ML23172A146

Aging Management Audit Report - Comanche Peak Units 1 and 2 - License Renewal Application

ML23172A146
Person / Time
Site:	Comanche Peak
Issue date:	08/09/2023
From:	Mark Yoo NRC/NRR/DNRL/NLRP
To:	Peters K Vistra Operations Company
References
EPID L-2022-RNW-0018
Download: ML23172A146 (106)

Text

August 9, 2023 Mr. Ken J. Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC Comanche Peak Nuclear Power Plant 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2022-RNW-0018)

Dear Mr. Peters:

By letter dated October 3, 2022 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML22276A082), as supplemented by letters dated April 6, 2023 (ML23096A302) and April 24, 2023 (ML23114A377), Vistra Operations Company LLC (Vistra OpCo or the applicant) submitted an application for the license renewal of Renewed Facility Operating License Nos. NPF-87 and NPF-89 for the Comanche Peak Nuclear Power Plant (Comanche Peak) to the U.S. Nuclear Regulatory Commission (NRC). Vistra OpCo submitted the application pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

The NRC staff completed its aging management audit from December 12, 2022 -

May 18, 2023, in accordance with the audit plan (ML22304A191), as supplemented by [[letter::CP-202100751, (CPNPP) - ASME OM Inservice Test Program Relief Request SNB-3, Snubber Inservice Program Third Internal Extension|letter dated January 4, 2022]] (ML22355A043). The audit report is enclosed.

K. Peters If you have any questions, please contact me by email at Mark.Yoo@nrc.gov.

Sincerely,

/RA/

Mark Yoo, Senior Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Audit Report cc w/encl.: Listserv

Pkg: ML23172A136 Letter: ML23172A146 OFFICE PM:NLRP:DNRL LA:NLIB:DNRL BC:NPHP:DNRL BC:NCSG:DNRL BC:NVIB:DNRL NAME MYoo SGreen MMitchell SBloom ABuford DATE 06/21/23 06/23/23 6/14/23 7/13/23 5/17/23 OFFICE BC:ESEB:DEX BC:ELTB:DEX BC:SNSB:DSS BC:NLRP:DNRL PM:NLRP:DNRL NAME ITseng JPaige PSahd LGibson MYoo DATE 5/24/23 5/4/23 5/2/23 7/28/23 8/9/23 AUDIT REPORT Aging Management Audit Comanche Peak Nuclear Power Plant, Units 1 and 2 License Renewal Application December 12, 2022 - May 18, 2023 Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF NEW AND RENEWED LICENSES Docket Nos: 50-445 and 50-446 License No: NPF-87 and NPF-89 Licensee: Vistra Operations Company LLC (Vistra OpCo)

Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Locations: Rockville, Maryland Glen Rose, Texas Dates: December 12, 2022 - May 18, 2023 Approved By: Steven D. Bloom, Chief Corrosion and Steam Generator Branch Division of New and Renewed Licenses Angie R. Buford, Chief Vessels and Internals Branch Division of New and Renewed Licenses Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses Matthew A. Mitchell, Chief Piping and Head Penetrations Branch Division of New and Renewed Licenses Jason Paige, Chief Long-Term Operations and Modernization Branch Division of Engineering and External Hazards Phillip Sahd, Chief Nuclear Systems Performance Branch Division of Safety Systems Ian Tseng, Chief Structural, Civil, Geotech Engineering Branch B Division of Engineering and External Hazards Reviewers: Name Organization Thinh Dinh PRA Licensing Branch B (APLB)/Division of Risk Assessment (DRA)

Naeem Iqbal APLB/DRA Adakou Foli Electrical Engineering Branch/Division of Engineering and External Hazards (DEX)

Jorge Cintron-Rivera Long-Term Operations and Modernization Branch (ELTB)/DEX Gurcharan Matharu ELTB/DEX Matthew McConnell ELTB/DEX Liliana Ramadan ELTB/DEX Ata Istar Structural, Civil, Geotech Branch (ESEB)/DEX Bryce Lehman ESEB/DEX Andrew Prinaris ESEB/DEX George Thomas ESEB/DEX George Wang ESEB/DEX Zuhan Xi ESEB/DEX Brian Allik Corrosion and Steam Generator Branch (NCSG)/Division of New and Renewed Licenses (DNRL)

Lydiana Alvarado NCSG/DNRL Reena Boruk NCSG/DNRL Tony Gardner NCSG/DNRL James Gavula NCSG/DNRL Joel Jenkins NCSG/DNRL Andy Johnson NCSG/DNRL Paul Klein NCSG/DNRL Greg Makar NCSG/DNRL Leslie Terry NCSG/DNRL Matthew Yoder NCSG/DNRL Mat Burton Piping and Head Penetrations Branch (NPHP)/DNRL Jay Collins NPHP/DNRL Robert Davis NPHP/DNRL Bart Fu NPHP/DNRL Varoujan Kalikian NPHP/DNRL Seung Min NPHP/DNRL Eric Reichelt NPHP/DNRL Ali Rezai NPHP/DNRL Karen Sida NPHP/DNRL Michael Benson Vessels and Internals Branch (NVIB)/DNRL David Dijamco NVIB/DNRL Carolyn Fairbanks NVIB/DNRL Emma Haywood NVIB/DNRL James Medoff NVIB/DNRL Cory Parker NVIB/DNRL John Tsao NVIB/DNRL On Yee NVIB/DNRL Christopher Jackson Nuclear Systems Performance Branch (SNSB)/Division of Safety Systems (DSS)

Adam Rau SNSB/DSS Jessica Hammock License Renewal Projects Branch (NLRP)/DNRL Bill Rogers NLRP/DNRL Andrew Siwy NLRP/DNRL Mark Yoo NLRP/DNRL TABLE OF CONTENTS AUDIT REPORT ........................................................................... Error! Bookmark not defined.

