (Component Risk Category)

3) Blended deterministic and probabilistic data to perform a final importance ranking of components and categorization as either Low Safety Significant Component (LSSC) or High Safety Significant Component (HSSC). (Integrated Decision Process) (IDP)

4) Develop/Determine Test Frequencies and Test Methodologies for the IST components. (Testing Philosophy)

5) Evaluate the cumulative impact of the test frequency changes on total plant risk (i.e., CDF and LERF) to ensure that the change in plant safety is within the acceptable range. (Cumulative impact)

6) Develop an implementation plan. (Implementation)

7) Develop a Corrective Action plan. (Corrective Action)

8) Perform periodic reassessments. (Periodic Reassessments)

9) Methodology for making changes to the RI-IST. (Changes to RI-IST Program after Initial NRC Approval)

1) PRA Techniques

PRA methods will be used to determine the risk significance of components based on end states of interest, such as core damage fr equency (CDF) and release of radioactivity (e.g.

large early release frequency (LERF)).

The PRA techniques are used in conjunction wi th the Integrated Decision Process (IDP) to ensure that all the available information is accounted for in developing the importance measures. As such, a review of plant equipment and operating procedures will be performed to identify potential plant specific initiating events as well as those initiating

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events that have been identified in the Nuclear industry. Evaluation of initiating events will also include loss of support systems and other special initiators.

Any changes to the PRA models used for the development of importance measures for the RI-IST will be independently reviewed. The independent reviews will be by either the in-house personnel or outside consultants.

The PRA will be periodically evaluated (See Section 8) to reflect the current plant design, procedures, and programs. Also the PRA will be evaluated prior to moving components to the LSSC category.

A full scope PRA is not required. However, any limitations (e.g. missing initiating events) will be addressed by the IDP using the methodology described in Section 2 below.

The potential degradation of components will be considered in the overall assessment of risk associated with the implementation of the RI-IST. As a result, any effect on common cause failure estimations will also be evaluated. To the extent possible, plant-specific data will be utilized to assess component degradation.

Compensatory measures which are used as part of the IDP process to qualitatively justify the extension of test interval will be re-verified during the IDP process update (See Section 8).

2) Component Risk Category

Two figures of merit will be used to initially determine the risk categories of IST components. These two methods are Fussell-Vesely (FV) and Risk Achievement Worth (RAW). For the RI-IST Program, the following criteria will be used to initially rank components for review by the Integrated Decision Process (IDP).

Category Criterion

High FV > 0.001

Potentially High FV < 0.001 and RAW > 2

Low FV < 0.001 and RAW < 2

The CDF and LERF for the change are within the acceptance guidelines of Regulatory Guide 1.174.

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Methodology/Decision Criteria for Limited Scope PRA

The following describes the methodology used to categorize components in the RI-IST when the program is reassessed. However, only those elements that are significantly affected by the model changes (e.g., design modifications or procedural changes) need to be reviewed in detail using this process. The scope of the review and the justification for it will be documented as part of the IDP.

Apply Importance Criteria to PRA and Review

Review FV and RAW importance measures for pumps and valves considered in the PRA against the criteria and determine if the grouping of components is logical.

Review component importance measures to make sure that their bases are well understood.

Robustness/Validation of Results

Address the sensitivity of the results to common cause failures (CCF),

assuming all/none of the CCF importance is assigned to the associated component.

Evaluate the sensitivity due to human action modeling. Identify/evaluate operator actions omitted by the PRA that can change the ranking of a component. The omitted recovery actions are those not credited because they are not important to the CDF.

Consider industry history for particular IST components. Review such sources as NRC Generic Letters, SOERs, IOERs and Technical Bulletins and rank accordingly.

For components with low FV/high RAW ensure that other compensatory measures are available to maintain the reliability of the component.

Identify and evaluate components whose performance shows a history of causing entry into LCO conditions. To ensure that safety margins are maintained, consider retaining the ASME test frequency for these components.

Ensure that truncated components have been eliminated due to redundancy of function rather than solely due to reliability. If they are truncated due to their high reliability, then those components should be qualitatively re-evaluated and re-categorized appropriately.

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Validate or change the PRA-based component ranking. If the validated PRA ranking is high, rank the component high; if the PRA ranking is low and the other factors such as the operating performance of the component validate the ranking, rank as low.

Fire, Tornado and Seismic Considerations

Consider the following for risk ranking components for external events.

Calculate risk importance measures for components in the fire and tornado cutsets. Compare these calculated values and the PRA values to identify those components that are low risk significant for the PRA but high risk significant for fire and tornado.

Review component importance measures and the PRA limitations for fire and tornado in a manner similar to that described for internal events discussed above and adjust the rankings of the components accordingly.

For those components on the Safe Shutdown Equipment List (SSEL) and the containment systems list, review their risk categories to ensure that those components important to seismic and containment integrity are appropriately categorized.

Outage Risk Importance

A qualitative assessment of PRA systems modeled for shutdown modes will be performed to determine the impact of shutdown modes on IST rankings. To perform this analysis a three step process will be used. First, using existing PRA system models as the basis, components and system configurations that are unique to the shutdown modes from the at power PRA will be identified. Second, using a qualitative set of rules, components in key trains will be ranked into three categories:

1. Category 1: High safety significant components (high FV)

2. Category 2: Potentially high safety significant components (low FV, moderate to high RAW).

3. Category 3: Low safety significant components (low FV, low RAW)

Third, support systems that are unique to shutdown configurations will also be identified and ranked accordingly.

There are several safety functions important to shutdown. These are Over-Pressure Protection, Shutdown Cooling, Spent Fuel Pool Cooling, Inventory

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Control, Reactivity Control, AC Power, and Containment Integrity. Rather than analyzing each function separately, the systems required for the shutdown accident sequences will be analyzed and ranked with respect to their shutdown configurations. This will provide a co mprehensive review of the shutdown systems and their unique configurations.

The risk profile for an outage changes as maintenance activities start and stop and plant states change. Therefore, the importance of components can also change during the outage, depending on the plant configuration as governed by the outage schedule. There can be times when almost any component can become more risk significant depending upon the outage scenario. If the plant is in a configuration of increased risk, and an IST component must operate to respond to an accident, that component will be more risk significant for that time period. If that period of time is extended, then the component on average will be more risk significant.

A major difference between at power and shut down is that safety systems are in a standby mode at power and active components must start or reposition automatically for success. Since actuation failure is much more likely than failure to continue to operate, a reliability-orient ed risk importance measure like Fussell-Vesely is lower for outage than at power. However, since functional importance is similar, the RAW value is likely to be the same and its FV is correspondingly lower. Also, during shutdown, automatic actuations are usually blocked and pumps and valves are actuated by manual operation only. Since the failure probability for human action may at times be more likely than automatic actuation, the contribution of equipment failure is relatively less likely. Therefore, in most cases the ranking of components at pow er is higher than during shutdown, although the system configuration must still be compared to determine if there are unique differences for the shutdown mode. Based upon the insights discussed above, the approach to risk ranking is as follows:

If a component performs the same function and is in the same initial state as at power, the at power ranking is assumed to bound the outage ranking.

If a component performs a different function or is in a different initial state than at power, then the outage ranking must be evaluated.

The latter evaluation involves cases where a different system is used, i.e., spent fuel pool cooling, or where a different function is performed by a component in a system used at power or during an outage. Additionally the following guidelines are used for risk ranking for shutdown.

