Text

(Cpnpp), Units 1 & 2 Inservice Testing Plan for Pumps & Valves Third Interval, Revision 5
	ML24178A443
Person / Time
Site:	Comanche Peak
Issue date:	06/26/2024
From:	Hicks J; Vistra Operations Company
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	CP-202400253, TXX-24053
	Download: ML24178A443 (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-202400253 TXX-24053 June 26, 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 Third Interval , Revision 5

Dear Sir or Madam:

Pursuant to 10 CFR 50 .55a, 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 third ten-year 1ST interval, Revision 5 . This copy of the 1ST plan is being supplied for information only .

The start date of the third interval of the In service Testing Plan for CPNPP , Units 1 and 2 was August 3 , 2013.

Revision 5 was effective April 29 , 2024 . The Third interval was superseded by the Fourth interval on May 22 , 2024.

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 Third Interval , Revision 5

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 THIRD 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 THIRD INTERVAL EFFECTIVE LISTING FOR SECTIONS, TABLES, AND FIGURES

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

Revision 0 August 3, 2013 Revision 1 February 24, 2014 Revision 2 February 26, 2015 Revision 3 October 31, 2019 Revision 4 April 29, 2021 Revision 5 April 25, 2024

CPNPP/IST EL-1 Revision 5 CPNPP/IST

Section 1 Revision 0

Section 2 Revision 3

Table 0 Revision 0

Section 3 Revision 0

Valve Table Index Revision 4

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

Appendix A Revision 4

EL-1 Revision 5 EL-2 Revision 5

CPNPP/IST EL-2 Revision 5 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

APPENDIX A RISK INFORMED RELIEF REQUEST FOR PUMPS AND VALVES ........................ A-1 RELIEF REQUEST FOR SAFEGUARDS PUMPS ............... ..................................... P-1 RELIEF REQUEST FOR INSERVICE TEST FREQUENCY ..................................... T-1 RELIEF REQUEST FOR MOVs ........................... ..................................................... V-1

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

1.0 GENERAL INFORMATION

1.1 Introduction

Inservice Testing Plan for Pumps & Valves, hereafter referred t o as the IST Plan, has been prepared to summarize the test program for certain pum ps and valves pursuant to the requirements of the Code of Federal Regulations ,

10CFR50.55a(f)(4); and as modified by Relief Request A-1, Requ est for Alternative from 10CFR50.55a(f)(4)(i) and (ii) for Inservice Te sting 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 verify the control st atus of their copy prior to use. To obtain a copy of this document, contact Distr ibution Control at the Main Document Control Center. An electronic copy can be accessed via CPNPP Electronic License Basis Documents (CPNPP ELBD).

1.2 Code Edition and Addenda

This IST Plan meets the requirements of the ASME OM Code 2004 Edition through 2006 Addenda, except in specifically identified instanc es where an alternative to the Code requirements is proposed or where it ha s been determined that conformance with certain Code requirements is impractical. In these instances, a request for relief from the Code requirement(s), i ncluding proposed alternatives to the requirement(s), has been prepared for Nucle ar Regulatory Commission review and approval pursuant to 10CFR50.55a(a)(3) or (f)(5).

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 CP NPP Unit 1 before that unit was returned to power following the third refu eling outage. This superceded 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 y ear test interval for 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 te n year test interval for Unit 2 (August 3, 2003).

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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 exten ded from August 2, 2003 to not later than August 2, 2004 (see TXX-03075, dated Apr il 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 i n 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 Au gust 3, 2004, and the end date for the second interval is August 2, 2013 (see TXX -04134).

The current start date of the third interval IST Plan for Unit 1 and Unit 2 is August 3, 2013, and the end date for the third interval is August 2, 2 023.

1.4 Approval Status

The first interval IST Plan was submitted to the NRC staff on J uly 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 contained in Appendix A of th is 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 NURE G-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 r equirements of the Code. (Approval had not specifically been requested to test Unit 2 to the requirements of the 1989 Code since regulation 10CFR50.5 5a already seemed to permit it; approval was granted nonetheless.)

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

3. Approval of the Relief Requests contained in Appendix A of th is 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 info rmation.)

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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 containe d 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, 10CFR50.55a, Codes and Standard s.

2. ASME OM Code 2004 Edition, through 2006 Addenda Code for Operation and Maintenance of Nuclear Power Plants.

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

4. USNRC, Minutes of the Public Meetings on Generic Letter 89-0 4, October 25, 1989.

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

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

7. NUREG-0800, USNRC Standard Review Plan, July 1981. (Sectio n 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 1 Guidelines for Inservice Testing at N uclear Power Plants.

10. USNRC Letter dated August 14, 1998, Approval of Risk-Informed Inservice Testing (RI-IST) Program for Comanche Peak Steam Elec tric 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 th e requirements of ASME OM Code 2004 Edition through 2006 Addenda, as modified by 10CFR50.55a(f)(4). As modified by Risk Informed IST Program Pl an and previously NRC approved by Relief Request A-1. The pumps selec ted for inclusion in this testing plan are that ASME Class 1, 2 and 3 p umps which are provided with an emergency power source and are:

a) Required in shutting down a reactor to the safe shutdown cond ition, 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 un it and the pump bearings are in the driver, and

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

c) Skid mounted pumps that are tested as part of the major compo nents 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.

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 Refe rences 1.5.2, 1.5.8 and 1.5.9 was used to the greatest extent possible in for matting 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 nou n 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 Fl ow Diagram M1-0200, Mechanical Symbols and Notes, for a discussio n of pump numbering conventions and abbreviations. The pump names and

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pump numbers shown in Table 0 are the same names and numbers us ed on the respective flow diagrams to identify the pumps.

2. Flow Diagram Number - The flow diagram number field indicates on whic h drawing the pump may be found. The flow diagram numbers are pr efixed 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 numbe r.

3. Code Class - The code class field indicates the ASME Boiler a nd 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 Cod e 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 posit ive displacement. Centrifugal pumps are further classified by the pump/driver arrangement and positive displacement pumps are further classif ied 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 drive r 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 na me 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 shaf t 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 pum p. This pump has a short pump shaft, and has an accessible inboard bear ing housing near the coupling end of the pump; the pump shaft and s uction areas are inaccessible due to being submerged.

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

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

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 geomet ry of the pump casing and rotor(s).

5. Test Parameters - The test parameters field indicates those q uantities which the Code requires to be established or determined at each inservice test. The test parameters include speed, discharge pressure, d ifferential pressure, flow rate and bearing vibration. Vibration is further classified as pump bearing vibration and driver bearing vibration. Not all t est parameters are applicable to all pumps. Rather, the parameters to be established or determined for any pump are dependent on the pum p type and are specified per the requirements of ASME OM Code 2004 Edi tion, through 2006 Addenda, Subsection ISTB. In Table 0, Code requir ed test parameters are indicated with an X. Test parameters which ar e not applicable to a particular pump are indicated N/A. Required test parameters for which relief is requested are indicated by a foo tnote 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 frequen cy of inservice tests for each pump in the RI-IST 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 2004 Ed ition, through 2006 Addenda, Subsection ISTB-3400, and are indicated i n Table 0 by 3 MO. High Safety Significant pumps lacking required fl uid inventory (e.g., pumps in dry sumps) are tested at least once e very two years per the requirements of ASME OM Code 2004 Edition, throug h 2006 Addenda, Subsection ISTB-3400, 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 cont inuously or routinely during normal operation, cold shutdown, or refueli ng operations as defined by ISTB-5121, 5221 and Table ISTB-3000-1.

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

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

When a Group A test is required, a comprehensive test may be substituted. When a Group B test is required, a Group A or comprehensive test may be substituted. A preservice test may be substituted for any inservice test. As allowed by ASME OM Code edition 2004 through 2006 addenda, 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. 1 of the 2012 Edition of the ASME OM Code supplemented by Figure 1 of OMN-16 that is in the 2006 Addendum of the OM Code.

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 Plan is derived from t he requirements of ASME OM Code 2004 Edition through 2006 Addenda, Subsection ISTC ,

Appendix I and Appendix II 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 ASME Class 1, 2 and 3 valves and pressure rel ief devices (and their actuating and position indicating systems) which are requ ired 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, drai n, instrument and test valves, or

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

c) Valves used only for system or component maintenance.

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

e) Category A and Category B Safety and Relief Valves are exclud ed 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 t his testing plan are described in the CPNPP Final Safety Analysis Report (FSAR), Sec tions 3.9N.3.2 and 3.9B.3.2, Pump and Valve Operability Assurance, and are t abulated in FSAR Tables 3.9N-10 and 3.9B-10, Active Valves. ASME Code Cl ass 2 and 3 pressure relief devices that only protect systems/components th at perform a safety function as described above are not tabulated in FSAR Ta bles 3.9N-10 and 3.9B-10. These valves will continue to be tested within the re quired test interval of 10 years during the third interval. Consistent with the philos ophy discussed in Reference 1, these specific thermal relief valves do not requir e the two additional valve tests following as-found set-pressure determination failu res. However, if

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performance data indicates that more frequent testing is needed to assure valve function, then the testing frequency should be modified. In lieu of tests, valve replacement may be performed as an alternative to testing. Thi s philosophy only applies to thermal relief valves whose only function is to prot ect systems/

components that have a safety function. These valves are ident ified 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 rel ief devices which perform a nuclear safety function but are not active and for wh ich 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 19 of this IST Plan.