TABLE OF CONTENTS ........................................................................................................... ACRONYMS ............................................................................................................................ 1. Introduction .......................................................................................................................... 10

2. Audit Activities ..................................................................................................................... 11 LRA Section 2.1, Scoping and Screening Methodology .......................................................... 11 LRA AMP B.2.2.1, Fatigue Monitoring .................................................................................... 15 LRA AMP B.2.2.2, Environmental Qualification of Electric Components ................................ 17 LRA AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD 18 LRA AMP B.2.3.2, Water Chemistry ....................................................................................... 19 LRA AMP B.2.3.3, Reactor Head Closure Stud Bolting .......................................................... 20 LRA AMP B.2.3.4, Boric Acid Corrosion ................................................................................. 22 LRA AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components ................... 23 LRA AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel .............. 24 LRA AMP B.2.3.7, PWR Vessel Internals ............................................................................... 25 LRA AMP B.2.3.8, Flow-Accelerated Corrosion ...................................................................... 36 LRA AMP B.2.3.9, Bolting Integrity ......................................................................................... 36 LRA AMP B.2.3.10, Steam Generators ................................................................................... 38 LRA AMP B.2.3.11, Open-Cycle Cooling Water System ........................................................ 39 LRA AMP B.2.3.12, Closed Treated Water Systems .............................................................. 39 LRA AMP B.2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems .............................................................................................. 40 LRA AMP B.2.3.14, Compressed Air Monitoring ..................................................................... 42 LRA AMP B.2.3.15, Fire Protection ......................................................................................... 43 LRA AMP B.2.3.16, Fire Water System .................................................................................. 45 LRA AMP B.2.3.17, Fuel Oil Chemistry ................................................................................... 47 LRA AMP B.2.3.18, Reactor Vessel Surveillance.................................................................... 49 LRA AMP B.2.3.19, One-Time Inspection ............................................................................... 50 LRA AMP B.2.3.20, Selective Leaching .................................................................................. 51 LRA AMP B.2.3.21, One-Time Inspection of ASME Code Class 1 Small-Bore Piping ........... 52 LRA AMP B.2.3.22, External Surfaces Monitoring of Mechanical Components...................... 53 LRA AMP B.2.3.23, Flux Thimble Tube Inspection ................................................................. 54 LRA AMP B.2.3.24, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components ........................................................................................................................ 55 LRA AMP B.2.3.25, Lube Oil Analysis .................................................................................... 56 LRA AMP B.2.3.26, Monitoring of Neutron-Absorbing Materials Other Than Boraflex ........... 57 LRA AMP B.2.3.27, Buried and Underground Piping and Tanks ............................................ 58 LRA AMP B.2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks ....................................................................................................... 59 LRA AMP B.2.3.29, ASME Section XI, Subsection IWE ......................................................... 60 LRA AMP B.2.3.30, ASME Section XI, Subsection IWL ......................................................... 62 LRA AMP B.2.3.31, ASME Section XI, Subsection IWF ......................................................... 63 LRA AMP B.2.3.32, 10 CFR Part 50, Appendix J ................................................................... 65 LRA AMP B.2.3.33, Masonry Walls ......................................................................................... 66 LRA AMP B.2.3.34, Structures Monitoring .............................................................................. 67 LRA AMP B.2.3.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants ................................................................................................................................... 69 LRA AMP B.2.3.36, Protective Coating Monitoring and Maintenance .................................... 70 LRA AMP B.2.3.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements .................................................. 71 LRA AMP B.2.3.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits ..................................... 73 LRA AMP B.2.3.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ................................................................................................. 74 LRA AMP B.2.3.40, Metal Enclosed Bus ................................................................................ 75 LRA AMP B.2.3.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ................................................................................................. 76 LRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses ................................... 76 LRA TLAA Section 4.2.1, Neutron Fluence Projections .......................................................... 77 LRA TLAA Sections 4.2.2 - 4.2.5 ............................................................................................ 78 LRA TLAA Section 4.3.1, Transient Cycle Projections for 60 Years ....................................... 80 LRA TLAA Section 4.3.2, ASME Section III, Class 1 Fatigue Analysis of Piping, Piping Components, and Equipment .............................................................................................. 81 LRA TLAA Section 4.3.3, ASME Section III, Class 2 and 3 Allowable Stress Analyses ......... 82 LRA TLAA Section 4.3.4, Environmentally Assisted Fatigue .................................................. 83 LRA TLAA Section 4.4, Environmental Qualification of Electrical Equipment ......................... 86 LRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analyses ................................................................................................................. 87 LRA TLAA Section 4.7.1, Leak-Before-Break ......................................................................... 88 LRA TLAA Section 4.7.2, Reactor Coolant Pump Casings ASME Code Case N-481 ............ 90 LRA TLAA Section 4.7.3, Reactor Coolant Pump Flywheel Fatigue Crack Growth Analysis, Audit Report Input ................................................................................................................ 90 LRA TLAA Section 4.7.4, Crane Load Cycle Limit .................................................................. 91 LRA TLAA Section 4.7.5, Spent Fuel Pool Metal Corrosion Allowance .................................. 92 LRA TLAA Section 4.7.6, Protective Coatings ........................................................................ 93 LRA TLAA Section 4.7.7, Steam Generator Tubes Metal Corrosion Allowance ..................... 93 LRA TLAA Section 4.7.8, Steam Generator Flow-Induced Vibration and Tube Wear Evaluations .......................................................................................................................... 94 LRA TLAA Section 4.7.9, Steam Generator U-Bend Tube Vibration and Fatigue Assessment

............................................................................................................................................. 94 LRA TLAA Section 4.7.10, Flaw Tolerance Evaluation for Susceptible Reactor Coolant Loop Cast Austenitic Stainless Steel Piping Components ........................................................... 95 LRA TLAA Section 4.7.11, Safe Shutdown Impoundment Sedimentation .............................. 96 AMR Items Not Associated with an AMP ................................................................................ 96

3. Supplements to the LRA .................................................................................................... 101