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Category 1 - High Safety Significant Components (High FV):

Pumps that must start to perform function (assume all pumps in systems that cycle operating trains)(High FV)

Motor Operated Valve (MOV) or Air Operated Valve (AOV) that must change state to perform function (but not portions with redundant paths, e.g. two supply sources to one pump)(High FV)

MOV or AOV that must change state to prevent flow diversion that can fail redundant trains (high FV, extremely high RAW)

Pressure relief valves (safety or power operated) needed to control pressure so that redundant trains of systems can perform function (high FV or low FV, high RAW)

Category 2 - Potentially High Safety Significant Components (low FV & moderate to high RAW):

Pumps that must continue running (low FV, moderate RAW)

Valves in single path portions of redundant systems that are not required to change state (RHR outlet valves)(usually low FV, moderate or high RAW)

Check valve plus MOV or AOV that must remain as is if they are in the trains only flow path (low FV, moderate RAW)

Check valves for which reverse flow can fail redundant trains simultaneously (low FV, extremely high RAW)

MOV or AOV which if they change state can cause flow diversion that can fail redundant trains (low FV, extremely high RAW)

Control components that need to function to prevent system degradation (e.g. AFW flow control valves to the Steam Generators that can fail the Turbine Driven AFW pump)(low FV, moderate RAW)

Category 3 - Low Safety Significant Components (low FV & low RAW):

All other Components that do not fall into category 1 or 2 were ranked low.

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These rules will be applied to the systems that support the safety functions described herein.

Back-end Risk Importance

It is equally important to identify those pumps and valves that prevent containment failure or bypass that could result in an unacceptable release. Examples might include the valves that provide the boun dary between the reactor coolant system and low-pressure systems located outside containment. Various analyses have shown that large releases, though infrequent and of low probability, tend to dominate offsite consequences. Therefor e, those IST components identified by back-end analyses will be ranked according to their importance to large early release frequency only.

Containment isolation failures or containment bypass events can, in some accident scenarios, cause a large, early release. The associated valves represent a substantial fraction of components treated by the IST program. However, their importance varies significantly depending on their initial position, their size, the leak path they are in, etc. These factors will be evaluated with a simple model consistent with the PRA back-end analys is. Risk importance of containment functions will be measured by developing quantitative importance measures for accidents contributing to large, early releases.

The large, early releases are more likely to result from accidents with the following attributes:

A failure in containment exists at the time of the accident, either because the containment fails to isolate or it is bypassed, or

A high-pressure core meltdown occurs with containment heat removal (sprays) unavailable at the time of core melting.

One cause of a large, early release is a steam generator tube rupture, with immediate failure of core cooling, and failur e of the main steam system to isolate.

A large but not early release can also occur if the same scenario occurs except that core cooling fails late in the accident rather than immediately. This latter scenario is the most likely source of a large release. However, because adequate time would be available to implement emergency response measures, this source of a large release will not be considered in the importance measure calculation.

Instead, the most important sources of main steam isolation failure are considered potentially important and will be reviewed by the IDP to determine if the associated valves should be categorized as high.

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IST Components Not in PRA

Review components not explicitly modeled in the PRA to ensure an IST component is, in fact, low risk.

High-Risk PRA Components Not in the IST Program

Identify other high risk pumps and valves that are not in the IST program but should be tested commensurate with their risk importance.

Evaluate the PRA modeling assumptions, component failure modes, operator actions, recoveries and any other effects that could substantiate the components risk category as high ri sk even if they are not in the IST Program.

Determine whether current plant testing is commensurate with the importance of these valves. If not, determine what test, e.g., the IST test, would be the most appropriate.

Other Considerations

Perform sensitivity studies, as needed, to evaluate the cumulative impact of changes in the IST Program test strategies on the total Core Damage Frequency (CDF).

3) Integrated Decision Process

The purpose of utilizing the Integrated Decision Process (IDP) is to confirm or adjust the initial risk ranking developed from the PRA re sults, and to provide qualitative assessment based on engineering judgement and exper ience. This qualitative assessment compensates for limitations of the PRA, including cases where adequate quantitative data is not available.

The IDP utilizes deterministic insights, engineering judgement, experience and regulatory requirements as described above in Section 2. The IDP will review the initial PRA risk ranking, evaluate applicable deterministic information, and determine the final safety significance categories. The IDP considerations will be documented for each individual component to allow for future repeatability and scrutiny of the categorization process.

The scope of the IDP includes both categorization and application. The IDP is to provide deterministic insights that might influence categorization. The IDP will identify components whose performance justifies a higher categorization.

The IDP will determine appropriate changes to testing strategies. The IDP will identify compensatory measures for potentially high components or justify the final

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categorization. The IDP will also concur on the test interval for components categorized as low.

The end product of the IDP will be components categorized as Low Safety Significant Component (LSSC) or High Safety Significant Component (HSSC).

In making these determinations, the IDP will ensure that key safety principles, namely defense-in-depth and safety margins, are maintained and that the changes in risk for both CDF and LERF are acceptable per the guidelines discussed in Section 2 above. The key safety principles are described below.

Defense in Depth

To ensure that defense-in-depth is maintai ned by the CPNPP RI-IST program, adherence to four basic principles will be reviewed and documented as part of the IDP for any future changes to the program. The following des cribes these four basic principles:

1. No changes to the plant design or operat ions procedures will be made as part of the RI-IST program which either significantly reduce defense-in-depth or place strong reliance on any particular plant feature, human action, or programmatic activity.

2. The results and dominant contributors to core damage risk will be reviewed to ensure that the categorization of components using PRA is done on an evenhanded basis covering the full scope of safety functions. A review will be done to ensure that components which mitigate the spectrum of accidents are not ranked low solely because of initiating event frequency. Further, sensitivity studies will be performed for human actions to ensure that components which mitigate the spectrum of accidents are not ranked low solely because of the reliability of a human action.

3. The methodology for component categorization, namely the selection of importance measures and how they are applied and understanding the basic reasons why components are categorized HSSC or LSSC, will be reviewed to ensure that redundancy and diversity are preserved as the more important principles. If a component is categorized as LSSC solely due to its high reliability, then it must be confirmed that: 1) plant performance has been good and 2) a compensatory measure or feedback mechanism is available to ensure adverse trends in equipment performance can be detected in a timely manner. A review will be done to ensure that relaxation in the RI-IST program occurs only when the level of redundancy or diversity in the plant design or operation supports it. In this regard, all components that have significant contributions to common cause failure will be reviewed to avoid relaxation of requirements on those components with the lowest level of diversity within the system.

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4. The use of multiple risk metrics, including core damage frequency (CDF) and large early release frequency (LERF), with additional checks for large but late releases and consequence mitigation, will be done to ensure a reasonable balance between risk reduction methods.

Other Considerations Related To Defense-In-Depth

When the PRA does not explicitly model a component, function or mode of operation, a qualitative method may be used to classify the component HSSC or LSSC and to determine whether a compensatory measure is required.

Sufficient Safety Margin is Maintained

The IDP will perform reviews to ensure that su fficient safety margin is maintained when compared to the existing IST program. In perfo rming this review, the IDP will consider such things as proposed changes to test intervals and, where appropriate, test methods.

The IDP will ensure that the proposed compensat ory measures are effective fault finding tasks, where this is required in the program, to assure safety margin is maintained. To enhance the safety margin, the IDP will also review PRA-important components not in the current IST program for potential inclusion in the RI-IST program.

Categorization Guidelines

Modeled Components/Functions

For modeled components/functions with a FV >0.001 the IDP either confirms the component categorization is HSSC or justification of conservatism in the PRA model will be developed.

For modeled components/functions with a FV <0.001, but a RAW >2.0, the component will be categorized LSSC provided a compensatory measure exists that ensures operational readiness and the components performance has been acceptable. If a compensatory measure is not available or the component has a history of performance problems, the component will be ranked HSSC.

For modeled components/functions with a FV <0.001 and a RAW <2.0, the component will be categorized as LSSC provided the components performance has been acceptable. For those components with performance problems, a compensatory measure will be identified to ensure operational readiness or the component will be categorized as HSSC.