3.2 Valve Testing Table Format

Detailed information and testing requirements for the valves in cluded in this IST Plan are summarized in Tables 1 through 19. A separate table h as been prepared for each plant system which contains valves in the sco pe 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

Safety Injection Table 13

Service Water Table 14

Ventilation (Control Room Air Conditioning) Table 15

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Vents and Drains Table 16

Miscellaneous Containment Isolation Valves Table 17

Safety & Relief Valves Table 18

Motor Operated Valves Table 19

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

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

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

In each table, the valves are arranged in numerical order by th e four digit location number which forms the root of each valve number. See Flow Diagram M1-0200, Mechanical Symbols and Notes, for a discussi on of valve numbering conventions and abbreviations. 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 be en dropped from the valve numbers in the tables. The valve number s 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 common system, exists in on e unit only, is numbered differently between units or has different test requir ements between units, then the unit designator is shown.

3. Flow Diagram Number - The flow diagram number field indicates on whic h drawing the valve may be found. The flow diagram numbers are p refixed 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.

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

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

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6. Code Class - The code class field indicates the ASME Boiler a nd 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 2004 Edition through 2006 Addenda, Subsection ISTC-1300. See the Valve Table Index at th e 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 a ctive valve and P denotes a passive valve with the terms defined as follo ws:

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

Passive valves - valves which maintain obturator position and a re not required to change obturator position to accomplish their requi red 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 close d positions are indicated by O and C respectively.

10. Test Parameters/Schedule - The test parameters/schedule fiel d denotes the Code test requirements and test frequencies for valves in t h e I S T P l a n .

The test parameters include leak test, exercise test, fail-safe test and position indicator test. Not all test parameters are applicabl e 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 di rection regardless of safety function position or valve safety significance. Non-safety function exercise tests for high safety significant chec k valves shall be performed at least once every two years. Non-safety functio n exercise tests for low safety significant check valves shall be performe d at the frequency specified in Relief Request A-1.

Required test parameters or test frequencies for which relief i s 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 l imited to cold shutdowns or refueling outages, a table footnote is provided wh ich justifies

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this determination. See the Valve Table Index at the end of th is section for a listing of test parameter and schedule acronyms and their mea nings.

11. Footnotes - Footnotes containing additional valve testing information are located at the back of each system valve table and are referenc ed 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. 1, 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 Elec tric Station, Unit 1 and 2 (TAC NOS. M94165, MA94166, MA1972, and MA1973). (Relief Request A-1.)

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APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

The following pages contain requests for relief from certain Co de test requirements which are identified in the Pump and Valve Testing Plans tables. The Re lief Requests address instances where an alternative to the Code requirements is proposed or wh ere it has been determined that compliance with certain Code requirements is impractical or pre sents a hardship or unusual difficulty without a compensating increase in the level of plan t quality and safety. Relief Requests associated with the Inservice Pump Testing 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, 1.5.8 and 1.5.9 was used to the greatest exte nt 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 i n 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 fro m 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 allow ed by the ASME OM Code. The process used to identify candidates for frequency extension is discussed under Proposed Alternative a nd Basis for Alternative.

CURRENT TEST Test frequencies of 2 years or less, the specified frequency fo r 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 i f the test is performed with the interval specified in frequency (1.25 tim es interval does not apply).

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

Inservice tests to verify operation readiness of pumps and valv es, whose function is required for safety, conducted during the ini tial 120-month interval must comply with the requirements in the lat est edition and addenda of the Code incorporated by reference in paragraph (b) of this section on the date 12 months prior to th e 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 valv es, whose function is required for safety, conducted during successive 120-month interval must comply with the requirements in the lat est edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of t he 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-mont h 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 b e 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 us ed when authorized by the Director of the Office of Nuclear Reactor Reg ulation.

The applicant shall demonstrate that: (i) The proposed alterna tives 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 regulat ions require that inservice tests on pumps and valves, whose functio n 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 AS ME Code. The use of the Risk-Informed Inservice Testing Program Description will provide an acceptable level of quality and saf ety.

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 con tains elements of probability, such as the selection of accidents to be analyzed as design basis accidents (e.g., the reactor vessel ru pture 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 th is 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 challen ges 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 defe nd 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 Pr ogram Plan will be tested in accordance with Appendix I for safety re lief valves, Subsection ISTC for active valves and Subsection ISTB f or pumps. Where ASME OM Code testing is not practical, alternati ve 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 c urrent 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 wi ll also be tested in accordance with the ASME IST Program, except that the test frequency will initially be extended to once every 6 y ears. The extended test frequency will be staggered over 6 years as descr ibed in Attachment 1. No LSSC will be deleted from the ASME IST Progra m.

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 o ther accident initiators (e.g. fires, tornadoes, and earthquakes) an d plant operating modes. These rankings considered importance with res pect to core damage prevention, and prevention of large early releas es 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 se t 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 procedur es, and with plant-specific operating experience. At the end of the ID P 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 resourc es on HSSCs and reducing the testing frequency on LSSCs. Extensiv e testing on LSSCs could have an adverse effect on safety. Reduc tion of testing should reduce component wear-out, operator burden, system unavailability, cost of testing, and radiation exposure.

Reduced testing could also achieve a more optimum balance betwe en the positive impacts of testing and the negative effects of dis turbing equipment from service and entering less than optimum plant configuration, such as valve misalignments.

RADIOLOGICAL Potential radiation exposure will be diminished due to less fre quent 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 process to determin e the safety significance and testing strategy of components in the ASME Inservice Testing (I ST) Program, and identify non-ASME IST components (pumps & valves) modeled in the Probabilist ic Risk Analysis (PRA) that are determined to be High Safety Significant Components (HSSCs) . T h e p r o c e s s c on s i s t s o f t h e 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 fin al importance ranking of components and categorization as either Low Safety Significa nt 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 frequency (CDF) and rel ease of radioactivity (e.g.

large early release frequency (LERF)).

The PRA techniques are used in conjunction with the Integrated Decision Process (IDP) to ensure that all the available information is accounted for i n developing the importance measures. As such, a review of plant equipment and operating p rocedures will be performed to identify potential plant specific initiating events as well as those initiating events that have been identified in the Nuclear industry. Evaluation of initiating events

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will also include loss of support systems and other special ini tiators.

Any changes to the PRA models used for the development of importance measures for the RI-IST will be independently reviewed. The independent rev iews 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 t he overall assessment of risk associated with the implementation of the RI-IST. As a re sult, any effect on common cause failure estimations will also be evaluated. To the exten t 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 I DP 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 comp onents in the RI-IST when the program is reassessed. However, only those ele ments that are significantly affected by the model changes (e.g., design modifications or procedural changes) need to be reviewed in detail using this pr ocess. The scope of the review and the justification for it will be documented a s part of the IDP.

Apply Importance Criteria to PRA and Review

Review FV and RAW importance measures for pumps and valves cons idered in the PRA against the criteria and determine if the grouping of c omponents is logical.

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

Robustness/Validation of Results

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

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

Evaluate the sensitivity due to human action modeling. Identi fy/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. Revi ew such sources as NRC Generic Letters, SOERs, IOERs and Technical Bulletins and rank accordingly.

For components with low FV/high RAW ensure that other compensa tory measures are available to maintain the reliability of the compo nent.

Identify and evaluate components whose performance shows a his tory of causing entry into LCO conditions. To ensure that safety margins are maintained, consider retaining the ASME test frequency for thes e 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 val idated 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 vali date 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 v alues 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 accor dingly.

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

Outage Risk Importance

A qualitative assessment of PRA systems modeled for shutdown mo des will be performed to determine the impact of shutdown modes on IST rank ings. To perform this analysis a three step process will be used. First , using existing PRA system models as the basis, components and system configuration s that are unique to the shutdown modes from the at power PRA will be iden tified. 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 R AW)

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 Integrit y. Rather than analyzing each function separately, the systems required for th e shutdown accident sequences will be analyzed and ranked with respect to their shutdown configurations. This will provide a comprehensive review of th e shutdown systems and their unique configurations.

The risk profile for an outage changes as maintenance activitie s start and stop and plant states change. Therefore, the importance of componen ts can also change during the outage, depending on the plant configuration as governed by the outage schedule. There can be times when almost any compon ent 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 signif icant 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 shutdown is that safety s y s t e m s a r e i n a standby mode at power and active components must start or repos ition automatically for success. Since actuation failure is much more likely than failure to continue to operate, a reliability-oriented 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 c orrespondingly 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 a utomatic actuation, the contribution of equipment failure is relatively less likely. Therefore, in most cases the ranking of components at power is higher than during shutdown, although the system configuration must still be compared to det ermine if there are unique differences for the shutdown mode. Based upon the insig hts discussed above, the approach to risk ranking is as follows:

If a component performs the same function and is in the same i nitial state as at power, the at power ranking is assumed to bound the outag e ranking.

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

The latter evaluation involves cases where a different system i s used, i.e., spent fuel pool cooling, or where a different function is performed b y a component in a system used at power or during an outage. Additionally the f ollowing 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 th at can fail redundant trains (high FV, extremely high RAW)

Pressure relief valves (safety or power operated) needed to co ntrol pressure so that redundant trains of systems can perform functi on (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 n ot 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 Generato rs that can fail the Turbine Driven AFW pump)(low FV, moderate RAW)

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

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

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

Back-end Risk Importance

It is equally important to identify those pumps and valves that p r e v e n t c o n t a i n m e n t failure or bypass that could result in an unacceptable release. Examples might include the valves that provide the boundary between the reacto r coolant system and low-pressure systems located outside containment. Various analyses have shown that large releases, though infrequent and of low probabi lity, tend to dominate offsite consequences. Therefore, 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 wi th a simple model consistent with the PRA back-end analysis. 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 accide nts with the following attributes:

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

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

One cause of a large, early release is a steam generator tube r upture, with immediate failure of core cooling, and failure of the main stea m system to isolate.