4. Audit Questions Provided to Vistra OpCo ......................................................................... 101

5. Applicant Personnel Contacted During the Audit............................................................... 102

6. Exit Meeting ....................................................................................................................... 103 ACRONYMS ADAMS Agencywide Documents Access and Management System AMP aging management program AMR aging management review ART adjusted reference temperature ASME American Society of Mechanical Engineers BMI Bottom-mounted instrumentation CAP corrective action program CASS cast austenitic stainless steel CB core barrel CCW component cooling water CFR Code of Federal Regulations CLB current licensing basis CPNPP Comanche Peak Nuclear Power Plant CR condition report CRDM control rod drive mechanism CRGT control rod guide tube CUF cumulative usage factor CUFen environmentally-adjusted cumulative usage factor DBD design-basis document DBE design-basis event dpm drops per minute EAF environmentally assisted fatigue EFPY effective full power years EI&C electrical and instrumentation and controls EPRI Electric Power Research Institute EQ electrical qualification FAC Flow-Accelerated Corrosion FBOC fuel building overhead crane FE further evaluation FSAR final safety analysis report FTEC flux thimble tube eddy current GALL-LR generic aging lessons learned for license renewal HELB high-energy line break HV high-voltage I&C instrumentation and control I&E inspection and evaluation IASCC irradiation-assisted stress corrosion cracking IE irradiation embrittlement IPA integrated plant assessment ISR/IC irradiation-enhanced stress relaxation or creep ISG Interim Staff Guidance ISI inservice inspection Kv kilo Volt LAR license amendment request LBB leak-before-break LRA license renewal application LR license renewal LTOP low temperature overpressure protection MRP materials reliability program MSIP Mechanical Stress Improvement Process NDE nondestructive examination NEI Nuclear Energy Institute NNS nonnuclear safety NRC U.S. Nuclear Regulatory Commission OE operating experience P/T Pressure and temperature PTLR pressure-temperature limits report PTS pressurized thermal shock PWR pressurized-water reactor PWROG Pressurized-Water Reactor Owners Group PWRVI pressurized-water reactor vessel internals PWRVIP pressurized-water reactor vessel internals program PWSCC primary water stress corrosion cracking RAI request for additional information RCI request for confirmation of information RCP reactor coolant pump RCPB reactor coolant pressure boundary RCS reactor coolant system RG Regulatory Guild RHR residual heat removal RIS regulatory issue summary RPV reactor pressure vessel RTNDT reference temperature nil ductility RV reactor vessel RVI reactor vessel internal QA quality assurance SBO station blackout SC structure and component SCC stress corrosion cracking SE safety evaluation SG steam generator SLR Subsequent License Renewal SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants SS stainless steel SSC system, structure, and component SSI safe-shutdown impoundment SWIS service water intake structure SWOL structural weld overlay TE thermal aging embrittlement TLAA time-limited aging analyses UFW upper flange weld UGW upper girth weld UIA upper internals assembly USE upper-shelf energy UT ultrasonic testing VS void swelling VT visual examination WO work order Report for the Aging Management Audit Comanche Peak Nuclear Power Plant, Units 1 and 2 License Renewal Application

1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an aging management audit of Vistra Operations Company LLC (Vistra or the applicant) (1) plant-specific operating experience (OE), (2) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal (LR) and subject to an aging management review (AMR) (Scoping and Screening Portion), and (3) aging management programs (AMPs),

AMR items, time-limited aging analyses (TLAA) and associated bases and documentation as applicable (AMP and TLAA Portion) for the LR of Renewed Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP, Comanche Peak, or the applicant).

The purpose of the plant-specific OE portion of the audit is to identify examples of age-related degradation, as documented in the applicants corrective action program (CAP) database, and to provide a basis for the staffs conclusions on the ability of the applicants proposed AMPs to manage the effects of aging in the period of extended operation. Vistra searched their OE database and provided the results for the associated AMPs and TLAAs for NRC staff review.

Additional word searches were performed by Vistra upon NRC staffs request, and the results were provided to the NRC staff for review.

The purpose of the Scoping and Screening Portion of the audit is to evaluate the scoping and screening process as documented in the license renewal application (LRA), implementing procedures, reports, and drawings, such that the NRC staff:

• Obtains an understanding of the process used to identify the SSCs within the scope of LR and to identify the structures and components subject to an AMR.

• Has sufficient docketed information to allow the staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.

The purpose of the AMP and TLAA Portion of the audit is to:

• Examine Vistras AMPs, AMR items, and TLAAs for Comanche Peak;

• Verify Vistras claims of consistency with the corresponding NUREG-1801, Generic Aging Lessons Learned for License Renewal (GALL) Report, (GALL-LR Report) issued in December 2010, AMPs, and AMR items; and

• Assess the adequacy of the TLAAs.

Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation (SE).

The regulatory basis for the audit was Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. The staff also considered the guidance contained in NUREG-1800, Standard Review Plan for Review of 10

License Renewal Applications for Nuclear Power Plants (SRP-LR), dated December 2010, and NUREG-1801. The SRP-LR allows an applicant to reference in its LRA the AMPs described in the GALL-LR Report. By referencing the GALL-LR Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-LR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-LR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-LR Report program. The applicant should document this determination in an auditable form and maintain the documentation onsite.

2. Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information, and, if applicable, to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.

The LRA states that every AMP in the LRA is consistent with the program elements of the GALL-LR Report. To verify this claim of consistency, the staff audited each AMP, including any enhancements or exceptions associated with an AMP.

The LRA discusses each time-limited aging analyses, the disposition of the TLAA in accordance with 10 CFR 54.21(c)(1), and the basis for that disposition. To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited each TLAA.

The staff also audited AMR items not Associated with an AMP to determine if the information in the LRA is consistent with the further evaluation information in the SRP-LR.

Furthermore, the staff audited the FSAR descriptions for each AMP and TLAA for consistency with the SRP-LR. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.

Licensing conclusions or staff findings are not made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed using other NRC processes, such as requests for additional information (RAIs), requests for confirmation of information (RCIs), and public meetings. Licensing conclusions, staff findings, staff review of enhancement and exceptions, and resolution of audit items will be documented in the staffs SE.

The following sections discuss the LRA areas reviewed by the staff.

LRA Section 2.1, Scoping and Screening Methodology Summary of Information in the Application. LRA Section 2 describes the process for identifying and determining the CPNPP SSCs that are included within the scope of LR. 10 CFR 54.21, Contents of Application - Technical Information, requires that each application for LR contain an integrated plant assessment (IPA). The IPA must list, for SSCs within the scope of LR, the structures and components (SCs) that are subject to an AMR. 10 CFR 54.4(a), Scope, 11

provides the criteria for inclusion of SSCs within the scope of LR and 10 CFR 54.21(a)(1) requires that SCs within the scope of license, that are determined to be passive and not periodically replaced (long-lived), are subject to an AMR. The staff conducted the scoping and screening methodology audit, from March 20-22, 2023, to review the applicants administrative controls governing implementation of the scoping and screening methodology and the technical basis for selected scoping and screening results for various plant SSCs.

Audit Activities.

A. Scoping Methodology Staff Review of Information Sources, Implementing Documents and Scoping Methodology The audit team reviewed the methodology used by the applicant to identify mechanical, structural, and electrical SSCs within the scope of LR (scoping). In addition, the audit team reviewed documentation pertinent to the scoping process. The audit team assessed whether the scoping methodology outlined in the LRA and implementing procedures was consistent with the requirements of 10 CFR Part 54.

The staff confirmed that the applicants detailed LR program guidelines specified the use of the current licensing basis (CLB) source information in developing scoping evaluations. The staff reviewed pertinent information sources used by the applicant including the component database, the Final Safety Analysis Report (FSAR), maintenance rule basis documents, design-basis documents (DBD), LR drawings and station drawings.