Non-Modeled Components/Functions

For components not modeled or the safety function not modeled in the PRA, the categorization is as follows:

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If the sister train is modeled then the component takes that final categorization.

If the component is implicitly modeled, the FV and RAW are estimated and the deliberation is as discussed for modeled components/functions.

If the component is not implicitly modeled, the system ranking associated with the Maintenance Rule will be confirmed. For confirmed system ranking, the component performance history will be reviewed. For acceptable performance history the component will be categorized as LSSC. For poor performance history, a compensatory measure will be identified to ensure operational readiness and the component categorized as LSSC, or if no compensatory measures are available, categorize the component as HSSC.

Documentation

Documentation of the IDP will be available for review at the plant site.

4) Testing Philosophy

Motor Operated Valves (MOVs)

HSSC Testing will be performed in accordance with Mandatory Appendix III, and NRC Generic Letter 89-10 and 96-05 commitments.

LSSC Testing will be performed in accordance with Mandatory Appendix III, and NRC Generic Letter 89-10 and 96-05 commitments.

Note: OMN-1 Rev. 1 (originally approved for use under relief request V-1 in the third interval) has expired. Code Case OMN-1 Rev.1 has been incorporated into the OM Code as Mandatory Appendix III which allows a Risk-Informed approach to enable testing on extended intervals.

Therefore, testing of Active MOVs will be performed in accordance with Mandatory Appendix III. Passive HSSC MOVs will continue to be tested per ISTC-3500-1 at intervals specified by the OM Code, and Passive LSSC MOVs will continue to be tested per ISTC-3500-1 except with test frequencies not to exceed 6 years.

Performance Monitoring (applicable to HSSC and LSSC):

termination inspection

stem threads re-lubed

actuator gear box grease inspection

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ATTACHMENT TO R/R A-1

T-drain inspection

limit switch gear box grease inspection

visual inspection of housings

stem nut staked and secure

Relief Valves

HSSC & Testing will be performed in accordance with Code of Record as LSSC defined in 10CFR50.55a.

Performance Monitoring (applicable to HSSC and LSSC):

test results trended

new valves tested prior to installation

valves set as close to nominal as practical

Check Valve Testing Strategy

HSSC Testing will be performed in accordance with the ASME Code of Record as defined by 10CFR50.55a.

Certain HSSC check valves will also be tested in accordance with the Check Valve Reliability Program (CVRP). This program was developed in response to INPO SOER 86-03. Testing for the CVRP includes nonintrusive testing (e.g. acoustic monitoring) and where conditions direct, valve disassembly. The enhanced nonintrusive testing provides for co ndition monitoring by comparing data from current testing to a known baseline where the valve was operating in a satisfactory manner

LSSC Testing will be performed in accordance with the ASME Code of Record as defined by 10CFR50.55a except at a test frequency not to exceed 6 years.

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ATTACHMENT TO R/R A-1

Test frequencies of 2 years or less, the specified frequency for each inservice test is met if the test is performed within 1.25 times the interval specified in frequency. For staggered test frequencies greater than 2 years (typically 3 to 6 years), the specified frequency for each inservice test is met if the test is performed within 1.25 times the 18 month interval, but not to be deferred past the next refueling outage.

Certain LSSC check valves will be tested in accordance with the CVRP as necessary.

Check valves included in the CVRP are those which have been evaluated to be susceptible to wear, fatigue, or corrosion.

Performance Monitoring (applicable to HSSC and LSSC):

acoustic monitoring data when taken is trended

check valve disassembly inspections where necessary

Air Operated Valves (AOVs)

HSSC Testing will be performed in accordance with the Code of Record as defined by 10CFR50.55a.

LSSC Testing will be performed in accordance with the Code of Record as defined by 10CFR50.55a except with a test frequency not to exceed 6 years. Additionally LSSC AOVs will be stroked at least once during the operating cycle.

Test frequencies of 2 years or less, the specified frequency for each inservice test is met if the test is performed within 1.25 times the interval specified in frequency. For staggered test frequencies greater than 2 years (typically 3 to 6 years), the specified frequency for each inservice test is met if the test is performed within 1.25 times the 18 month interval, but not to be deferred past the next refueling outage.

Performance Monitoring (applicable to HSSC and LSSC):

diagnostic testing

elastomer replacement

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ATTACHMENT TO R/R A-1

response time testing

Note: Beginning with the Fourth interval, Luminant Power revised the AOV program to implement the new performance assessment tests of Active HSSC and LSSC AOVs in accordance with Mandatory Appendix IV with no exceptions. OM Code requirements for stroke time, fail safe, leak, and position indication tests were moved from Section ISTC to Mandatory Appendix IV. These tests will continue on extended intervals as described above consistent with the lifetime approval of Risk-Informed relief request A-1.

Pumps

HSSC Testing will be performed in accordance with the Code of Record as defined by 10CFR50.55a.

LSSC Testing will be performed in accordance with the Code of Record as defined by 10CFR50.55a except with a test frequency not to exceed 6 years.

Test frequencies of 2 years or less, the specified frequency for each inservice test is met if the test is performed within 1.25 times the interval specified in frequency. For staggered test frequencies greater than 2 years (typically 3 to 6 years), the specified frequency for each inservice test is met if the test is performed within 1.25 times the 18 month interval, but not to be deferred past the next refueling outage.

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ATTACHMENT TO R/R A-1

Performance Monitoring (applicable to HSSC and LSSC):

thermography of the drivers

lube oil analysis

alignment checks

motor current testing

vibration monitoring

flange loading checks of connected piping

5) Cumulative Impact

Evaluate the cumulative impact of the test fr equency changes on total plant risk (i.e., CDF and LERF) to ensure that the change in plant safety is within the acceptable range.

This will be done by performing various sensitivity studies to determine the potential risk impact of increasing in-service testing intervals simultaneously on all low risk significant components.

The unavailabilities of the IST components in the low-risk category will be increased by a factor equivalent to the proposed increase in the component test interval. For each sensitivity case, the PRA cutset results will be requantified using the adjusted component unavailabilities due to the proposed test intervals. The new total CDF and LERF for each case will be obtained. These new values will, then, be compared with the CDF and LERF of the base case to assess the net change in total plant risk due to proposed IST test frequencies.

In addition, component risk importances will be re-evaluated for the following groups of IST components to identify any components that may move up from low safety significant components to high safety significant components:

Group 1: Low FV, high RAW with credit taken for compensatory measures identified by the IDP (i.e., other surveillance tests on the same piece of equipment).

Group 2: Low FV, low RAW with no credit taken for compensatory measures because this category implies that increases in component unavailabilities are not expected to impact risk significantly.

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ATTACHMENT TO R/R A-1

Due to uncertainty in how test interval changes will actually affect the component unavailabilities, a number of conservative assumptions are made as summarized below:

It is assumed that any increase in test intervals would simultaneously impact the reliability of all IST components in the low safety-significant component (LSSC) category.

Consistent with the PRA techniques, the component unavailability required to change state, is assumed to be:

Q = OD + (T/2)

Q = total component unavailability

Where OD = Component unavailability on demand

= Component failure rate per hour

T = Interval between tests that verify operability of the component

The component unavailability is assumed to increase by the same factor as the increase in the test interval. For example, a change in the test interval from quarterly to semi-annually is assumed to increase the total component unavailability by a factor of two. This is a very conservative assumption because it assumes that not only the (T/2) term would be increased by a factor of two, but also the failure on demand term ( OD) term is assumed to be directly impacted by the change in the test interval.

Decrease in wear out due to less frequent testing is assumed to be negligible although frequent testing has been seen to cause components to be less available due to wearout.

It is conservatively assumed that all IS T tests are fully effective in finding the causes of component unavailabilities.