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

Instead, the most important sources of main steam isolation fai lure are considered potentially important and will be reviewed by the IDP to determ ine 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 a n 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 I ST 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 s ubstantiate the components risk category as high risk even if they are not in the IST Program.

Determine whether current plant testing is commensurate with t he 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 cumulat ive impact of changes in the IST Program test strategies on the total Core Da mage 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 results, and to pro vide qualitative assessment based on engineering judgement and experience. This qualitativ e assessment compensates for limitations of the PRA, including cases where a dequate 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 det ermine the final safety significance categories. The IDP considerations will be docume nted for each individual component to allow for future repeatability and scrutiny of the categorization process.

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

The IDP will determine appropriate changes to testing strategie s. 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 f or components categorized as low.

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

In making these determinations, the IDP will ensure that key sa fety principles, namely defense-in-depth and safety margins, are maintained and that th e 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 maintained by the CPNPP RI-I ST 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 describes these four bas ic principles:

1. No changes to the plant design or operations 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 cont ributors 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 a ccidents are not ranked low solely because of initiating event frequency. Further, sensitivity studies will be performed for human actions to ensure that comp onents which mitigate the spectrum of accidents are not ranked low solely be cause of the reliability of a human action.

3. The methodology for component categorization, namely the sele ction 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 oc curs only when the level of redundancy or diversity in the plant design or operati on supports it. In this regard, all components that have significant contributions to c ommon 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 o r LSSC and to determine whether a compensatory measure is required.

Sufficient Safety Margin is Maintained

The IDP will perform reviews to ensure that sufficient safety margin is maintained when compared to the existing IST program. In performing this revie w, the IDP will consider such things as proposed changes to test intervals and, where ap propriate, test methods.

The IDP will ensure that the proposed compensatory 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 progr am.

Categorization Guidelines

Modeled Components/Functions

For modeled components/functions with a FV >0.001 the IDP eithe r confirms the component categorization is HSSC or justification of conservati sm 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 meas ure 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 pro blems, a compensatory measure will be identified to ensure operational r eadiness or the component will be categorized as HSSC.

Non-Modeled Components/Functions

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

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

If the component is implicitly modeled, the FV and RAW are esti mated 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 ranki ng, the component performance history will be reviewed. For acceptable performance history the component will be categorized as LSSC. For poor pe rformance history, a compensatory measure will be identified to ensure operational readiness and the component categorized as LSSC, or if no compe nsatory measures are available, categorize the component as HSSC.

Documentation

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

4) Testing Philosophy

Motor Operated Valves (MOVs)

HSSC Testing will be performed in accordance with Code Case OMN- 1 (except the maximum diagnostic test interval will be 6 years), and NRC Generic Letter 89-10 and 96-05 commitments.

LSSC Testing will be performed in accordance with Code Case OMN- 1 (except the maximum diagnostic test interval will be 10 years), and NRC Generic Letter 89-10 and 96-05 commitments.

Performance Monitoring (applicable to HSSC and LSSC):

termination inspection

stem threads re-lubed

actuator gear box grease inspection

T-drain inspection

limit switch gear box grease inspection

visual inspection of housings

stem nut staked and secure

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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 wit h 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 condition monitoring by comparing data from current testing to a known baseline where the valve w as 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.

Test frequencies of 2 years or less, the specified frequency fo r 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 fr equency 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 ne xt refueling outage.

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

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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 Re cord as defined by 10CFR50.55a.

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

Test frequencies of 2 years or less, the specified frequency fo r 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 fr equency 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 ne xt refueling outage.

Performance Monitoring (applicable to HSSC and LSSC):

diagnostic testing

elastomer replacement

response time testing

Note: Luminant Power is participating in a tailored collaborat ion project with EPRI to develop an AOV program similar to the MOV Program mandated by GL 89-10 and 96-05. This program will evaluate the valve/operator characteristics/capabilities and the design conditions under which t he valve is expected to operate. Once this information is developed the valves will be tested and modified as necessary to meet their safety function. AOVs which are being evaluated by the EPRI Tailored Collaboration are:

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1) an HSSC AOV from each grouping (i.e. same manufacturer, size)

2) an LSSC AOV from other groups not included from (1) above.

Pumps

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

LSSC Testing will be performed in accordance with the Code of Re cord 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 fo r 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 fr equency 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 ne xt refueling outage.

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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 frequency changes on t o t a l p l a n t r i s k ( i . e . , C D F and LERF) to ensure that the change in plant safety is within t he 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 cate gory will be increased by a factor equivalent to the proposed increase in the component tes t 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 t otal CDF and LERF for each case will be obtained. These new values will, then, be compare d with the CDF and LERF of the base case to assess the net change in total plant risk d ue 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 sa me 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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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 unavailabili ty 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 te st interval from quarterly to semi-annually is assumed to increase the total com ponent 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 t o be negligible although frequent testing has been seen to cause components to be less available due to wearout.

It is conservatively assumed that all IST tests are fully effe ctive in finding the causes of component unavailabilities.

The PRA models will be updated to reflect the changes to the te st 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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6) Implementation

Implementation of the RI-IST to LSSC will consist of grouping c omponents 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 b asis over the test frequency will reduce the importance of common cause failure mo des as components in the same staggering failure mode group are continually being te sted. This ensures that the component capability will be maintained over the test inter val (i.e., 6 years).

Testing of components within the defined group will be staggere d 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 dur ing 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 i s appropriate.

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

7) Corrective Action

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

For components not meeting the acceptance criteria, a Smart For m will be generated.

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

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Smart Form may be from causes other than an unacceptable IST te st. Programs exist that provide timely information to the IST Engineer that the pe rformance of a reliable component has degraded. For example, a common compensatory act ion 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 a Smart Form initiated. The reco rded information could then be used to assess whether a significant change in componen t reliability has occurred such that the component would merit a change in test interval.

The initiating event could be any other indication that the com ponent is in a non-conforming condition. The unsatisfactory condition will be eva luated to:

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

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

c) Perform a root cause analysis.

d) Determine if this is a generic failure. If it is a generic f ailure whose implications affect a group of components, initiate corrective action for al l 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 r equired, review the IST test schedule and change as appropriate.

The results of component testing will be provided to the PRA gr oup 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 af ter evaluation of the component through the RI-IST Program (i.e., PRA model evaluatio n if applicable and IDP review) will this be considered LSSC.

8) Periodic Reassessment

As a living process, components will be reassessed at a frequen cy not to exceed every other refueling outage (based on Unit 1 refueling outages) to r eflect changes in plant configuration, component performance test results, 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 feedback loop of i nformation to the PRA. This will include information such as components tested since last r eassessment, 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 compone nts as LSSC will be validated. Additionally, the maximum test interval 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 component s and associated testing strategies using the above process will not require pri or 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

SYSTEM Vents & Drains

PUMP NUMBER CP1-WPAPSS-01 CP2-WPAPSS-01

CP1-WPAPSS-02 CP2-WPAPSS-02

CP1-WPAPSS-03 CP2-WPAPSS-03

CP1-WPAPSS-04 CP2-WPAPSS-04

CLASS 3

DESCRIPTION Safeguards Building Floor Drain Sump

TEST REQUIREMENT ASME OM Code:

ISTB-3540 (b), Vibration

ISTB-5200 (a) (1), Duration of Tests

ISTB-5221, Group A Test Procedure

ISTB-5223, Comprehensive Test Procedure

REFERENCES 1. Generic Letter 89-04, Guidance for Developing AcceptableInservice Testing Programs

2. NUREG-1482, Revision 1, Guidelines for Inservice Testing atNuclear Power Plants

BASIS FOR RELIEF The Safeguards Building Sump Pumps are required to detect and mitigate passive failures in the Emergency Core Cooling System (ECCS) and Containment Spray (CT) System post-LOCA and to prevent flooding of the safety-related systems.

There is no recirculation line from the discharge header of the pumps back to the sumps. There are no installed pressure instruments on the pump suction or discharge. Without a recirculation line on each pump discharge, the only method to meet the Group A Test procedure requirement is to set a reference flow of 0 gpm, dead-head the pump, calculate the differential pressure and record vibration. Diffe rential pressure is determined by making elevation corrections to the discharge pressure reading taken from an installed test gage at a vent connection. This vent connection is remotely located in a diffe rent

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room on a different floor elevation than the sump pumps. An ele vation difference is also measured on the suction side between the sump cover and the sump water surface. This procedure takes a minimu m of four test personnel to conduct the test in this manner. This te st has proven to be very difficult and operating experience and equipm ent history show that testing the pump in a dead-head condition can cause equipment reliability concerns.

CPNPP Inservice Testing Program is an approved Risk-Informed Inservice Testing (RI-IST) Program as described in the Safety Evaluation Report (TAC NOS. M94165, M94166, MA1972, and MA1973). The basis of the RI-IST Program is that there could be safety enhancements obtained by focusing resources on High Safe ty Significant Components (HSSCs). Extensive testing on Low Safety Significant Components (LSSCs) could have an adverse effect on safety. Reduction of testing should reduce component wear, oper ator burden, system unavailability, cost of testing, and radiation e xposure.

Reduced testing could also achieve a more optimum balance betwe en the positive impacts of testing and the negative effects of dis turbing equipment from service and entering a less than optimum plant configuration, such as valve misalignments. The CPNPP Safeguards Building Sump Pumps (SBSPs) have a low risk ranking and are tes ted every six years on a staggered test basis, such that at least t wo pumps are tested every 18 months.