The staff discussed the applicants administrative controls for the component database and the other information sources used to verify system information. These controls are described and implemented by plant procedures. Based on a review of the administrative controls and on a sample of the system classification information contained in the applicable documentation, the staff determined that the applicant has established adequate measures to control the integrity and reliability of system identification and safety classification data; therefore, the staff determined that the information sources used by the applicant during the scoping and screening process provided a controlled source of system and component data to support scoping and screening evaluations.

The staff reviewed the implementing procedures and results reports used to support identification of SSCs that the applicant relied on to demonstrate compliance with the requirements of 10 CFR 54.4(a). The applicants LR program guidelines provided a listing of documents used to support scoping evaluations. The staff determined that the design documentation sources, required to be used by the applicants implementing procedures, provided sufficient information to ensure that the applicant identified SSCs to be included within the scope of LR consistent with the plants CLB.

During the audit, the applicant stated that it evaluated the types of events listed in Nuclear Energy Institute (NEI) 95-10 (anticipated operational occurrences, design-basis accidents, external events, and natural phenomena) that were applicable to CPNPP. The staff reviewed the applicants basis documents, which described design-basis conditions in the CLB, and addressed events defined by 10 CFR 50.49(b)(1) and 10 CFR 54.4(a)(1). The FSAR and basis documents discussed events, such as internal and external flooding, tornados, and missiles.

The staff determined that the applicants evaluation of DBEs was consistent with the SRP-LR.

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The staff determined that the applicants LR project personnel performed the scoping activities, in accordance with the applicable implementing documents, as follows:

• Mechanical scoping: The applicant used information contained in the plant component database to develop a list of plant systems and used CLB information, DBD, and station drawings to identify system intended functions. The intended functions were evaluated using the criteria of 10 CFR 54.4(a) to identify those systems to be included within the scope of LR.

• Structural scoping: The applicant used CLB information, DBD and maintenance rule basis documents to develop a structures list and to identify structural intended functions.

The intended functions were evaluated using the criteria of 10 CFR 54.4(a) to identify those systems to be included within the scope of LR.

• Electrical scoping: The applicant used a bounding approach for plant electrical and instrumentation and control (EI&C) systems and included all EI&C systems, and EI&C components contained in mechanical systems, within the scope of LR by default.

Staff Verification of Scoping and Screening Results for Sampled Systems and Components The staff performed a sampling review of the results of the applicants implementation of the scoping and screening methodology to confirm that the results were in conformance with the applicable implementing documents and the requirements of 10 CFR Part 54.

The staff reviewed a sample of the scoping and screening implementation and performed walkdowns for portions of various systems, focusing on non-safety-related SSCs in proximity of SR SSCs. The staff reviewed applicable portions of the FSAR, scoping and screening reports, and LR drawings and performed walkdowns to confirm information contained in the LRA.

The staff performed a site walkdown to observe those buildings that were included within the scope of LR, determined to be subject AMR, and were included in AMPs. The staff walkdowns included the exteriors and interiors (as appropriate) of the turbine, emergency diesel generator, switchgear, auxiliary, and containment structures. The staff observed the plant effluent hold-up and monitoring tanks, which were in the proximity of structures that had been included within the scope of LR in accordance with the requirements of 10 CFR 54.4 (a)(1). The staff requested that the applicant provide documentation of the scoping evaluation for the plant effluent hold-up and monitoring tanks, however the applicant indicated that the tanks had not been included within the scope of LR and did not provide a scoping evaluation. Upon the applicants further review, it was indicated to the staff that the applicant had determined that the plant effluent hold-up and monitoring tanks should be included within the scope of LR and subject to AMR, and that the LRA would be supplemented to include this information.

B. Screening Methodology The audit team reviewed the methodology used by the applicant to determine if mechanical, structural, and electrical components within the scope of LR would be subject to an AMR (screening) and the applicant provided a discussion indicating the processes used for each discipline.

The staff determined that the applicants LR project personnel performed the screening activities, in accordance with the applicable implementing documents, as follows:

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• Mechanical components were subject to AMR if they met the criteria of being passive and long-lived and the components supported a system intended function, which required the system to be included within the scope of LR. The applicant had identified the component level intended functions (e.g., pressure boundary, heat transfer), which supported a system intended function and highlighted the in-scope components that were subject to AMR on the LR drawings. Mechanical components that were included within scope in accordance with 10 CFR 54.4(a)(2) and subject to AMR were also identified on the LR drawings.

• Structural components had been determined by the applicant to be inherently passive and long-lived and were grouped by common structural intended functions (e.g., support, enclosure protection, fire barrier, flood barrier, pressure boundary). The components were treated as bulk commodities based on material of construction for the purposes for the AMR.

• Electrical and instrumentation and control components, which were included within the scope of renewal in accordance with the bounding method used for EI&C, were evaluated in accordance with the guidance contained in NEI 95-10 to identify the passive and long-lived components subject to AMR.

The audit team noted that the applicants screening process was performed in accordance with its written requirements and was consistent with the guidance provided in the SRP-LR and NEI 95-10. The audit team determined that the screening methodology was consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the screening criteria of 10 CFR 54.21(a)(1).

C. Aging Management Program Quality Assurance Attributes The audit team reviewed the AMP quality assurance (QA) elements to verify consistency with the staffs guidance described in SRP-LR, Appendix A, Branch Technical Positions, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1). The AMP QA elements are corrective action, confirmation process, and administrative controls.

The applicant described the AMP QA elements in LRA Appendix A, Final Safety Analysis Report Supplement, Section A.1.3, Quality Assurance Program and Administrative Controls, and LRA Appendix B, Aging Management Programs, Section B.1.3, Quality Assurance Program and Administrative Controls, and the individual AMPs.

LRA Appendix A stated that the QA Program for CPNPP implements the requirements of 10 CFR Part 50, Appendix B, and will be consistent with the summary in Appendix A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1), of NUREG-1800. The QA Program includes the elements of corrective action, confirmation process, and administrative controls, and is applicable to nuclear safety-related SSCs. CPNPP will enhance the QA Program to include nonnuclear safety (NNS) SSCs that are subject to AMR for LR.

LRA Appendix B also stated that the CPNPP QA Program implements the requirements of 10 CFR Part 50, Appendix B, Quality Assurance Requirements for Nuclear Power Plants and Fuel Reprocessing Plants and is consistent with the summary in Appendix A.2 of 14

NUREG-1800. The CPNPP QA Program includes the elements of corrective action, confirmation process, and administrative controls, and is applicable to nuclear safety-related SSCs. CPNPP will enhance the QA Program to include NNS SSCs that are subject to AMR for LR.