The PRA models will be updated to reflect the changes to the test frequency of modeled components, and the PRA study will be re-evaluated to quantify the aggregate impact of the changes. The cumulative impact of the test frequency changes will be reviewed through the IDP.

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ATTACHMENT TO R/R A-1

6) Implementation

Implementation of the RI-IST to LSSC will consist of grouping components and then staggering the testing of the group over the test frequency.

Grouping:

Components will be grouped based on:

- manufacturer

- model

- service condition

- size

The population of the group will be dependent on:

- total population available

- maintaining current testing schedule

Grouping components in this manner and testing on a staggered basis over the test frequency will reduce the importance of common cause failure modes as components in the same staggering failure mode group are continually being tested. This ensures that the component capability will be maintained over the test interval (i.e., 6 years).

Testing of components within the defined group will be staggered over the test interval, typically 6 years. Testing will be scheduled on regular intervals over the 6 year period to ensure all components in the group are tested at least once during the 6 year test interval and not all components are tested at one time. The staggering allows the trending of components in the group to ensure the test frequency selected is appropriate.

Testing will be scheduled/planned such that there is no more than one cycle between tests of components in a group.

7) Corrective Action

When a component on the extended test interval fails to meet established test criteria, corrective actions will be taken in accordance with the CPNPP corrective action program as described below for the RI-IST.

For components not meeting the acceptance criteria, an Issue Report will be generated.

This document initiates the corrective action process. Also, the initiating event for an

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ATTACHMENT TO R/R A-1

Issue Report may be from causes other than an unacceptable IST test. Programs exist that provide timely information to the IS T Engineer that the performance of a reliable component has degraded. For example, a common compensatory action for pump discharge check valves would be the IST pump test. Since this test can not be considered satisfactory if the check valve fails to perform its risk significant function, a test failure would be recorded and an Issue Report initiated. The recorded information could then be used to assess whether a significant change in component reliability has occurred such that the component would merit a change in test interval.

The initiating event could be any other indication that the component is in a non-conforming condition. The unsatisfactory condition will be evaluated to:

a) Determine the impact on system operability and take appropriate action.

b) Review the previous test data for the component and all components in the group.

c) Perform a root cause analysis.

d) Determine if this is a generic failure. If it is a generic failure whose implications affect a group of components, initiate corrective action for all components in the affected group.

e) Initiate corrective action for failed IST components.

f) Evaluate the adequacy of the test strategy. If a change is required, review the IST test schedule and change as appropriate.

The results of component testing will be provided to the PRA group for input to PRA model evaluation. (See Section 8)

For an emergent plant modification, any new IST component added will initially be included at the current Code of Record test frequency. Only after evaluation of the component through the RI-IST Program (i.e., PRA model evaluation if applicable and IDP review) will this be considered LSSC.

8) Periodic Reassessment

As a living process, components will be r eassessed at a frequency not to exceed every other refueling outage (based on Unit 1 refueling outages) to reflect changes in plant configuration, component performance test resu lts, industry experience, and other inputs to the process. The RI-IST reassessment will be completed within 9 months of completion of the outage.

Part of this periodic reassessment will be a f eedback loop of information to the PRA. This will include information such as components tested since last reassessment, number and

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type of tests, number of failures, corrective actions taken including generic implication and changed test frequencies. Once the PRA has been reassessed, the information will be brought back to the IDP for deliberation and confirmation of the existing lists of HSSCs and LCCSs or modification of these lists based on the new data. As part of the IDP, confirmatory measures previously utilized to categorize components as LSSC will be validated. Additionally, the maximum test interv al will be verified or modified as dictated by the IDP.

9) Changes to RI-IST after Initial NRC Approval

Changes to the process described above and to the evaluation of risk impact will require prior NRC approval. Changes to the categorization of components and associated testing strategies using the above proces s will not require prior NRC approval. As changes to component categorization are made, TU Electric will periodically submit them to the NRC for their information.

NRC APPROVAL Approved. Reference safety evaluation dated August 14, 1998 for STATUS Units 1 & 2.

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RELIEF REQUEST NO. P-1

Applicable Components and or System

Description:

The Vents and Drains System Safeguards Building Sump Pumps (SBSPs):

CP1-WPAPSS-01 CP2-WPAPSS-01

CP1-WPAPSS-02 CP2-WPAPSS-02

CP1-WPAPSS-03 CP2-WPAPSS-03

CP1-WPAPSS-04 CP2-WPAPSS-04

Applicable IST Requirements:

ISTB-5200, Vertical Line Shaft Centrifugal Pumps, (a) Duration of Tests, paragraph (1) states, For the Group A test and the comprehensive test, after pump conditions are as stable as the system permits, each pump shal l be run at least 2 min. At the end of this time at least one measurement or determination of each of the quantities required by Table ISTB-3000-1 shall be made and recorded.

ISTB-3540, Vibration, paragraph (b), states, On vertical line shaft pumps, measurements shall be taken on the upper motor-bearing housing in three approximately orthogonal directions, one of which is the axial direction.

ISTB-5221, Group A Test Procedure, states in part, that Group A tests shall be conducted with the pump operating as close as practical to a specified reference point and within the variances from the reference point as described in this paragraph. The test parameters shown in Table ISTB-3000-1 shall be determined and recorded as required by this paragraph.

ISTB-5223, Comprehensive Test Procedure, states in part, that Comprehensive tests shall be conducted with the pump operating as close as practical to a specified reference point and within the variances from the refe rence point as described in this paragraph.

The test parameters shown in Table ISTB-3000-1 shall be determined and recorded as required by this paragraph.

Brief Description of the Proposed Alternative:

The proposed test consists of the following: The sump will be filled to a predetermined level, and the pump will operate until the automatic low-level cutoff switch actuates. The sump will be pumped down rapidly (approximately 50 seconds) by one pump. Suction pressure will vary as sump level changes; therefore, the 2-minute stabilization time and

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differential pressure measurement are not achi evable. The test will require pumping the same quantity of fluid along a repeatable system path while measuring flow and vibration.

A baseline reference shall be established fo r flow and vibration. Alert and Required Action Limits for vibration will be established and maintained as per Table ISTB-5221-1, Vertical Line Shaft Centrifugal Pump Test Acceptance Criteria, for vertical line shaft centrifugal pumps. Vibration will be measur ed in a single direction due to the short pump run and the ability to acquire a single vibration reading during this time period. The acceptance criteria for flow will be greater than the design flow of 50 gpm. The flowrate delivered will be trended for detecting pump degradation and to ensure the SBSPs have adequate design margin.

Basis for Use:

To meet the operational readiness requirements for these pumps, a test can be performed that demonstrates the pump can meet its intended safety functions. This test would require that the pump start on the proper level switch actuation, determine that the pump is capable of delivering a minimum of 50 gpm to the Waste Holdup Tank, and have velocity-based vibration reading that is satisfactory. Differential pressure measurement is not required to show adequate pump performanc e. Differential pressure measurement creates additional radiation exposure to personnel (ALARA) because the sump is potentially contaminated. Pumping 50 gpm or more to the Waste Holdup Tank demonstrates that adequate head was developed to overcome system resistance with greater confidence that the ASME OM Code requirements, for operational readiness have been met. The required head to pump to the Waste Holdup Tank is greater than the required head to discharge to the Floor Drain Tank, which is the normal lineup.

In addition, Regulatory Guide (RG) 1.175, A n Approach for Plant-Specific, Risk-Informed Decisionmaking: Inservice Testing, states that for LSSCs, like the SBSPs, the testing may be less rigorous. This philosophy of demonstrating that the SBSPs have adequate design margin (greater than 50 gpm) is consistent with RG 1.175 testing strategy for LSSCs.