To meet the operational readiness requirements for these pumps, a test should require that the pump starts on the proper level sw itch actuation, determine that the pump is capable of delivering a minimum of 50 gpm to the Waste Holdup Tank (WHT), and that velocity-bas ed vibration readings are satisfactory. Differential pressure meas urement is not needed to show adequate pump performance. Differential pressure measurement may resul t in additional radiation exposure to personnel (ALARA) and potential equipment damage due to dead-heading the pump. Pumping 50 gpm or more to the WHT demonstrates that an adequate head was developed to overcome system resistance and greater confidence exists that the ASME OM Code requirements for operational readiness have been met.

These pumps alert the operator of potential leakage in the safe guards building and mitigate the consequences of the leakage. To meet the testing requirements of ASME OM Code, Subsection ISTB, the pump s must be dead-headed for extended periods.

SUBSTITUTE TEST The pumps shall be tested in accordance with IST B-5221 (Group A pump test) and ISTB-5223 (Comprehensive pump test) for measurin g flow and vibration. The sump will be filled to a predetermined level and the pump will operate until the rapidly (approximately 50 secon ds) by

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automatic low-level cutoff switch actuates. The sump will be pumped down rapidly (approximately 50 seconds). Suction pressure will vary as sump level changes; therefore, the 2 minute stabilization ti me and differential pressure measurement are not achievable. The test will require pumping the same quantity of fluid along a repeatable s ystem path while measuring flow and vibration. A baseline reference value shall be established for flow and vibration. Alert and Required Action Limits for vibration will be established and maintained as per Table ISTB-5221-1 for vertical line shaft centrifugal pumps. Vibrati on will be measured in a single direction due to the short pump run and th e ability to acquire a single vibration reading during this time period. The acceptance criteria for flow will be greater than the design fl ow of 50 gpm. The flowrate delivered will be trended for detecting pump degradation to ensure the SBSPs have adequate design margin.

NRC APPROVAL Approved for the third ten year IST program interval; reference safety STATUS evaluation dated June 26, 2013 for Units 1 & 2, TAC NOS. ME9259 and ME9260 [ML13050A183].

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RELIEF REQUEST NO. T-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 compon ents in COMPONENT the CPNPP Inservice Testing (IST) Plan.

DESCRIPTION

BASIS FOR RELIEF ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the Code. The frequenci es (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in the Table 3.2 of NUREG-1482, Guidelines for lnservice Testing at Nuclear Power Plants, Revis ion 2

[dated October 2013 (ADAMS Accession No. ML13295A020)]) and owners routinely applied the surveillance extension time period (i.e.,

grace period) contained in the plant Technical Specifications ( TSs)

Surveillance Requirements (SRs). The TSs typically allow for a less than or equal to 25% extension of the surveillance test interva l to accommodate plant conditions that may not be suitable for conducting the surveillance (TS SR 3.0.2). However, Regulatory Issue Summ ary 2012-10, NRC Staff Position on Applying Surveillance Requirements (SRs) 3.0.2 and 3.0.3 to Administrative Controls Program Tests, [dated August 23, 2012 (ADAMS Accession No. ML12079A393),] states that SR 3.0.2 and 3.0.3 cannot be applied to TS 5.5, Programs and Manuals, for tests that are not associated with a TS SR. TS SR 3.0.2 is equivalent to SR 3.0.2 contained in NUREG-1431, Standard Techni cal Specifications, Westinghouse Plants, [Revision 4 (ADAMS Accession No. ML12100A222)]

The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. There may be a con flict where a surveillance test could be required (i.e., its frequenc y could expire), but where it is not possible or not desired that it be performed until sometime after a plant condition or associated Limiting C ondition for Operation (LCO) is within its applicability.

The NRC recognized this potential issue in the TSs by allowing a frequency tolerance as described in TS SR 3.0.2. The lack of a similar tolerance applied to the [ASME] OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility.

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Thus, just as with TS-required surveillance testing, some tolerance is needed to allow adjusting [ASME] OM Code testing intervals to s uit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling surveillance te sts that minimize the conflicts between the need to complete the surveil lance and plant conditions.

TEST REQUIREMENT ISTA-3120, "lnservice Test Interval," (a) state s, "The frequency for inservice testing shall be in accordance with the requirements of Section IST."

ISTB-3400, "Frequency of lnservice Tests," states, "An inservice test shall be run on each pump as specified in Table ISTB-3400-1."

ISTC-3510, "Exercising Test Frequency," states, "Active Categor y A, Category B, and Category C check valves shall be exercised nominally every 3 months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222. Power-operated valves shall be exercise tested once per fuel cycle."

ISTC-3540, "Manual Valves," states, "Manual valves shall be ful l-stroke exercised at least once every 2 years, except where adverse conditions may require the valve to be tested more frequently t o ensure operational readiness. Any increased testing frequency shall be specified by the Owner. The valve shall exhibit the require d change of obturator position."

ISTC-3630, "Leakage Rate for Other Than Containment Isolation Valves," (a) "Frequency," states, "Tests shall be conducted at least once every 2 years."

ISTC-3700, "Position Verification Testing," states, in part, "Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated."

ISTC-5221, "Valve Obturator Movement," (c)(3), states, "At leas t one valve from each group shall be disassembled and examined at each refueling outage; all valves in each group shall be disassemble d and examined at least once every 8 years."

Mandatory Appendix I, "lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants," 1-1320, "Test Frequencies, Class 1 Pressure Relief Valves," (a), "5-Year Test Interval," states, in part, "Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation."

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Mandatory Appendix I, 1-1330, 'Test Frequency, Class 1 Nonreclo sing Pressure Relief Devices," states, "Class 1 nonreclosing pressur e relief devices shall be replaced every 5 years unless historical data indicates a requirement for more frequent replacement."

Mandatory Appendix I, 1-1340, 'Test Frequency, Class 1 Pressure Relief Valves That Are Used for Thermal Relief Application," st ates,

'Tests shall be performed in accordance with 1-1320, Test Frequencies, Class 1 Pressure Relief Valves."

Mandatory Appendix I, 1-1350, 'Test Frequency, Classes 2 and 3 Pressure Relief Valves," (a), "10-Year Test Interval," states, in part, "Class 2 and 3 pressure relief valves, with the exception of PW R

[pressurized-water reactor] main steam safety valves, shall be tested every 10 years, starting with initial electric power generation ."

Mandatory Appendix I, 1-1360, "Test Frequency, Classes 2 and 3 Nonreclosing Pressure Relief Devices," states, "Classes 2 and 3 nonreclosing pressure relief devices shall be replaced every 5 years, unless historical data indicates a requirement for more frequent replacement."

Mandatory Appendix I, 1-1370, "Test Frequency, Classes 2 and 3 Primary Containment Vacuum Relief Valves," (a) states, "Tests s hall be performed on all Classes 2 and 3 containment vacuum relief valves at each refueling outage or every 2 years, whichever is sooner, unless historical data requires more frequent testing." 1-1370 (b) sta tes "Leak tests shall be performed on all Classes 2 and 3 containment vacuum relief valves at a frequency designated by the Owner in accorda nce with Table ISTC-3500-1."

Mandatory Appendix I, 1-1380, "Test Frequency, Classes 2 and 3 Vacuum Relief Valves, Except for Primary Containment Vacuum Relief Valves," states, "All Classes 2 and 3 vacuum relief valves shal l be tested every 2 years, unless performance data suggest the need for a more appropriate test interval."

Mandatory Appendix I, 1-1390, 'Test Frequency, Classes 2 and 3 Pressure Relief Devices That Are Used for Thermal Relief Application," states, 'Tests shall be performed on all Classes 2 and 3 relief devices used in thermal relief application every 10 year s, unless performance data indicate more frequent testing is necessary. I n lieu of tests the Owner may replace the relief devices at a frequency of every 10 years, unless performance data indicate more frequent replacements are necessary."

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PROPOSED The ASME OM Code specifies component test frequencies based ALTERNATIVE either on elapsed time periods (e.g., quarterly, 2 years, etc.) or on the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenan ce, etc.). ASME OM Code, Code

Case OMN-20, describes test frequency grace periods associated with the IST program for pumps and valves as follows:

(a) Components whose test frequencies are based on elapsed time periods shall be tested at the frequencies specified in Section IST with a specified time period between tests as shown in the table bel ow.

Frequency Specified Time Period Between Tests

Quarterly 92 days (or every 3 months)

Semiannually 184 days (or every 6 months)

Annually 366 days (or every year)

x Years x calendar years where x is a whole number of years 2

The specified time period between tests may be reduced or exten ded as follows:

1) For periods specified as less than 2 yr, the period may be extended by up to 25 percent for any given test.

2) For periods specified as greater than or equal to 2 yr, the period may be extended by up to 6 months for any given test.

3) All periods specified may be reduced at the discretion of th e owner (i.e., there is no minimum period requirement).

Period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance o f the required testing (e.g., performance of the test would cause an unacceptable increase in the plant risk profile due to transien t conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used rep eatedly

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merely as an operational convenience to extend test intervals b eyond those specified.

Period extensions may also be appl ied to accelerated test frequencies (e.g., pumps in alert range) and other less than 2 yr test frequencies not specified in the table above.

Period extensions may not be applied to the test frequency requirements specified in ASME OM Code Subsection ISTD, Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants, as Subsection ISTD contains its own rules for period extensions.

(b) Components whose test frequencies are based on the occurren ce of plant conditions or events may not have their period between tests extended except as allowed by the ASME OM Code.

NRC APPROVAL Approved for the remainder of the third ten year IST program in terval; STATUS reference safety evaluation dated January 19, 2016 for Units 1 & 2,

[ML16011A073].