Based on the audit teams evaluation, review of the AMPs and information contained in LRA Appendix A and Appendix B, the staff determined that the AMP QA elements are consistent with the staffs position regarding QA for aging management.

Documents Reviewed. The table below lists documents that were reviewed by the staff and were found relevant. The staff will document its review of this information in the SE.

Document Title Revision /

Date Report No. LUM00020- System and Structure Scoping Results Revision 1 REPT-001 Report No. LUM00020- System and Structure Scoping Revision 0 LRPI-001 Report Nos. Screening and Aging Management Reports Various LUM00020-Reports 004 - 034 Boundary Drawing LR- Plot Plan Revision 2 STRUCT-01 LRA AMP B.2.2.1, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP B.2.2.1, Fatigue Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL-LR Report (NUREG-1801, Revision 2) AMP X.M1, Fatigue Monitoring.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision /

Date TBX/TCX-IPA-AMP- Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 2 X.M1 Renewal Fatigue Monitoring Aging Management Program Basis 12/14/2022 Document WCAP-18711-P/NP Comanche Peak Units 1 and 2 NUREG/CR-6260 Revision 1 Environmentally Assisted Fatigue Results in Support of First 08/18/2022 License Renewal LTR-SDA-II-21 Comanche Peak Units 1 & 2 License Renewal: Primary Revision 1 P/NP Equipment and Piping Environmentally Assisted Fatigue 01/11/2022 Screening Evaluation Results LTR-SDA-II-21-28 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 2 Renewal - 60 Year Transient Projections for Class 1 RCS and 08/05/2022 Auxiliary Systems, Class 2 Heat Exchangers, and Class 1, 2 and 3 Valves STI-706 Station Administration Manual: Transient and Fatigue Cycle Revision 2 Monitoring 09/12/2014 15

Document Title Revision /

Date STI-706.01 Station Instruction Manual: Transient and Fatigue Cycle Revision 0 Monitoring 09/23/2014 CN-MRCDA-07-42 Comanche Peak Unit 1 and Unit 2 Power Uprate - Reactor Revision 1 Vessel Evaluation 08/07/2007 CN-RIDA-07-36 Comanche Peak Unit 1 and Unit 2 Reactor Internal Revision 0 Components Evaluation 2007 CN-SDA-II-19-014 Comanche Peak Units 1 and 2 Thermal Event and Fatigue Revision 0 Monitoring Update for 1/1/2018 to 12/31/2018 07/19/2019 CN-SDA-21-011 Comanche Peak Units 1 & 2 License Renewal: Primary Revision 1 Equipment and Piping Environmentally Assisted Fatigue 12/01/2021 Screening Evaluation Results ER-ME-103 Summary Information: Thermal Monitoring Data and Evaluation Revision 14 04/02/2018 LTR-SDA-II-21-02 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 5 Renewal Fatigue AOR Usage and Material Inputs 08/20/2021 LTR-SDA-II-21 Comanche Peak Unit 1 and 2 License Renewal: Class 2 and 3 Revision 2 P/NP Piping Fatigue Evaluation 08/10/2022 CN-SDA-21-012 Comanche Peak Unit 1 and Unit 2 60-Year Transient Cycle Revision 3 Projections 08/05/2022 LTR-SDA-II-21-42-P Comanche peak Unit 1 and 2 License Renewal: ASME Code Revision 1 Class 1 Piping High Energy Line Break (HELB) TLAA 12/5/2022 Evaluation LTR-SEE-21-31 Comanche Peak, Units 1 and 2, Transient Set and Cycles Revision 2 Considered in License Renewal Project 11/04/2021 WCAP-16477-P Addendum to Analytical Reports for the Comanche Peak Unit September 2005 No. 1 Reactor Vessel (Replacement Steam Generator Project)

CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring CR-2014-00818 Several Reactor Vessel Closure Stud/Hole Threads Have 07/16/2014 Incurred Damage Over the Life of the Plant Resulting in Stud/Hole Thread Loss CR-2015-002780 015 Strategic Self-Assessment of the Reactor Coolant System 03/26/2015 (RCS) Materials Management Program TR-2021-000782 Track and Document the Planning, Performance and Reporting 02/01/2021 for 2021 Self-Assessment for the Thermal Stratification Monitoring Program CR-2011-007576 Review and Implement (NEI 03-08) Needed Requirements of 07/05/2011 MRP-146, Rev. 1 During the audit, the staff verified the applicants claim that the detection of aging effects and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

The staff found that, for the scope of program, preventive actions, parameters monitored or inspected, acceptance criteria, and corrective actions program elements sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

During the audit, the staff made the following observations.

• In relation to the scope of program and preventive actions program elements, Enhancement 1 states that the program will be modified to include environmentally-16

assisted fatigue (EAF) analyses for locations that have been determined to be sentinel (limiting) locations through the EAF screening evaluation in addition to those listed in NUREG/CR-6260. The applicants approach for EAF analyses is described in LRA Section 4.3.4. However, the LRA does not clearly describe whether the applicant will use a staff-approved flaw tolerance analysis methodology (e.g., ASME Code,Section XI, Appendix L) if the applicant performs a flaw tolerance analysis to manage the effects of fatigue based on the results of the EAF analyses that are described in Enhancement 1.

• In relation to the preventive actions program element, Enhancement 2 states that the program will be modified, as needed, to monitor the environmental effects at the sentinel locations. However, the LRA does not clearly describe whether this enhancement addresses the monitoring of chemistry parameters that are used as input to the environmental cumulative usage factor (CUFen) calculations. The staff also needs clarification on whether the monitoring in this enhancement will ensure that the CUFen values do not exceed the design limit of 1.0 during the period of extended operation.

• In relation to the parameters monitored or inspected program element, Enhancement 3 states that the program will be revised to account for additional critical thermal and pressure transients for components that have been identified to have a fatigue TLAA.

During the audit, the applicant explained that the transients, which will be added to the cycle monitoring as part of this enhancement, will be based on the EAF analyses that are described in Enhancement 1. The applicant also indicated that the design transients in LRA Tables 4.3.1-2, 4.3.1-3 and 4.3.1-4 will be compared with the transients under cycle monitoring in this enhancement. However, the LRA does not clearly address how the applicant will determine the transients that are not be monitored for the period of extended operation (i.e., technical basis for not monitoring a transient).

• In relation to the acceptance criteria program element, Enhancement 4 states that the program will be modified to include acceptance criteria based on the 60-year cycle projections used in the supporting analyses. However, the LRA does not clearly describe whether this enhancement includes an acceptance criterion to ensure that CUFen values do not exceed the design limit of 1.0.