The SBSPs are small capacity pumps, compared to other pumps in the plant, with a capacity of greater than 50 gpm. The SBSPs are designed to pump a working volume and not expected to run continuously. The SBSPs run intermittently in their normal and emergency modes. They turn on following a high sump level actuation and turn off following low sump level actuation. Trending flow against the required flowrate of 50 gpm will provide adequate means of demonstrating acceptable pump operation.

The SBSPs are of low safety significance and are not explicitly modeled in the Probabilistic Risk Assessment (PRA) for internal events analysis. As stated previously, the SBSPs are installed to prevent flooding from a LOCA. Alarms associated with these pumps alert the operator of potential leakage in the Safeguards Building and mitigate the consequences of the leakage. The proposed alternate test will provide reasonable

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assurance that the sump pumps will perfo rm their intended functions and not impact the assumptions in the PRA assessment.

The basis for classifying the SBSPs as active is they mitigate continuous system leakage in the Safeguard Building at a flow rate of 1-gpm. These pumps also provide credited positive indication to the Control Room of flooding in the Safeguards Building from ESF equipment. The performance requirements for these pumps are unlike any other pumps in the Risk-Informed Inservice Testing Plan. These pumps are not required to provide a significant flow at a required head to prevent or mitigate any accident or maintain the plant in a safe shutdown condition. Modificati ons to enable testing in compliance with the ASME OM Code would not result in an increase to safety.

The proposed alternate test simulates expected pump operation and demonstrates the pumps' capability to meet the unique performance requirements of these pumps.

Performance of this test will clearly demon strate that the pumps can achieve their intended safety functions. There is no change to the design functions of the sump pumps. This proposed alternative impacts the testing criteria and does not impact the safety analysis as described in the Final Safety Analysis Report (FSAR).

Describe the Hardship or Unusual Difficulty:

The Safeguards Building sump does not contain sufficient water inventory for the 2-minute duration at 80% or greater design flow as required by ISTB-5200(a)(1). The sump pumps are not designed with a recirculation line (mini-flow or test header) that allows a pump to be run continuously at design flow conditions. Due to the limited volume of water, the sump is emptied in approximately 50 seconds. The pumps do not have time to stabilize and subsequently CPNPP cannot meet the ASME OM ISTB-5200(a)(1) requirements.

Direct access to the SBSPs would be a significant burden since they are inside the sump and the sump is covered by a 1-inch thick steel plate. To run the pumps for greater than 50 seconds would require opening the sump and running water from a demineralized water source with temporary hoses. Performing this test would incur significant effort.

The man-hours estimated to remove the plate, run demineralized water, and re-establish the design configuration is approximately 50 man-hours for each pump test versus approximately 9 man hours for the proposed pump run of approximately 50 seconds.

Since the pumps are under a 1-inch thick steel plate, only the motors are accessible by workers. These are small motors with only one location for horizontal (MH), vertical (MV),

and axial (MA). Motor inboard horizontal (MIH) and motor outboard horizontal (MOH) are the same point, MH. Hence, only the MH measur ement (i.e., MIH), is taken for vibration.

The 1-inch thick steel plate is stiff and will dampen any vibrations. The trending of three vibration readings at the same location would not provide any additional trending information beyond the current single MH measurement. During normal operations,

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these pumps are not used continuously. Therefor e, the use of a single vibration reading as proposed by CPNPP, is an acceptable alte rnative to the ISTB-3540(b) requirement to measure vibration in three directions.

In addition, the SBSPs are located in a radiological area of the plant at elevation (EL.)

773, in both units. The radiological dose in the room will vary depending on what waste has been discharged into the sumps. If the waste is very radioactive, then the dose rate for workers performing the test could be high. More importantly; however, removing the steel access plate to access the sump will significantly increase the risk of worker contamination, since the sumps are highly contaminated.

There are no plant installed pressure or differential pressure instruments on the suction or discharge of the SBSPs. Previously, the SBSPs were tested by setting flow at 0 gpm (i.e., deadhead the pump) and differential pressure was calculated. The suction pressure was calculated by measuring an elevation between the sump cover and water level within the sump. This method was abandoned due to the concerns of the sump potentially being contaminated thereby keeping expos ures as low as reasonably achievable (ALARA). The test method of dead heading the SBSPs is adverse to the condition of the pumps and is no longer performed.

The design of the SPSPs was previously reviewed and it was determined that significant modifications would have to be performed without any appreciable benefit to safety to enable testing in compliance with ASME OM ISTB-5200(a)(1), ISTB-5221, ISTB-5223, and ISTB-3540(b).

NRC Approval Status:

The NRC staff authorized the use of Proposed Alternative P-1 at Comanche Peak, Units 1 and 2, for the fourth 10-year interval IST program for Comanche Peak, Units 1 and 2, which begins on May 22, 2024, and ends on August 2, 2033. [ML23121A220]

COMANCHE PEAK - UNITS 1 AND 2 A-29 Rev. 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

FOURTH INTERVAL REVISION 0:

LDCR-IT-2023-001 (EV-TR-2022-006138-7) (KLB):

Referenced Section: IST Plan Tabl e 4 - CHEMICAL AND VOLUME CONTROL

Description of Change: Move valve CS-8442 from Group 22 to new CVCM Group X-1, Piston Check Valve/Self-Actuating, Edwards Model D36274(F316)JT1 with only valves (1&2)CS-8442 in the group and changing exercise test from CV/6YR & CVD/8YR to CV/18MO and DD/5YR adding reference to Note 3 and deleting reference to Note 1.

Technical Justification: These changes implement new CVCM groups in accordance with ASME OM Code Appendix II. The Appendix allows the optimization of testing activities and frequencies provided a thorough evaluati on and continued monitoring of applicable trendable check valve testing attributes is per formed. This check valve testing method is approved by the OM Code and endorsed by 10CFR50.55a with specific conditions. The 10CFR50.55a conditions are implemented per IST-304. The CVCM Plans are developed and approved per IST-304 and are available for review (EV-TR-2022-006138-6). Note 1 is no longer applicable since staggered testing is to be implemented per the CVCM Plan rather than the A-1 Risk Informed relief request.

The remaining RI-IST check valve group 22, which lost valves CS-8442 to CVCM group X-1, has a sufficient number of valves to support extended frequency testing on a staggered test basis per Relief Request A-1 and continues to meet the requirements of the Risk Informed Relief Request A-1.

Referenced Section: IST Plan Table 5 - CONTAINMENT SPRAY

Description of Change: Create new CVCM Group 1-6 / 2-6, Swing Check Valve/

Self-Actuating, Borg Warner Model 75810 with valves CT-0142, CT-0145, CT-0148, &

CT-0149 in the group and changing exercise test from CVD/8YR to CV/16YR adding reference to Note 4, and deleting reference to Notes 1 & 2. Delete Note 2.

Technical Justification: These changes implement new CVCM groups in accordance with ASME OM Code Appendix II. The Appendix allows the optimization of testing activities and frequencies provided a thorough evaluati on and continued monitoring of applicable trendable check valve testing attributes is per formed. This check valve testing method is approved by the OM Code and endorsed by 10CFR50.55a with specific conditions. The 10CFR50.55a conditions are implemented per IST-304. The CVCM Plans are developed and approved per IST-304 and are available for review (EV-TR-2022-006138-3). Note 2 is no longer applicable since the sample di sassembly examination program is being discontinued. Note 1 is no longer applicable since staggered testing is to be implemented per the CVCM Plan rather than the A-1 Risk Informed relief request.

The remaining RI-IST check valve group 28, which lost the valves to CVCM group 1-6 /

2-6, has a sufficient number of valves to support extended frequency testing on a staggered test basis per Relief Request A-1 and continues to meet the requirements of the Risk Informed Relief Request A-1.