COMANCHE PEAK - UNITS 1 AND 2 A-33 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

RELIEF REQUEST NO. V-1, Revision 0

SYSTEM See attached table

VALVE NUMBER See attached table

CATEGORY See attached table

CLASS See attached table

DESCRIPTION See attached table

BASIS FOR RELIEF Pursuant to the guidelines provided in NUREG-1482, Rev. 1, Section 4.2.5, and the conditions stated in RG 1.192, CPNPP proposes to implement Code Case OMN-1 Revision 1, in lieu of the stroke-tim e provisions specified in ISTC-5120 for MOVs as well as the posit ion verification testing in ISTC-3700.

TEST REQUIREMENT ISTC-5120, Motor-Operated Valves, ISTC-5121(a) states: Active valves shall have their stroke times measured when exercised in accordance with ISTC-3500.

ISTC-3700, Position Verification Testing, states in part: Valv es with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated.

ISTC-3510, Exercising Test Frequency, states: Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months, except as provided by ISTC-3520, ISTC-3540, IST C-3550, ISTC-3560, ISTC-5221, and ISTC-5222. Power-operated reli ef valves shall be exercise tested once per fuel cycle.

SUBSTITUTE TEST The use of Code Case OMN-1 Revision 1 by CPNPP p ermits it to replace stroke time and position verification testing of MOVs with a program of exercising MOVs every refueling cycle and diagnostic ally testing on longer intervals.

This alternative is considered to be acceptable because Code Ca se OMN-1 Revision 1 provides a superior method than the stroke-tim ing method required by the OM code for assessing the operational readiness of MOVs.

Using the alternative to the MOV stroke time testing requiremen ts of ISTC-5120 and position indication verification of ISTC-3700 pro vide an acceptable level of quality for determination of valve operatio nal readiness. Code Case OMN-1 Revision 1 should be considered

COMANCHE PEAK - UNITS 1 AND 2 A-34 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

acceptable for use with ASME OM Code 2004 Edition through 2006 Addenda as the Code of Record.

1) The potential benefits (such as identification of decreased thrustoutput and increase thrust requirements) and potential adverseeffects (such as accelerated aging or valve damage) will beconsidered when determining the appropriate testing for each MOV.

2) Where the selected inservice test frequency extends beyond6 years or 4 refueling outages (whichever is longer),performance and test experience obtained from valve testingconducted during the first 6 year or 4 refueling outage timeperiod shall be evaluated to justify the longer periodicverification frequency.

3) The risk insights determined during TU Electrics participati onin the Electric Power Research Institute (EPRI) Risk-InformedInservice Testing Pilot Project (ref. EPRI TR-105869) and on- going development of an updated risk-informed categorizationprocess based upon ASME Research guidance and Codes asapplicable will be used in accordance with the requirements ofthe ASME OM Code Case OMN-1.

Inservice testing shall be conducted in the as-found condition only.

As-found referring to: no maintenance activities that may aff ect the performance of an MOV shall be conducted prior to performing inservice testing. MOV Preventative Maintenance (PM) activities (including stem lubrication) will be performed on time based in tervals to ensure the MOV is maintained in optimum working condition. P M activities will be scheduled separately and frequencies determi ned independently from MOV inservice test requirements. Performance of a MOV PM will not alter an MOVs as-found status with regards to performing inservice testing. The effects of PM activities on MOV operational readiness will be as sessed to ensure the PM activities do not affect the validity of the MOV inservice test results.

Inservice testing shall be sufficient to assess changes in MOV functional margin. Therefore, MOVs requiring maintenance prior to their scheduled inservice test frequency shall be evaluated to determine whether or not performance of an inservice test prior to the maintenance activity will provide sufficient and/or valuable in formation in assessing changes in the MOVs functional margin. This evaluation, as a minimum, shall consider: inservice test frequency, time from last inservice or preservice test, functional margin, maintenance ac tivity to be performed, grouping, MOV history, risk significance, and a review of the last inservice or preservice test performed. In addition, this

COMANCHE PEAK - UNITS 1 AND 2 A-35 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

evaluation shall be documented for future reference.

Any OMN-1 Code Case requirements that are not currently include d in the CPNPP MOV program will be implemented using a controlled process in accordance with OMN-1 and evaluated under 10 CFR 50.59.

CPNPP intends to Maintain the following exceptions to the requirements in ASME Code Case OMN-1 as described below:

1) Paragraph 3.3.1, items (a) & (b) The initial inservice testfrequency for each MOV shall be determined based upon theMOVs risk significance category (i.e. High or Low) andmagnitude of margin. See Figure 1 for initial inservice testfrequency details. The inservice test frequency may changewhen sufficient test data has been collected and analyzed todetermine a more appropriate test frequency. No testfrequency shall exceed 10 years.

2) Paragraph 6.4.3 - In order to maintain consistency andcompatibility with the Joint Owners Group (JOG) MOV PeriodicVerification Program, Functional Margin will be redefined toagree with the definition of Margin as detailed i n TopicalReport MPR-1807 (Reference 1). The terms FunctionalMargin and Margin shall be synonymous within the CPNPPMOV Periodic verification program.

Margin, as defined in Reference 1, is dependent uponRequired Thrust. At CPNPP Required Thrust for rising stemMOVs has been determined from stem thrust measurementstaken during extensive baseline testing performed in responseto GL 89-10 under both static and dynamic test conditions.Valve factors have been determined by statistical means foreach group of rising stem MOVs; these factors will bereviewed/verified as new data is obtained from CPNPP testingand results are received from the JOG Periodic VerificationProgram.

REFERENCES

1) Joint BWR, Westinghouse and Co mbustion Engineering Owners Group Program onPeriodic Verification on Motor-Operated Valves (MOV) Periodic Verification, TopicalReport MPR-1807, Revision 2, July 1997

COMANCHE PEAK - UNITS 1 AND 2 A-36 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

Auxiliary HV-2480 B 3 Aux Feedwater Pump Emergency Supply Feedwater Flowpath

HV-2481 B 3 Aux Feedwater Pump Emergency Supply Flowpath

HV-2482 B 3 Aux Feedwater Pump Emergency Supply Flowpath

HV-2484 B 3 Condensate System to Condensate Storage Tank Isolation to Preclude Tank Overpressurization

HV-2485 B 3 Condensate System to Condensate Storage Tank Isolation to Preclude Tank Overpressurization

HV-2491A B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2491B B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2492A B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2492B B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2493A B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2493B B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2494A B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

HV-2494B B 2 Containment Isolation & AFW to Faulted SG Flow Isolation

Component HV-4512 B 3 Train A to Train B Crosstie Isolation Cooling Water

HV-4513 B 3 Train A to Train B Crosstie Isolation

COMANCHE PEAK - UNITS 1 AND 2 A-37 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

HV-4514 B 3 Train A to Train B Crosstie Isolation

HV-4515 B 3 Train A to Train B Crosstie Isolation

HV-4524 B 3 Non-Safety Loop Flowpath Isolation

HV-4525 B 3 Non-Safety Loop Flowpath Isolation

HV-4526 B 3 Non-Safety Loop Flowpath Isolation

HV-4527 B 3 Non-Safety Loop Flowpath Isolation

HV-4572 B 3 RHR Heat Exchanger Cooling Flowpath

HV-4573 B 3 RHR Heat Exchanger Cooling Flowpath

HV-4574 B 3 Containment Spray Heat Exchanger Cooling Flowpath

HV-4575 B 3 Containment Spray Heat Exchanger Cooling Flowpath

HV-4696 A 2 Containment Isolation & RCP Thermal Barrier Rupture Isolation

HV-4699 B 2 Passive Pipe Break Isolation (Inside Containment)

HV-4700 A 2 Containment Isolation & Passive Pipe Break Isolation (Inside Containment)

HV-4701 A 2 Containment Isolation

HV-4708 A 2 Containment Isolation

HV-4709 A 2 Containment Isolation & RCP Thermal Barrier Rupture Isolation

Chemical & LCV-0112B B 2 ECCS Flowpath Boundary & Isolation of VCT Volume Cover Gas from Charging Pumps Suction Control Header (upon low VCT level) & Boron Dilution Flowpath Isolation

LCV-0112C B 2 ECCS Flowpath Boundary & Isolation of VCT Cover Gas from Charging Pumps Suction Header (upon low VCT level) & Boron Dilution Flowpath Isolation

COMANCHE PEAK - UNITS 1 AND 2 A-38 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

LCV-0112D B 2 ECCS Injection Flowpath & Boration Flowpath/ECCS Recirc Flowpath Boundary

LCV-0112E B 2 ECCS Injection Flowpath & Boration Flowpath/ECCS Recirc Flowpath Boundary

8100 A 2 Containment Isolation

8104 B 2 Boration Flowpath

8105 A 2 Boration Flowpath/ECCS Flowpath Boundary

& Containment Isolation

8106 B 2 Boration Flowpath/ECCS Flowpath Boundary

8109 B 2 ECCS Flowpath Boundary

8110 B 2 ECCS Flowpath Boundary

8111 B 2 ECCS Flowpath Boundary

8112 A 2 Containment Isolation

8351A B 2 Containment Isolation

8351B B 2 Containment Isolation

8351C B 2 Containment Isolation

8351D B 2 Containment Isolation

8511A B 2 High Head Safety Injection Pump Miniflow Path/ECCS Recirculation Flowpath Boundary

8511B B 2 High Head Safety Injection Pump Miniflow Path/ECCS Recirculation Flowpath Boundary

8512A B 2 ECCS Recirculation Flowpath Boundary

8512B B 2 ECCS Recirculation Flowpath Boundary

Containment LV-4754 B 3 Chemical Additive Flowpath/Chemical Spray Additive Tank Isolation