• In relation to the corrective actions program element, Enhancement 5 states that the program will be modified to provide clarity on when to initiate corrective action. However, the enhancement does not clearly explain what clarity will be specifically provided regarding when to initiate corrective action. The staff also need clarification on whether this enhancement includes corrective actions for new additional high-energy line break (HELB) locations (e.g., additional HELB analysis for newly identified break locations and their effects during the period of extended operation).

The staff also audited the description of the LRA Fatigue Monitoring AMP provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA AMP B.2.2.2, Environmental Qualification of Electric Components Summary of Information in the Application. The LRA notes that AMP B.2.2.2, Environmental Qualification of Electric Components, is an existing program with an enhancement that will be consistent with the program elements in GALL-LR Report X.E1, Environmental Qualification (EQ) of Electric Components.

17

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title/Description Revision /

Date LUM00020-REPT-038 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Environmental Qualification of Electric Components Aging Management Program Basis Document LUM00020-REPT-081 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal Time-Limited Aging Analysis-Environmental Qualification of Electrical Equipment DBD-EE-031 Comanche Peak Nuclear Power Plant Units 1 and 2 - Design- Revision 9 Basis Document - Environmental Qualification of Safety-Related Electrical Equipment TR-2018-000995 Tracking Report - Track Items Associated with the 2018 EQ Created:

Excellence Plan 02/05/2018 TR-2020-001719 Tracking Report - Review EPRI Technical Report A Review of Closed:

Equipment Aging Theory and Technology: Revision 1 of NP- 10/18/2020 1558 (Product ID 3002018283) for incorporation into the EQ program During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP, or will be consistent after implementation of the identified enhancement.

The staff also audited the description of the LRA Environmental Qualification of Electric Components provided in the FSAR supplement. The staff verified that the description is consistent with the acceptance criteria provided in SRP-LR Section 4.4.3.2.

LRA AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The LRA states that AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, & IWD is an existing program consistent with the program described in GALL-LR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, & IWD.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-039 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal ASME Section XI Inservice Inspection, Subsections IWB, 08/20/2020 IWC, & IWD Aging Management Program Basis Document CP-201900257 Unit 1 - Third Interval ASME Section XI ISI Program Plan Revision 2 04/17/2019 CP-201800909 Unit 2 - Third Interval ASME Section XI ISI Program Plan Revision 2 12/20/2018 CR-2016-003811 During ISI VT-3 Inspection for Pre-Outage 1RF18, Occurrence Date:

Strut SW-1-132-046-A43R (ISI Number SW-1-AB-001-H1) 04/27/2016 Failed Visual Exam Closed Date:

06/06/2016 18

CR-2014-003902 White Residue Found During 2RF14 ISI Exam of Control Rod Drive Occurrence Date:

Penetration 77 On Top of Unit 2 Reactor Vessel Head 04/05/2014 Closed Date:

04/12/2014 CR-2013-003784 During ISI LPT of Head-to-Shell Weld on the Letdown Reheat Heat Occurrence Date:

Exchanger, TBX-TRAHLR-01, a Linear Indication Was Found 04/08/2013 Closed Date:

08/06/2013 CR-2014-002396 IN 2014-02 Failure to Properly Pressure Test Reactor Vessel Occurrence Date:

Flange Leak Off Lines 02/28/2014 Closed Date:

06/16/2014 CR-2001-002837 The Potential for Alloy 600 Cracking in PWR Reactor Vessel Head Occurrence Date:

Penetrations Has Been Identified by the NRC in Bulletin 2001-01 12/04/2001 Closed Date:

01/13/2005 CR-2013-006188 IDDEAL Program Incorrectly Identifies Piping Welds Exam Occurrence Date:

Category 06/06/2013 Closed Date:

09/30/2013 CR-2019-009042 For Station Service Water System 30 Buried Supply Piping, Test Occurrence Date:

Instructions Fail to Specify and Document the Use of Temporary 11/21/2019 Flow Instrumentation and the Basis for Accepting Test Results is Closed Date:

Not Well Documented 10/01/2020 TR-2020-001247 IR Written to Track Implementation of NSAL-20-1, (Reactor Vessel Occurrence Date:

Head Control Rod Drive Mechanism Penetration Thermal Sleeve 11/21/2019 Cross-Sectional Failure) Closed Date:

10/01/2020 EPG-731 CPNPP Station Engineering Programs Manual, ASME Section XI Revision 6 Repair / Replacement Activities 03/16/2021 STA-730 CPNPP Station Administration Manual, Corrosion Monitoring Revision 5 Program 02/02/2010 EPG-703 CPNPP Engineering Programs Manual, Inservice Inspection Revision 4 Program 08/03/2014 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the LRA ASME Section XI Inservice Inspection, Subsections IWB, IWC, & IWD Program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.2, Water Chemistry Summary of Information in the Application. The LRA states that AMP B.2.3.2, Water Chemistry, is an existing program with one enhancement and one exception that will be consistent with the program elements in GALL-LR Report AMP XI.M2, Water Chemistry.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

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Document Title Revision / Date LUM00020-REPT-040 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal Water Chemistry Aging Management Program Basis Document CHM-120 Primary Chemistry Revision 15 CHM-130 Secondary Chemistry Revision 10 N/A Primary Chemistry Strategic Plan Revision 16 N/A Secondary Chemistry Strategic Plan Revision 10 STA-609 Reactor Coolant Water Chemistry Control Program Revision 14 STA-610 Secondary Water Chemistry Control Program Revision 15 TR-2020-004330 Perform a Self-Assessment of Primary Chemistry Occurrence date 06/08/2020 Closed date 01/25/2021 TR-2017-000399 This TR is created to track action items and document a targeted Occurrence date self-assessment on Secondary Chemistry 01/10/2017 Closed date 05/30/2017 TR-2021-001760 Unit 2 Steam Generator chemistry is showing indications of a Occurrence date possible condenser tube leak 03/10/2021 Closed date 10/27/2022 TR-2019-004928 Evaluation of corrosion for Unit 1 steam generators during 1RF20 Occurrence date establishing wet layup chemistry 05/13/2019 Closed date 06/18/2019 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also verified the applicants claim that aspects of the scope of program, program element not associated with the exception identified in the LRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-LR Report AMP.