CPNPP/IST DOC-1 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-001 (EV-TR-2022-006138-7) (KLB) (continued):

Referenced Section: IST Plan Table 7 - DIESEL GENERATOR AUXILIARIES

Description of Change: Change Group 113 to CVCM Group 1-7 / 2-7. Change the exercise test interval for each of the valves (DO-0049, 1DO-0050, and 2DO-0052) from CV/6YR and CVD/8YR to CV/18MO and DD/12YR adding reference to Note 3 and deleting reference to Note 1. Add Note 3: A Check Valve Condition Monitoring Plan has been established per ASME OM Code Appendix II for valves in this group.

Technical Justification: These changes implement new CVCM groups in accordance with ASME OM Code Appendix II. The Appendix allows the optimization of testing activities and frequencies provided a thorough evaluati on and continued monitoring of applicable trendable check valve testing attributes is per formed. This check valve testing method is approved by the OM Code and endorsed by 10CFR50.55a with specific conditions. The 10CFR50.55a conditions are implemented per IST-304. The CVCM Plans are developed and approved per IST-304 and are available for review (EV-TR-2022-006138-4).

Referenced Section: IST Plan Table 8 - FEEDWATER

Description of Change: Change Group 42 to CVCM Group 1-8 / 2-8. Change the exercise test interval for each of the valves (FW-0070, FW-0076, FW-0082, and FW-0088) from CVD/8YR to CV/16YR adding reference to Note 4 and Note 6 and deleting reference to Note 1 and 2. Delete Note 2, and Revise Note 6 to state: A Check Valve Condition Monitoring Plan has been established per ASME OM Code Appendix II for valves in this group.

Technical Justification: The group name, exercise interval changes and references to Notes 4 and 6 implement a new CVCM Plan in accordance with ASME OM Code Appendix II. The Appendix allows the optimization of testing activities and frequencies provided a thorough evaluation and continue d monitoring of applicable trendable check valve testing attributes is performed. This check valve testing method is approved by the OM Code and endorsed by 10CFR50.55a with specific conditions. The 10CFR50.55a conditions are implemented per IST-304. The CVCM Plans are developed and approved per IST-304 and are available for review (EV- TR-2022-006138-5). Note 2 is no longer applicable since the sample disassembly examination program is being discontinued.

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB):

Referenced Section: Throughout

Description of Change: General editorial changes which update to ASME OM Code 2017 Edition, update to the Fourth Interval Rev. 0, note the location of the Snubber test program, correct misspelling errors, update references due to reorganization of 10CFR50.55a, update/add/revise test requirements consistent with OM-2017.

CPNPP/IST DOC-2 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Technical Justification: OM-2017 is adopted per 10CFR50.55a(f)(4)(ii). On February 3, 2022 (18-months prior to the start of the fourth interval) ASME OM-2017 was the latest edition of the OM Code approved by the NRC in 10CFR50.55a(a)(1)(iv). The 2017 Edition was incorporated by reference on June 3, 2020 (Agency/Docket Number NRC-2016-0082). The 2020 Edition of the ASME OM Code was not incorporated by reference until November 28, 2022 (Agency/Docket Number NRC-2018-0290). There are no commitments affected, nor is safety impacted by these changes.

Referenced Section: 2.1 Scope and 3.1 Scope

Description of Change: Expand scope of IST Program by deleting ASME Class 1, 2 and 3 and adding reference to the final rule and the site review for additional IST Program scope documented in AI-TR-2021-002083-5.

Technical Justification: On August 17, 2017, the final rule published in the Federal Register on July 18, 2017 (82 FR 32934) o fficially expanded the scope of IST programs beyond ASME Class 1, 2, and 3 pumps and valves to the pumps and valves within the scope of the ASME OM Code while allowing non-ASME class pumps and valves in the scope of the ASME OM Code to be test ed under an Augmented IST Program. This change enhances nuclear safety as it officially expands the applicability of the ASME OM Code to additional components. There are no commitments affected by these changes.

Referenced Section: INSERVICE VALVE TESTING PLAN

Description of Change: Add reference to TABLE 20 where applicable.

Technical Justification: TABLE 20 - Air Operated Valves was added to consolidate new Mandatory Appendix IV test requirements. There are no commitments affected, nor is safety impacted by these changes.

Referenced Section: TABLE 0 - INSERVICE PUMP TESTING PLAN

Description of Change: Add sentence to Note 3: OM Code deviations for these pumps are approved per EV-TR-2021-006046-1. Add Note 6: PPVT requires only flow and differential pressure measurement.

Technical Justification: These Non-ASME pumps are allowed per 10 CFR 50.55a(f)(4) to be tested using an augmented IST Program that does not meet ASME OM Code requirements provided the basis for any devi ations from the OM Code demonstrates an acceptable level of quality and safety, or that implementing the Code provisions would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, where documented and available for NRC review. The referenced evaluation documents that the alternate test demonstrates an acceptable level of quality and safety and that implementing the Code pr ovisions would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The referenced document (EV-TR-2021-006046-1) sa tisfies the regulatory requirement and is available for NRC review. Since it has no impact on testing, this change is administrative in nature and has no impact on nuclear safety or any commitments.

CPNPP/IST DOC-3 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

ASME OM-2017 does not require vibration measurements during the PPVT, so this note clarifies which parameters are required to be measured during a Periodic Pump Verification Test (PPVT) and has no impact on nuclear safety or commitments.

Referenced Section: TABLE 1 - AUXILIARY FEEDWATER

Description of Change: Revise Exercise Test descriptions for valves in groups X-6, 1-19, X-15, 2-19, 1-5, 2-5, X-8, X-9, and 3 consistent with the definitions of CV and DD in the Valve Table Index. Add Note 5 to the Group 3 check valves

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. Additional Note 5 is required per ISTC-9200(d) which requires bases for testing series check valve pairs as a unit per ISTC-5223. New Note 5 provides the following basis: All of the Group 3 check valves are installed in pairs providing isolation of the safety class 3 air accumulators to non-nuclear safety instrument air piping. This configuration is required by ANSI N18.2a to isolate the safety class from the non-safety class. Only one valve is required to close and limit back-leakage (depressurization of the accumulator) because failure of a pair of check valves to close would only affect the function of one of two redundant trains. Theref ore, failure of the series pair would not prevent the fulfillment of a safety function, and each pair is allowed to be tested as a unit per ISTC-5223. This is an administrative change that has no impact on nuclear safety or commitments.

Referenced Section: TABLE 2 - COMPONENT COOLING WATER

Description of Change: Revise Exercise Test descriptions for valves in groups 1-12, X-5, 105, 13, and 14 consistent with the definiti ons of CV and DD in the Valve Table Index.

Add Note 5 to the Group 105 check valves.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. The addition of Note 5 is required per ISTC-9200(d) which requires bases for testing series check valve pairs as a unit per ISTC-5223. New Note 5 provides the following basis: All of the Group 3 check valves are installed in pairs providing isolation of the safety class 3 air accumulators to non-nu clear safety instrument air piping. This configuration is required by ANSI N18.2a to isolate the safety class from the nonsafety class. Only one valve is required to close and limit back-leakage (depressurization of the accumulator) because failure of a pair of check valves to close would only affect the function of one of two redundant trains. Theref ore, failure of the series pair would not prevent the fulfillment of a safety function, and each pair is allowed to be tested as a unit per ISTC-5223. This is an administrative change that has no impact on nuclear safety or commitments.

CPNPP/IST DOC-4 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Referenced Section: Table 2 - Component Cooling Water

Description of Change: Revise Note 2 to clarify that the fail-safe safety function must be tested per ISTC-5100 and IV-3430.

Technical Justification: The previous revision incorrectly identified the valves as being exempt under the control valve exemption, but correctly identified the need to perform testing of its safety related fail open function. The revision is editorial in nature since correction of the error had no impact on the test requirements.