LV-4755 B 3 Chemical Additive Flowpath/Chemical Additive Tank Isolation

HV-4758 B 2 Sump Recirculation Flowpath Boundary

COMANCHE PEAK - UNITS 1 AND 2 A-39 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

HV-4759 B 2 Sump Recirculation Flowpath Boundary

FV-4772-1 B 2 Pump Miniflow Flowpath/Containment Spray Flowpath Boundary

FV-4772-2 B 2 Pump Miniflow Flowpath/Containment Spray Flowpath Boundary

FV-4773-1 B 2 Pump Miniflow Flowpath/Containment Spray Flowpath Boundary

FV-4773-2 B 2 Pump Miniflow Flowpath/Containment Spray Flowpath Boundary

HV-4776 A 2 Containment Spray Flowpath/Containment Isolation

HV-4777 A 2 Containment Spray Flowpath/Containment Isolation

HV-4782 B 2 Sump Recirculation Flowpath/Containment Isolation

HV-4783 B 2 Sump Recirculation Flowpath/Containment Isolation

Reactor 8000A B 1 Post Accident Vent Path/Vent Path Isolation Coolant & Reactor Coolant Pressure Boundary

8000B B 1 Post Accident Vent Path/Vent Path Isolation

& Reactor Coolant Pressure Boundary

Residual FCV-0610 B 2 Pump Miniflow Path/ECCS & RHR Flowpath Heat Boundary Removal

FCV-0611 B 2 Pump Miniflow Path/ECCS & RHR Flowpath Boundary

8701A A 1 RHR Flowpath/Containment Isolation &

Reactor Coolant Pressure Boundary

8701B A 1 RHR Flowpath/Containment Isolation &

Reactor Coolant Pressure Boundary

8702A A 1 RHR Flowpath/Reactor Coolant Pressure Boundary

COMANCHE PEAK - UNITS 1 AND 2 A-40 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

8702B A 1 RHR Flowpath/Reactor Coolant Pressure Boundary

8716A B 2 ECCS Injection Flowpath/ECCS Recirculation Flowpath Boundary

8716B B 2 ECCS Injection Flowpath/ECCS Recirculation Flowpath Boundary

Safety 8801A B 2 ECCS to Cold Legs Flowpath & Boration Injection Flowpath/ Containment Isolation & Passive Pipe Break Isolation

8801B B 2 ECCS to Cold Legs Flowpath & Boration Flowpath/ Containment Isolation & Passive Pipe Break Isolation

8802A B 2 ECCS to Hot Legs Flowpath/ECCS to Cold Legs Flowpath Boundary & Containment Isolation & Passive Pipe Break Isolation

8802B B 2 ECCS to Hot Legs Flowpath/ECCS to Cold Legs Flowpath Boundary & Containment Isolation & Passive Pipe Break Isolation

8804A B 2 ECCS Recirculation Flowpath/Passive Pipe Break Isolation

8804B B 2 ECCS Recirculation Flowpath/Passive Pipe Break Isolation

8806 B 2 ECCS Flowpath Boundary (during Recirculation)

8807A B 2 ECCS Recirculation Flowpath/Passive Pipe Break Isolation

8807B B 2 ECCS Recirculation Flowpath/Passive Pipe Break Isolation

8808A B 2 ECCS from Accumulators to RC Cold Legs

8808B B 2 ECCS from Accumulators to RC Cold Legs

8808C B 2 ECCS from Accumulators to RC Cold Legs

8808D B 2 ECCS from Accumulators to RC Cold Legs

COMANCHE PEAK - UNITS 1 AND 2 A-41 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

8809A A 2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary & Passive Pipe Break Isolation & Containment Isolation

8809B A 2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary & Passive Pipe Break Isolation & Containment Isolation

8811A B 2 ECCS Recirculation Flowpath/Containment Isolation & Passive Pipe Break Isolation

8811B B 2 ECCS Recirculation Flowpath/Containment Isolation & Passive Pipe Break Isolation

8812A B 2 ECCS Recirculation Flowpath Boundary &

Shutdown Cooling Flowpath Boundary (during Safety Grade Cold Shutdown)

8812B B 2 ECCS Recirculation Flowpath Boundary &

Shutdown Cooling Flowpath Boundary (during Safety Grade Cold Shutdown)

8813 B 2 ECCS Recirculation Flowpath Boundary

8814A B 2 ECCS Recirculation Flowpath Boundary

8814B B 2 ECCS Recirculation Flowpath Boundary

8821A B 2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary & Passive Pipe Break Isolation

8821B B 2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary & Passive Pipe Break Isolation

8835 B 2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary & Containment Isolation & Passive Pipe Break Isolation

8840 A 2 ECCS to Hot Legs Flowpath/ECCS to Cold Legs Flowpath Boundary & Containment Isolation & Passive Pipe Break Isolation

8923A B 2 Passive Pipe Break Isolation

COMANCHE PEAK - UNITS 1 AND 2 A-42 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Va l v e System Number Category Class Description

8923B B 2 Passive Pipe Break Isolation

8924 B 2 Passive Pipe Break Isolation

Service HV-4286 B 3 Service Water Flowpath/Throttling during Water Pump Start

HV-4287 B 3 Service Water Flowpath/Throttling during Pump Start

HV-4393 B 3 Service Water Flowpath

HV-4394 B 3 Service Water Flowpath

HV-4395 B 3 AFW Pump Emergency Supply Flowpath

HV-4396 B 3 AFW Pump Emergency Supply Flowpath

Containment HV-6082 A 2 Containment Isolation Isolation

HV-6083 A 2 Containment Isolation

HV-6084 A 2 Containment Isolation

HV-4075B A 2 Containment Isolation

HV-4075C A 2 Containment Isolation

HV-5540 A 2 Containment Isolation

HV-5541 A 2 Containment Isolation

HV-5542 A 2 Containment Isolation

HV-5543 A 2 Containment Isolation

HV-5562 A 2 Containment Isolation

HV-5563 A 2 Containment Isolation

COMANCHE PEAK - UNITS 1 AND 2 A-43 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

LEGEND: Category A = Valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required s a f e t y function(s).

Category B = Valves for which seat leakage in the closed positio n is inconsequential for fulfillment of their required safety functi on(s).

Class = Code class

COMANCHE PEAK - UNITS 1 AND 2 A-44 Rev. 4 CPNPP UNIT 1 & 2 RISK INFORMED - INSERVICE TESTING PLAN APPENDIX A RELIEF REQUESTS FOR PUMPS AND VALVES

Figure 1 Initial Inservice Test Frequency MARGIN

Low Medium High R

I High 1 cycle 2 cycles 3 cycles S

K Low 2 cycles 4 cycles 6 cycles*

Not to exceed 10 years

Notes:

1. Criteria for MOV Margin Categories

Low Margin: < 10%

Medium Margin: 10% and < 15%

High Margin: 15%

2. Criteria for Risk Categories

High Risk: Risk-Informed IST Program

Low Risk: Risk-Informed IST Program

COMANCHE PEAK - UNITS 1 AND 2 A-45 Rev. 4 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

THIRD INTERVAL REVISION 0:

LDCR-IT-2013-004 (EV-CR-2011-009418-12) (JCH):

General Editorial Changes:

Page Nos: 1-1, 1-3, 2-1, 2-3, 3-1, 3-4 Valve Table Index all pages; Table 2 Page 8 of 8;Table 4 Page 8 of 8; Table 8 Page 7 of 7; Table 13 Page 12 of 13; Table 18 Page 15 of 15; Table 19 Page 20 of 20

Description:

Changed Code Edition and Addenda year from 1998 Edition through 2000Addenda to 2004 Edition through 2006 Addenda.

Justification: To comply with 10 CFR 50.55a (f)(4)(i) for the third inservice testing interval, which will be adoption of 2004 Edition through 2006 Addenda.

Affected Pages: Cover Page and General

Description:

Added "Third" Interval, Removed "Second" throughout the IST Plan, and added the address of CPNPP.

Justification: Editorial change for the third interval annotation. Added the address of the facility as required by ASME OM Code Subsection ISTA-9220.

Description:

Added the approval date for the RI-IST and implementation start date.

Section 1.3 Added a sentence to indicate the start and end date of the third interval.

Section 1.3 Added sentence the first interv al for consistency. Page 1-3 added Ref. 10 RI-IST approval letter.

Justification: Editorial addition and consistency.

Description:

Removed Para 2.1 and renumbered the paragraphs. Added Para c) to add the skid mounted pumps

Justification: Para 2.1 was redundant, the IST Plan is in accordance with the ASME OM Code and its Subsections for pumps and valves; Section 1 explains this adequately.

Description:

Added definition of centrifugal vertical line shaft direct coupled pumps

Justification: To depict the actual configuration of the safeguards pumps. Refer to AI-CR-2011-009418-2 and AI-CR-2011-009418-3.

Description:

Changed the pump type from C/DC to C/DC/VLS

Justification: To depict the actual configuration of the safeguards pumps. Refer to AI-CR-2011-009418-2 and AI-CR-2011-009418-3.

Description:

Removed Para 3.1 and renumbered the paragraphs. Added Para e) to reflect that Category A & B safety and relief are excluded from certain testing requirements.

CPNPP/IST DOC-1 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2013-004 (EV-CR-2011-009418-12) (JCH) (continued):

Justification: Previous Para 3.1 was redundant, the IST Plan is in accordance with the ASME OM Code and its Subsections for pumps and valves; Section 1 explains this adequately. Category A & B safety and relief are excluded from the testing requirements of stroke and position verification testing. Refer to ISTC-1200, "Exemptions", which excludes Category A & B safety and relief valves.

Description:

Added additional sentence to first paragraph.

Justification: Clarification for N/A.