The staff also audited the description of the LRA Water Chemistry Program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The LRA states that AMP B.2.3.3, Reactor Head Closure Stud Bolting, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-LR Report AMP XI.M3, Reactor Head Closure Stud Bolting.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

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Document Title or Description Revision / Date LUM00020-REPT-041 Comanche Peak Nuclear Power Plant Units 1 and Revision 1 2 License Renewal - Reactor Head Closure Stud Bolting Aging Management Program Basis Document LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and Revision 0 2 License Renewal Operating Experience Review CN-MRCDA-14-14 Comanche Peak Units 1 and 2 Reactor Vessel Revision 0 (PROPRIETARY) Closure Thread Damage Evaluation CR-2014-008181 Condition report on thread damage 07/16/2014 (Occurrence) 07/27/2015 (Closure)

CR-2019-003497 Condition report on water in stud holes 04/26/2019 (Occurrence) 08/20/2019 (Closure)

CR-2017-004534 and Condition reports related to stuck studs April 2017 and CR-2021-006481 October 2021 TR-2017-012881 Tracking report related to alternative lubrication for 11/21/2017 (Occurrence) the bottom threads of the reactor vessel head studs 09/20/2018 (Closure)

CR-2013-000912 Condition report on HydraNuts 01/28/2013 (Occurrence) 07/31/2013 (Closure)

MED-PCE-11320 Engineering Report for the Evaluation of the Stuck November 1991 Stud in the TU Electric Comanche Peak Unit No. 1 Reactor Vessel PCE-91-0055 (Appendix B of Out-of-Service Stud Evaluation November 1991 MED-PCE-11320) 1RF20 ISI Report.pdf Inservice Inspection Report at the Comanche Peak May 5, 2019 Nuclear Power Plant Unit 1 2RF19 ISI Report.pdf Inservice Inspection Report at the Comanche Peak October 29, 2021 Nuclear Power Plant Unit 2 MSM-C1-9901 Reactor Vessel Head Removal and Installation 09/30/20, Revision 7 (Unit 1)

MSM-C2-9901 Reactor Vessel Head Removal and Installation 09/14/21, Revision 10 (Unit 2)

During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. During the audit, the staff also verified the applicants claim that the preventive actions, and corrective actions program elements of the LRA AMP will be consistent with the corresponding elements of the GALL-LR Report AMP after implementation of the identified enhancements. In addition, the staff will consider issuing an RAI regarding the enhancement on the preventive actions program element.

The staff noted the exception to the preventive actions program element. The staff verified the applicants claim that the aspects of this program element not associated with the exception are consistent with the corresponding program element in the GALL-LR Report AMP.

During the audit, the staff made the following observations:

• The AMP basis document (LUM00020-REPT-041, Revision 1) states that the studs, nuts, and washers of CPNPP Unit 1 and the studs of CPNPP Unit 2 meet GALL-LR Report AMP guidance criterion of having actual yield stress values of less than 150 ksi.

The AMP basis document also states that the nuts and washers of CPNPP Unit 2 and HydraNuts and washers of both units have been identified as having some yield strength values from test results as high as 151.75 ksi but the average yield strength value is less 21

than 150 ksi; and that HydraNuts and washers are not currently used at both units for reactor head stud closure bolting application.

• The AMP basis document states that CPNPP reactor head closure stud bolting configuration does not have bushings.

• No recordable indications in the reactor head closure studs were found, as documented in the inservice inspection reports.

• Condition report CR-2014-008181 documents the plant-specific OE on thread damage.

• The staff will consider issuing an RAI in order to obtain the information to resolve OE related to thread damage.

The staff also audited the description of the LRA Reactor Head Closure Stud Bolting AMP (LRA Section A.2.2.3) provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.4, Boric Acid Corrosion Summary of Information in the Application. The LRA states that AMP B.2.3.4, Boric Acid Corrosion, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M10, Boric Acid Corrosion.

Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff conducted additional searches of the applicants CAP database, using alternate keywords.

The table below lists documents relevant to the program that were reviewed by the staff during the audit. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-042 Boric Acid Corrosion Aging Management Program Basis Revision 2 Document LUM00020-REPT-003 OE Review Revision 0 STA-737 Boric Acid Corrosion Detection and Evaluation Revision 8 STI-737.01 Boric Acid Corrosion Detection and Evaluation, Attachment 8A, Revision 1 Principal Locations of Potential Boric Acid Corrosion N/A BAAC Program Health Scorecard - 2021 First Half January 26, 2021 N/A BAAC Program Health Scorecard - 2020 First Half February 5, 2020 N/A BAAC Program Health Scorecard - 2019 First Half February 1, 2019 CR-2017-002887 While performing OPT-102A/B-7 found boric acid leaks March 4, 2017 CR-2017-005171 Corrosion discovered on Unit 1 CVCS pipe supports April 17, 2017 CR-2018-002385 Replace X-FIS-4847A due to small boric acid leak March 28, 2018 CR-2019-003467 Boric acid leak identified during Unit 1 mode 3 boric acid April 25, 2019 inspection CR-2019-003727 Excessive discolored boric acid identified on valve flange after May 1, 2019 insulation removal CR-2020-000145 Results of boric acid inspection on 2-02 containment spray heat January 7, 2020 exchanger CR-2021-0008469 Boric acid leaks identified during quarterly system walk down December 15, 2021 During the audit, the staff verified that applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and 22

trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also reviewed the FSAR summary of the Boric Acid Corrosion program provided in LRA Appendix A, Section A.2.2.4. The staff verified that this summary is consistent with the associated FSAR supplement in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The LRA states that AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-043 Cracking of nickel alloy components and loss of material due to Revision 2, boric acid-induced corrosion in reactor coolant pressure boundary 08/20/2022 components aging management program basis document TPEPG_EPG-9.07 Reactor Vessel Lower Head - Bottom-Mounted Instrumentation Revision 1, (BMI) Penetration Visual Examination 07/30/2020 TPEPG_EPG-9.08 Reactor Vessel Closure Head Visual Examination Revision 3, 09/22/2021 TPEPG_EPG-9.02 Comanche Peak Nuclear Power Plant (CPNPP) Alloy 600 Revision 3, management program 5/17/2019 OER-2018-009051 Operating experience report 07/22/2020 TPEPG_EPG-756 Nondestructive Examination Program Revision 6, 11/21/2016 CPNPP DM Weld Visual CPNPP Dissimilar Metal DM Weld Visual Examination Revision 6, Examination 04/12/2016 CR-2013-002005_1 Nondestructive Evaluation Improvement Focus Group Extent of 02/27/2013 Condition Actions in Response to North Anna Dissimilar Metal Weld Operating Experience LTR-SDA-II-20-19 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0, Renewal - Identification of Time Limited Aging Analyses 07/12/2021 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The NRC staff audited the applicants information regarding compliance with Table 1, Note 10 of ASME Code Case N-770-5, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation ActivitiesSection XI, Division 1, and the applicants AMP to address structural weld overlays (SWOLs) dissimilar metal butt welds in the reactor coolant pressure boundary. The applicant noted the NRC safety evaluation (SE) for the installation of the SWOLs (ML072270704) and WCAP-16681-P, Revision 2 showed compressive stress on each of the SWOLs to address the 23

concern of primary water stress corrosion cracking initiation or growth from the material of concern. The NRC staff reviewed and compared the WCAP-16681-P, Revision 2 weld residual stress profiles with similar geometries in independent calculations performed in NRC-sponsored research under, "Evaluation of Full Structural and Optimized Weld Overlays As Mitigation Strategies for Primary Water Stress Corrosion Cracking in Pressurized Water Reactors," Lee Fredette and Paul Scott, Battelle Columbus, April 2010 (ML101260540). Through this review the NRC staff found the applicants current AMP is effective to address implementation of Table 1, Note 10 of ASME Code Case N-770-5.