Referenced Section: TABLE 3 - CHILLED WATER (SAFETY AND NON-SAFETY)

Description of Change: Revise Exercise Test descriptions for valves in groups X-3 and 1-3 / 2-3 consistent with the definitions of CV and DD in the Valve Table Index.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected.

Referenced Section: TABLE 4 - CHEMICAL AND VOLUME CONTROL

Description of Change: Revise Exercise Test descriptions for valves in groups X-11, X-20, 22, and 23 consistent with the definitions of CV and DD in the Valve Table Index.

Add the Close position to the safety function position column for valves XCS-0037/0039/

0041/0044.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. Add the Close position because these valves communicate with the minimum flow line from an opposite unit boric acid trans fer pump. Therefore, the valves would be required to close on a pump failure to start to prevent diversion of flow in lieu of being directed to the boric acid blender. These are administrative changes as they have no impact on testing requirements.

Referenced Section: TABLE 6 - DEMINERALIZED & REACTOR MAKEUP WATER

Description of Change: Revise Exercise Test descriptions for valves in groups X-7, X-4, X-10, and 33 consistent with the definitions of CV and DD in the Valve Table Index.

Change XDD-0044 CV/3YR test frequency to CV/6YR.

CPNPP/IST DOC-5 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. XDD-0044 has a LOW risk rank, and since it is properly grouped with similar components and tested on a staggered test basis, risk-informed relief request A-1 allows extension of the interval to 6 years. This change is further justified in EV-CR-2018-006513-9 and has no impact on nuclear safety or commitments.

Referenced Section: TABLE 7 - DIESEL GENERATOR AUXILIARIES

Description of Change: Revise Exercise Test descriptions for valves in group 37 & 38 consistent with the definitions of CV and DD in the Valve Table Index.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected.

Referenced Section: TABLE 8 - FEEDWATER

Description of Change: Revise Exercise Test descriptions for valves in group 1-8 / 2-8 and 2-17 consistent with the definitions of CV and DD in the Valve Table Index.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected.

Referenced Section: TABLE 9 - MAIN STEAM

Description of Change: Revise Exercise Test descriptions for valves in group 48 consistent with the definitions of CV and DD in the Valve Table Index. Add Note 5 to the Group 48 check valves.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. Note 5 is required per ISTC-9200(d) which requires bases for testing series check valve pairs as a unit per ISTC-5223. New Note 5 provides the following basis: All of the Group 3 check valves are installed in pa irs providing isolation of the safety class 3 air accumulators to non-nuclear safety inst rument air piping. This configuration is required by ANSI N18.2a to isolate the safety class from the non-safety class. Only one valve is required to close and limit back-leakage (depressurization of the accumulator) because failure of a pair of check valves to close would only affect the function of one of two redundant trains. Therefore, failure of the series pair would not prevent the fulfillment of a safety function, and each pair is allowed to be tested as a unit per ISTC-5223. This is an administrative change that has no impact on nuclear safety or commitments.

CPNPP/IST DOC-6 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Referenced Section: TABLE 10 - REACTOR COOLANT

Description of Change: Revise Exercise Test descriptions for valves in group 108 consistent with the definitions of CV and DD in the Valve Table Index. Add to Note 2 a justification for testing series check valves in pairs.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. Note 2 is required per ISTC-9200(d) which requires bases for testing series check valve pairs as a unit per ISTC-5223. The addition to Note 2 provides the following basis: These check valves are installed in pairs providing isolation of the safety class 3 nitrogen accumulators to non-nuclear safety nitrogen supply header. This configuration is required by ANSI N18.2a to isolate the safety class from the non-safety class. Only one valve is required to close and lim it back-leakage (depressurization of the accumulator) because failure of a pair of check valves to close would only affect the function of one of two redundant trains. Theref ore, failure of the series pair would not prevent the fulfillment of a safety function, and each pair is allowed to be tested as a unit per ISTC-5223. This is an administrative change that has no impact on nuclear safety or commitments.

Referenced Section: TABLE 13 - SAFETY INJECTION

Description of Change: Revise Exercise Test descriptions for valves in groups 1-2 / 2-2, 1-1 / 2-1, and 63 consistent with the definiti ons of CV and DD in the Valve Table Index.

For valves 8949A and D, change the Note 5 reference for the CV/RF refueling outage justification to Note 3.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. Changing the reference corrects a minor error and is administrative in nature.

Note 5 refers to the 8949B&C valves, not the 8949A&D series valves which are addressed in Note 3.

Referenced Section: TABLE 15 - VENTILATION (CONTROL ROOM AIR CONDITIONING)

Description of Change: Revise Exercise Test descriptions for valves in group 106 consistent with the definitions of CV and DD in the Valve Table Index.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected.

CPNPP/IST DOC-7 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Referenced Section: TABLE 17 - MISCELLANEOUS CONTAINMENT ISOLATION VALVES

Description of Change: Revise Exercise Test descriptions for valves in group 70 consistent with the definitions of CV and DD in the Valve Table Index. Add PIT/6YR and Note 4 to valves BS-0025 and BS-0030.

Technical Justification: Exercise Test descriptions incorrectly described the test requirements - CV is for the safety function direction, and DD is for the non-safety direction. This is an editorial change for accuracy as actual test implementation is not affected. Valves BS-0025 and BS-0030 have remote position indicators and require a PIT on a 6YR interval (for this 4-valve group). Since the required observation of valve operation is satisfied during normal operat ion of the personnel air lock and audible indication provides adequate supplemental position verification, Note 4 for Valves in Regular Use applies. Since the testing has been accomplished during normal operations, this is an administrative change that has no impact on nuclear safety or commitments.

Referenced Section: TABLE 18 - SAFETY & RELIEF VALVES

Description of Change: For the Group 90 relief valves, remove the reference to Note 1.

Technical Justification: DO-0123, DO-0129, DO-0223, and DO-0229 are Code Class 3 valves that are required to open to protect the EDG starting air receivers from overpressure which could be caused by a malfunction of the non-safety related air compressor or its controls - not just thermal expansion. Therefore, the valves are not simply thermal relief valves. Since the event which would require the valves to open is not an accident, the passive function designation is still applicable consistent with FSAR Tables 3.9N-10 and 3.9B-10. Note that the active/passive designation has no impact on inservice test requirements specified by ASME OM Mandatory Appendix I.

Referenced Section: Table 18 - SAFETY & RELIEF VALVES

Description of Change: Delete Table 18 Note 2.

Technical Justification: Relief valves 8708A and 8708B are pressure relief devices that protect the RHR system and RCS - both of which are systems which perform one or more of the three IST functions. Therefore, they are not exempt from the requirements of the ASME OM Code. Thus, the previous note was incorrect. This is an administrative change as it has no impact on test requirements.

Referenced Section: TABLE 19 - MOTOR OPERATED VALVES

Description of Change: Add the open safety function O designation to valves HV-2491A&B, HV-2492A&B, HV-2493A&B, HV-2494A&B, 8924, 8812A&B, 8806, 8923A&B, 8814A&B, 8813, 8512A&B, HV-4758, and HV-4759. Add PIT/6YR requirement to HV-5540/5541/5542/5543/5562/5563.

CPNPP/IST DOC-8 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Technical Justification: Each of the listed valves perform an open safety function to mitigate the consequences of an accident. The error appears to have occurred when only the position for which the valve is consi dered active was listed. This change corrects the error and is administrative in nature as it has no impact on test requirements.

Regarding the addition of the PIT/6YR requireme nt, each of the listed valves are passive MOVs which are equipped with remote position indication. Since the valves are passive and not subject to diagnostic testing (which normally accomplishes the PIT for MOVs),

these valves require a separate PIT per ISTC-3 700. As Low Risk Rank valves that are appropriately grouped, the RI-IST Program allows extension of the PIT frequency to 6 years. Since the PIT is being met by performance of OPT-113A&B, this is an administrative change that has no impact on nuclear safety or commitments.