Description:

Added Rev. 1 to NUREG-1482 and included NRC RI-IST approval letter as reference 3.

Justification: Editorial and enhancement.

Affected Pages: 4, 5, & 15

Description:

For Group 86, valves 8510A and 8510B removed footnote 2 and extended the frequency of these valves to 4 years.

Removed Note 2 and Note 3, and renumbered the notes in the table accordingly.

Justification: Note 2 was a commitment to in response to NRC IN-92-61, this commitment (CDF # 26357) was closed using STA-509, Commitment Management Program, and a CMCE # 4636255 was issued and was approved to remove the commitment identified in Note 2. Also refer to EV-CR-2013-004411-3. Note 3 did not correspond to any items in the Table.

Description:

Removed measured stroke time testing (MT) and position indication verification (PIT) was removed from certain valves as marked.

Justification: Comanche Peak Relief request has been reviewed and approved by the NRC to adopt the OMN-1 Rev 1. This relief request eliminates MT and PIT; refer to NRC SER TAC Nos. ME9503 and ME9504 for both units.

Description:

Removed old relief request V-8 and inserted V-1 in its place.

Justification: Comanche Peak Relief request has been reviewed and approved by the NRC to adopt the OMN-1 Rev 1. This relief request eliminates MT and PIT; refer to NRC SER TAC Nos. ME9503 and ME9504 for both units. Therefore, V-8 is not applicable anymore.

Description:

Removed old Relief Request P-2 and inserted P-1 in its place.

Justification: Comanche Peak Relief Request has been reviewed and approved by the NRC on June 26, 2013. It is approved for the third ten year IST program interval; reference safety evaluattion dated June 26, 2013 for Units 1 & 2, TAC NOS. ME9259 and ME9260 [ML13050A183]. This relief request supersedes old relief request P-1.

CPNPP/IST DOC-2 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2013-003 (EV-CR-2012-002342-1) (JCH):

Description:

Table 5, "Containment Spray",

Add "(3)" under Leak Test for CT-0142/0145 in Group 28 on Page 1 of 4.

Add Note 3 to Page 4: "3. This valve has a water filled loop seal and is not required to be leakrate tested (see DBD-ME-013, rev. 22, Attachment 1, Note 3)."

Justification: Valves CT-0142/0145 have water seals and are exempt from Appendix J leak testing.

Per DBD-ME-013,Attachment 1, Note 3, "These valves are part of closed systems outside containment tested per NUREG-0737 Section III.D.1 which are in service post-accident and have a water filled loop seal on the containment side of the valves. These valves are either open or closed providing a third barrier to containment leakage. A water seal is maintained both inside and outside containment. These valves are therefore not required to be leakrate tested.

Description:

Table 19, "Motor Operated Valves",

Add "(2)" under Leak Test for HV-4776 on Page 8, HV-4777 on Page 9, 8809A on Page 13, 8809B on Page 14, 8840 on page 15

Add Note 2 to Page 20: 2. "This valve has a water filled loop seal and is not required to be leakrate tested (see DBD-ME-013, rev. 22, Attachment 1, Note 3)."

Justification: Valves HV-4776/4777/8809A/8809B/8840 have water seals and are exempt from Appendix J leak testing.

Per DBD-ME-013,Attachment 1, Note 3, "These valves are part of closed systems outside containment tested per NUREG-0737 Section III.D.1 which are in service post-accident and have a water filled loop seal on the containment side of the valves. These valves are either open or closed providing a third barrier to containment leakage. A water seal is maintained both inside and outside containment. These valves are therefore not required to be leakrate tested.

LDCR-IT-2012-001 (EV-CR-2010-004331-60) (JCH):

Table 19 - Motor Operated Valves

Description:

add the following valve to Table 19: 1-HV-8402A under "Chemical and Volume Control-High Safety Significance"

Under "Gate Valve/Motor Operated Westinghouse with Limitorque Actuator":

-Change 2-HV-8402A to HV-8402A

- Add Flow Diagram- M1-0255(B-1)

CPNPP/IST DOC-3 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2012-001 (EV-CR-2010-004331-60) (JCH) (continued):

Justification:

The new 3-inch motor operated valve is classi fied as Nuclear Safety Class 2. The control switch will be used to isolate and bypass

1-HCV-0182 during maintenance and in case of a fire to ensure that the normal charging path is isolated. Replacement of this manual operated valve with a motor operated gate valve will maintain all design and operational functions of the existing valve. This includes

the requirement that the valve is a "PASSIVE" open valve. Since the function to close during a fire is important to safety, 1-HV-8402A will be exercise open and closed and position indicated tested.

LDCR-IT-2013-002 (EV-CR-2012-003165-4) (JCH):

Description:

Change the function from "P" to "A" for the following valves in Table 18, Group 91:

DO-011, DO-0187, DO-0211, DO-0287

Justification: These valves are required to protect diesel fuel oil transfer pumps when backpressure from the "Y" strainers requires it. Since this could happen during the Emergency Diesel Generator mission time (30 Days) and no credit had been taken for online maintenance or operator action to protect the pumps, these valves must be classifed as ACTIVE to perform their function as described in the FSAR.

THIRD INTERVAL REVISION 1:

LDCR-IT-2013-005 (EV-CR-2011-009418-17) (JCH):

Table 19 - Motor Operated Valves

VALVE TABLE INDEX (VTI)

Description:

Diagnostic Testing column under Test Parameters/Schedule.

The Valve Table Index defines diagnostic testing as follows:

DT-Diagnostic testing determines the cause or mechanism associated with failure, degradation, or performance anomaly of a motor operated valve per the requirements of OMN-1 Rev. 1 (Relief Request V-1)

Justification: Code Case OMN-1 allows users to replace MOV stroke-time testing with a combination of MOV exercising at least every refueling outage and MON diagnostic testing on a longer interval. Table 19 is being enhanced to include an additional column which will identify those MOVs which are required to be "diagnostic" tested.

CPNPP/IST DOC-4 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2013-005 (EV-CR-2011-009418-17) (JCH) (continued):

VALVE TABLE INDEX (VTI)

Description:

add the following under Exercise Test:

DT-Diagnostic testing determines the cause or mechanism associated with failure, degradation, or performance anomaly of a motor operated valve per the requirements of OMN-1 Rev. 1 (Relief Request V-1)

Justification: Code Case OMN-1 allows users to replace MOV stroke-tiem testing with a combination of MOV exercising at least every refueling outage and MON diagnostic testing on a longer interval

THIRD INTERVAL REVISION 2:

LDCR-IT-2014-001 (EV-CR-2012-011620-15) (JCH):

Referenced Section: Table 13, Safety Injection

Description of Change: This activity replaces the Unit 2 Safety Injection (SI) to Cold Leg (CL) 2-01 piston check valve (2SI-8819A) with a 2" Enertech nozzle check valve.

Technical Justification: The nozzle check valve is a ASME Section III Class 1513 valve with a pressure rating of 3632 psig at 100F and a design rating of 2485 psig at 650F per drawing MD22754 Revision E (VDRT-3902424). This meets the requirements of 2323-MS-43B Category 2501 component. For flow characteristics, Westinghouse reviewed the new valve and the old valve and concluded the flow changes are insiginificant and acceptable; the Westinghouse conclusions regarding 2SI-8819A are documented in WPT-17762. The replacement valve is designed and manufactured in accordance with the requirements of ASME B&PV Code Section III, Class 1, 1974 Edition through winter 1975 Summer Addenda

LDCR-IT-2014-003 (EV-CR-2014-005580-7) (JCH):

Table 1-Auxiliary Feedwater

Description:

Change frequency for the following valves for dual direction testing (DD) from "3MO" to "RF"- AF-0014, AF-0024, AF-0032, AF-0038, AF-0051, AF-0065

Justification:

Reverse flow testing (dual direction) is not practical at power operations. Such testing would unacceptably increase plant risk due to system unavailability. The Code of Record allows performance of this testing during plant refueling.

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

LDCR-IT-2014-003 (EV-CR-2014-005580-7) (JCH) (continued):

Description:

Add Note 4 to end of Table 1:

"AF-0014, AF-0024, AF-0032, AFW Pump suction valves and AF-0065, AF-0051, AF-0038, AFW Pump discharge check valves are reverse flow (closed) tested at refueling.

These valves are not reverse flow tested during plant operation because such testing would unacceptably increase plant risk due to system unavailability."

Justification: Note 4 provides clarification for reverse flow testing during plant refueling outages.

Table 18-SAFETY & RELIEF VALVES

Description:

Page 5-Change Flow Diagram number for 2CH-0281 and 2CH-0282 from "M1-0307" to "M2-0307"

Justification:

The following corrections are needed to correct typos for the drawing numbers These are Unit 2 valves and the drawing numbers should start as M2 and not M1.

Description:

Table 13- Page 8: Change 8825 Category from "A" to "B"

Table 13-Page 8: Change 8890A and 8890B from "A" to "B"

Table 19-Page 8: Change HV-4776 from "A" to "B"

Table 19-Page 9: Change HV-4777 from "A" to "B"

Table 19-Page 13: Change 8809A from "A" to "B"

Table 19-Page 14: Change 8809B from "A" to "B"

Table 19-Page 15: Change 8840 from "A" to "B"

Justification:

The affected valves were listed as Category A valves; they should be listed as Category B, because they do not require leak testing criteria.

CPNPP/IST DOC-6 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

THIRD INTERVAL REVISION 3:

LDCR-IT-2016-001 (EV-TR-2016-000780-8) (GWS):

Update Risk Significance in accordance with ER-EA-010 R4 and revising Test Parameters/Schedule per Relief Request A-1.