Referenced Section: Table 19 - MOTOR OPERATED VALVES

Description of Change: Revise Note 1 consistent with OM-2017, III-3310 Inservice Test Interval

Technical Justification: Initial and extended MOV diagnostic test intervals in the Third interval were in accordance with Relief Request V-1. RR V-1 expires at the end of the Third interval. OM-2017 Mandatory Appendix III specifies inservice test intervals for Active MOVs and is required to be implemented by 10 CFR 50.55a. The new initial inservice interval is being changed to a fixed interval which is shorter than the original initial inservice test interval authorized under RR V-1. This change has no impact on extended MOV diagnostic test intervals. This change affects commitment 27136 which credits MOV testing per OMN-1 to satisfy GL 96-05. Commitment Material Change Evaluation 23-002 supports a revision to the commitment which credits MOV testing per Appendix III to satisfy GL 96-05. This change has no safety impact.

Referenced Section: Table 19 - MOTOR OPERATED VALVES

Description of Change: Added Note 6 to HIGH risk rank MOVs: See the cumulative risk assessment referenced in the latest revision of ER-EA-010 for an evaluation that confirms the potential increase in core damage frequency (CDF) and large early release (LER) associated with a longer MOV exercise interval is small.

Technical Justification: Documents satisfaction of OM-2017 requirement found in III-3721: HSSC MOVs that can be operated during plant operation shall be exercised quarterly, unless the potential increase in core damage frequency (CDF) and large early release (LER) associated with a longer exercise interval is small. This is an administrative change providing a reference to an existing evaluation.

CPNPP/IST DOC-9 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Referenced Section: TABLE 20 - AIR OPERATED VALVES

Description of Change: Create new table for all air operated valves so that all Mandatory Appendix IV test requirements may be presented in one table. Move all air operated valves in the IST Program and the applicable notes to Table 20. Change the Category designation of valves 8875A, B, C, &D from Category B to Category A and add reference to note 10 by replacing the N/A for leak test with LT/(10). Add Note 10: 8875A/B/C/D function in the course of plant operation in a manner than demonstrates functionally adequate seat leak-tightness such that additional leak testing is not required. Add valves FCV-0121 and HCV-0182 to Table 20 as passive, category B valves with only FO/6YR test requirements.

Technical Justification: Mandatory Appendix IV created a new performance assessment test, so a table similar to Table 19 for MOVs is needed to support specification of the new test requirement. Although the 8875 series valv es do not have a specific leak rate limit, gross leakage from this valve could exceed the total system leak rate limit of 10 psi/hr (See OPEV for CR-2014-0013741) such that the Category A valve designation is appropriate. Note 10 is appropriate because Control Room Operator surveillances, accumulator pressure indication, and alarms provide adequate operational observations of leak tightness; therefore, additional leak testing is not required per ISTC-3610. Valves FCV-0121 and HCV-0182 were identified as having open safety functions in support of emergency boration. Since these valves are nor mally open supporting a flow rate greater than 30 gpm, it is appropriate to consider the valves as passive valves that maintain obturator position and are not required to change obturator position to accomplish the required function. Since these valves are passive and do not have remote position indicators, no other testing is required. These changes are either administrative in nature or add testing requirements; therefore, there is no impact on nuclear safety.

Commitments are not affected.

Referenced Section: Appendix A, Relief Request P-1

Description of Change: Replace the description of relief request P-1 with the new description provided in the attached mark-up.

Technical Justification: The previous relief request expires at the end of the 3rd interval, and a new relief request was submitted (TXX-22064) and approved (ML23121A220) for the 4th interval. There are no commitments affected and no safety impact due to this change as the new relief request authorizes the same alternative pump test due to the same hardship.

Referenced Section: Appendix A, Relief Request A-1

Description of Change: Revise the Testing Philosophy for Motor Operated Valves (MOVs) replacing OMN-1 with Mandatory Appendix III, and add a note describing the change.

CPNPP/IST DOC-10 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Technical Justification: Relief Request A-1 is the Risk-Informed relief request which the NRC granted CPNPP to implement for the lifetime of the plant. In the A-1 relief request, CPNPP confirmed the intent to implement alternative Code Case OMN-1 Rev. 1 (previously approved for use under relief request V-1 in the third interval which was originally submitted in parallel with the A-1 relief request). Unlike A-1, the V-1 relief request has expired. Code Case OMN-1 Rev.1 has been incorporated into the ASME OM Code as Mandatory Appendix III which allows a Risk-Informed approach to support testing on extended intervals. Therefore, in the Fourth Interval, testing of HSSC and LSSC Active MOVs will be performed in accordance with OM-2017 Mandatory Appendix III based on risk ranking input from the Risk-Informed IST Program approved per CPSES-9804610. RR A-1 and Mandatory Appendix III are compatible, and the 10-year maximum MOV diagnostic test interval cannot be extended without approval and implementation of a new Risk-Informed process. Since Mandatory Appendix III only applies to Active MOVs, Passive HSSC MOVs will continue to be tested per ISTC-3500-1, and Passive LSSC MOVs will continue to be tested per ISTC-3500-1 except with test frequencies not to exceed 6 years. This change from OMN-1 to Appendix III affects commitment 27136 which credits MOV testing per OMN-1 to satisfy GL 96-05. Commitment Material Change Evaluation 23-002 supports a revision to the commitment which credits MOV testing per Appendix III to satisfy GL 96-05. Mandatory Appendix III adds requirements to evaluate the impact of changes to PMs of Active MOVs

- enhancing nuclear safety. Therefore, the change is acceptable.

Referenced Section: Appendix A, Relief Request A-1

Description of Change: Revise the note following the Air Operated Valves testing philosophy to address the impact of implementing Mandatory Appendix IV on the Risk-Informed Air Operated Valves (AOVs) testing philosophy.

CPNPP/IST DOC-11 Revision 0 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2023-002 (EV-TR-2020-003923-20) (KLB) (continued):

Technical Justification: The previous note described that CPNPP is participating in a tailored collaboration project with EPRI to develop an AOV program similar to the MOV Program mandated by GL 89-10 and 96-05. OM-2017 establishes new requirements for the AOV Program, and CPNPP has revised the AOV program to implement the performance assessment tests required by OM-2017 Mandatory Appendix IV. In addition to the previous AOV test requirements from the 2004 Edition with 2006 Addenda (stroke time, fail safe, leak rate, and position indica tion tests), OM-2017 Mandatory Appendix IV specifies a new test called the performance assessment test with an allowance to apply risk-informed methods to determine the inservice test interval for only the new performance assessment test. OM-2017 Mandatory Appendix IV does not provide an allowance to apply risk-informed methods to extend the inservice test intervals of the stroke time, fail safe, leak rate, or posi tion indication tests previously required under ISTC. However, in accordance with the lifetime approval of relief request A-1 (ref. CPSES-9804610), in the Fourth interval, CP NPP will continue to apply risk-informed methods to extend the inservice test intervals of the stroke time, fail safe, leak rate, and position indication tests as originally described in the A-1 relief request AOV testing philosophy. Passive HSSC AOVs will continue to be tested per ISTC-3500-1 at intervals specified by the OM Code, and Passive LSSC AOVs will continue to be tested per ISTC-3500-1 except with a test frequency not to exceed 6 years. This change adds requirements for AOV diagnostic testing - enhancing nuclear safety and has no impact on commitments.

CPNPP/IST DOC-12 Revision 0

CP-202400235, (Cpnpp), Units 1 & 2, Inservice Testing Plan for Pumps & Valves Fourth Interval, Revision 0

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