LDCR-IT-2016-003 (EV-CR-2010-008411-29) (GWS):

Delete Vacuum Breakers CP1/2-SWVAVB-03/4.

LDCR-IT-2018-001 (EV-CR-2018-000471-5) (GWS):

Revise Note 2 to state: "AF-0075, AF-0078, AF-0083, AF-0086, AF-0093, AF-0098, AF-0101, AF-0106, AFW to Steam Generator Header Check Valves, are full stroke exercised open during startup from a cold s hutdown outage. These valves cannot be open exercised during plant operation because such testing would unnecessarily subject the steam generator nozzles to thermal trans ients from the cool auxiliary feedwater and could result in steam generator level transients. These valves perform an ISTA-1100(a) function in MODES 1, 2, and 3. During an extended cold shutdown outage, exercise testing is required to be repeated every 3 months if the plant is in hot standby (MODE 3)."

LDCR-IT-2019-001 (EV-TR-2018-000922-18) (GWS):

Document use of Code Case OMN-16 Rev. 1. Update Risk Rank in accordance with EREA-010 R5. Revise Test Parameters/Schedule per Relief Request A-1 R0 and V-1 R0.

Add Relief Request T-1. Revision changed Pump Test Table and System Tables 1 (AFW), 2 (CCW), 4 (CVCS), 8 (FW), 13 (SI), 14 (SW), 16 (VD), 17 (Misc. CIVs), 18 (Safeties & Reliefs), and 19 (MOVs).

THIRD INTERVAL REVISION 4:

LDCR-IT-2019-002 (EV-CR-2015-011094-8) (GWS):

IST Plan Table 13 Safety Injection Update.

LDCR-IT-2020-001 (EV-TR-2019-008291-12) (GWS):

As allowed by ISTC-5220, implementation of a Check Valve Condition Monitoring Program in accordance with ASME OM Code Mandatory Appendix II.

LDCR-IT-2020-002 (EV-TR-2020-002118-23) (GWS):

Change maximum diagnostic test interval for LSSC Motor Operated Valves from 6 years to 10 years.

CPNPP/IST DOC-7 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2021-001 (EV-TR-2019-001528-8) (GWS):

Remove Group 39 and all associated valve and test information due to replacing DG Starting Air Compressors per FDA-2017-000092-01.

THIRD INTERVAL REVISION 5:

LDCR-IT-2022-001 (EV-TR-2022-001955-1) (GWS):

Table 4: Delete Group 25 and all associated FCV-0110B and FCV-0111B valve information and test requirements. Delete FCV-0111A valve information and test requirements.

Table 5: Add new Group 120, Globe Valve / Air Operated, Model ES to Table 5 with valves LV-4752 and LV-4753 and their associated valve and test information.

Table 18: Add multiple SSW and CCW relief valves to Group 92, create new Group 117 for multiple SSW relief valves, create new Group 118 for multiple CCCW relief valves, and create new group 119 for diesel lube oil relief valves.

LDCR-IT-2021-002 (EV-TR-2020-003923-6) (NWB):

Referenced Section: Table 1 - Auxiliary Feedwater

Description of Change:

1. CREATE new CVCM group 2-4 for 2AF-0051 and 2AF-0065:

CVCM Group 2-4 Swing Check Valve/Self Actuating Borg-Warner 75640

2. MOVE 2AF-0051 and 2AF-0065 to CVCM group 2-4, REVISE Risk Ranking to "HIGH", CHANGE reference from Note 1 to Note 4, and REVISE Exercise Test Schedule to "CV/3MO" and "DD/18MO".

3. CREATE new CVCM group 1-4 for 1AF-0051, 1AF-0065, and 1AF-0038:

CVCM Group 1-4 Swing Check Valve/Self Actuating Borg-Warner 75640 & 75700

4. For 1AF-0051, 1AF-0065, and 1AF-0038, MOVE valves to new CVCM Group 1-4, REVISE Test Schedule to CV/3MO and DD/ 6YR, and CHANGE reference from Note 1 to Note 4. For 1AF-0051 and 1AF-0065, REVISE Risk Ranking to "HIGH".

NOTE: 1AF-0038 Risk Ranking is to remain "LOW".

CPNPP/IST DOC-8 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2021-002 (EV-TR-2020-003923-6) (NWB) (continued):

Technical Justification: These changes are the result of the 2021 Periodic IST Program Re-assessment. An update to the PRA Internal Flooding model caused valves AF-0051 and AF-0065 Risk Ranking to change from Low to High as described in ER-EA-010 Rev. 6. The test frequency of HSSCs is required to meet ASME OM Code ISTC intervals or extended intervals supported by a CVCM Plan instead of the extended intervals allowed for LSSCs under Risk Informed Relief Request A-1. The performance of the Unit 1 valves supported DD/6YR intervals under CVCM Plan 1-4, but the leak rate performance of the Unit 2 valves is degraded and only supported DD/18MO intervals (See EV-TR-2021-002083-20 for CVCM Plans 1-4 and 2-4). This change does not affect any commitments or have any safety impact.

Referenced Section: Table 14 - Station Service Water

Description of Change:

1. For SW-0373 & 0374, DELETE reference to Note 1, REVISE Exercise Test schedule from CV/6YR to CV/3MO.

2. REVISE HIGH SAFETY SIGNIFICANCE identifier for check valve group containing SWVAVB-01/02 to Group 117. REVISE SWVAVB-01 & 02 Risk Ranking from HIGH to LOW.

Technical Justification: 1. Check valves SW-0373 & 0374 continue to be tested at 3MO intervals during quarterly pump testing. A RI-STB group has not been established for this group, and Table 14 does not have any notes, so the reference to Note 1 should be deleted. 2. The change in Risk Ranking of the vacuum breakers is the result of the 2021 Periodic IST Program Re-assessment. PRA ranking has been LOW for these check valves since 2005, but the IDP previously elevated their Final Risk Rank to High due to reliability issues. A plant modi fication to elevate the nozzle check valves above the water line has eliminated the reliability issues, and their performance has been reliable since the modification. Therefore, the IDP conf irmed their LOW Risk Rank. These changes do not affect any commitments or have any safety impact.

Referenced Section: Table 18 - Safety and Relief Valves

Description of Change:

1. Change the Position Indicator Test requirement to SRV/5YR for Pressurizer Safety Valves.

2. Change the Position Indicator Test requirement to N/A for Main Steam Safety Valves.

CPNPP/IST DOC-9 Revision 5 INSERVICE TESTING PLAN FOR PUMPS & VALVES - Description of Changes

LDCR-IT-2021-002 (EV-TR-2020-003923-6) (NWB) (continued):

Technical Justification: 1. Documenting the position indication test requirement as PIT/

2YR implies that the test is required by ISTC-3700 and that Table ISTC-3500 specifies the test frequency (see definition of PIT in the Valve Table Index). Safety and relief valves are excluded from the requirements of ISTC-3700 and ISTC-3500 per ISTC-1200.

Position indication testing of safety valves is a requirement of Appendix I-7310(f) and is at the same frequency as the set-pressure test. The SRV Exercise Test requirement as defined in the Valve Table Index under Test Parameters is the appropriate identifier because it points the reader to Appendix I. This change does not affect any commitments or have any safety impact. 2. Documenting the PIT/2YR requirement in this section implies that the test is required by ISTC-3700 and that Table ISTC-3500 specifies the test frequency (see definition of PIT in the Valve Table Index). Safety and relief valves are excluded from the requirements of ISTC- 3700 and ISTC-3500 per ISTC-1200. MSSVs are not equipped with position indicators which require testing per Appendix I. The acoustic sensors downstream of the MSSVs detect steam flow when the valve is open.

Rather than detecting a position of the valv e, these acoustic sensors detect whether flow noise is present and as such are not valve position indicators. Since the MSSVs do not have position indicators, position indication testing is not required of these valves. This change does not affect any commitments or have any safety impact.

Referenced Section: Table 19 - Motor Operated Valves

1. For HV-8402A, REPLACE reference to Note 1 under the Diagnostic Testing column with N/A.

2. REVISE Note 1 on page 20 of 20 to identify that the initial inservice test frequency for MOVs are determined by the chart, and when sufficient data exists, the JOG MOV Periodic Verification Approach may be used to determine MOV inservice test intervals per IST-301 Attachment 5.

Technical Justification: 1. As described in Table 19 Note 5, HV-8402A is a passive valve that does not perform an ISTA-1100(a) function. Rather, it performs an important to safety (non-IST) function which is adequately tested by a periodic exercise test which shows that the valve is capable of isolating normal charging in the event of a fire which disables MOVs 8105 and 8106 or for maintenance. Both 1-HV-8402A and 2-HV-8402A had very high margin (>70%) during their preservice diagnostic tests such that degradation of MOV capability to the point of failure is highly unlikely. Therefore, a periodic diagnostic test is not necessary to provide assurance that the valve is capable of performing the important to safety (non-IST) isolation function. 2. Extension of MOV inservice test intervals is already allowed per approved Relief Request V-1 (Code Case OMN-1), our Risk-Informed Relief Request, and IST-301, but that guidance is not prescriptive. IST-301 Attachment 5 provides a structured approach to extending MOV inservice test intervals beyond the initial inservice test interval based on test data that is in line with the JOG MOV Periodic Verification Approach (MPR-2524-A, Joint Owner's Group (JOG) Motor Operated Valve Periodic Verification Program Summary, November 2006). Furthermore, the JOG approach has been reviewed and approved by the NRC.

These changes do not affect any commitments or have any safety impact.

CPNPP/IST DOC-10 Revision 5

CP-202400253, (Cpnpp), Units 1 & 2 Inservice Testing Plan for Pumps & Valves Third Interval, Revision 5

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