The staff also audited the description of the LRA Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components provided in the FSAR supplement. The NRC staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Summary of Information in the Application. The LRA states that AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel, is a new condition monitoring program that will be consistent with the program elements in GALL-LR Report AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision /

Date TBX-TCX-IPA-AMP- Comanche Peak Units 1 and 2 License Renewal, Thermal Revision 1 XI.M12 Aging Embrittlement of CASS Program Basis Document January 3, 2023 LTR-SDA-II-21-28 Comanche Peak Units 1 and 2 License Renewal, 60 Year Revision 2 Transient Projections, for Class 1 RCS and Auxiliary August 5, 2022 Systems, Class 2 Heat Exchangers, and Class 1, 2, and 3 Valves CR2012-002117 Strategic Self-Assessment of the RCS Materials Revision 1 Management System LTR-SDA-20-093-NP Comanche Peak Units 1 and 2 Reactor Coolant Pump Revision 0 Casings ASME Code Case N-481 Analysis for 60-Year April 14, 2021 License Renewal WCAP-10528-NP Technical Justification for Eliminating Large Primary Loop Revision 3 Pipe Rupture as the Structural Design-Basis for Comanche Peak Units 1 and 2 for the License Renewal Program (60 years)

LTR-SDA-20-087-NP Flaw Tolerance Evaluation for Susceptible Reactor Coolant Revision 0 Loop Cast Austenitic Stainless Steel Piping Components in September 24, Comanche Peak Units 1 and 2 for 60-Year License 2021 Renewal For the audit of the operating experience program element, the staff reviewed the OE provided by the applicant in the AMP basis document and on the ePortal. The staff performed a search of the operating experience database using keywords: flaw tolerance evaluation, N-481, pump casing, weld overlay, CF8M, thermal aging, surge nozzle examination, embrittlement, CASS and cast stainless steel. The staff will document its review of relevant OE in the SE.

24

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.7, PWR Vessel Internals Summary of Information in the Application. LRA states that AMP B.2.3.7, PWR Vessel Internals, is a new program (abbreviated PWRVIP) that will be consistent with the program elements in AMP XI.M16A, PWR Vessel Internals, of GALL-LR Report, Revision 2, as modified in Interim Staff Guidance (ISG) SLR-ISG-2021-01-PWRVI (ML20217L203). The staff also audited LRA Table 3.1-1, Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant System, and Table 3.1.2-2, Reactor Vessel Internals - Summary of Aging Management Evaluation.

Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff conducted additional searches of the applicants CAP database, using alternate keywords.

The table below lists documents that were reviewed by the staff and were found relevant to the AMP B.2.3.7 and to the AMR of PWR Vessel Internals. The staff will document its review of this information in the SE.

Title Revision /

Document Date LRA Section B.2.3.7 PWR Vessel Internals Revision 0 EPRI Non-Proprietary Materials Reliability Program: Pressurized Water Reactor June 2020 Report No. 3002017168 Internals Inspection and Evaluation Guidelines (MRP-227, ML20175A112 Revision 1-A)

NRC Safety Evaluation Final Safety Evaluation for Electric Power Research Institute April 25, 2019 Topical Report MRP-227, Revision 1, Materials Reliability ML19081A001 Program: Pressurized Water Reactor Internals Inspection and Evaluations Guideline Nuclear Energy Institute Guidelines for the Management of Materials Issues Revision 4 (NEI) Non-Proprietary ML20315A536 Report No. 03-08 NRC Interim Staff Updated Aging Management Criteria for Reactor Vessel January 2021 Guidance (ISG) No. SLR- Internal Components for Pressurized-Water Reactors ML20217L203 ISG-2021-01-PWRVI EPRI Proprietary Report Materials Reliability Program: Inspection Standard for PWR November 2018 No. 3002010399, MRP- Internals (MRP-228, Rev. 3). Proprietary, 228, Revision 3 ML19081A064; Non-proprietary, ML19081A058 LUM00020-REPT-005 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal Screening and Aging Management Review Report for the Reactor Vessel Internals LUM00020-REPT-044 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal PWR Vessel Internals Aging Management Program Basis Document PWROG OG-21-160 PWR Owners Group NEI 03-08 Needed Guidance: PWR September 2021 Lower Radial Support Clevis Insert X-750 Bolt Inspection Requirements.

PWROG-15105-NP PWR RV Internals Cold Work Assessment. Revision 0, April 2016 ML16222A300 WCAP-17451-P, Rev. 1 Reactor Internals Guide Tube Wear-Westinghouse Domestic Revision 1, Fleet Operational Projections. December 2013 25

Title Revision /

Document Date LR-ISG-2011-04 Final Updated Aging Management Criteria for Reactor Vessel ML12270A436 Internal Components for Pressurized Water Reactors NUREG-1801 Generic Aging Lessons Learned (GALL) Report, Revision 2, December 2010 ML103490041 NUREG-1800 Standard Review Plan for Review of License Renewal Revision 2, Applications for Nuclear Power Plants, SRP-LR December 2010 ML103490036 CPNPP FSAR Final Safety Analysis Report. Amendment 111 EPRI Letter No. MRP Transmittal of MRP-191-SLR Screening, Ranking and August 31, 2018 2018-022 Categorization Results and Interim Guidance in Support of ML19081A061 Subject License Renewal at U.S. PWR Plants NRC Subsequent License Updated Aging Management Criteria for Reactor Vessel Jan. 8, 2021 Renewal Interim Staff Internal Components for Pressurized-Water Reactors ML20217L203.

Guidance (SLR-ISG)

Document No. SLR-ISG-2021-01-PWRVI NUREG-2191, Volume 1 Generic Aging Lessons Learned for Subsequent License Feb. 7, 2017 Renewal (GALL-SLR) Report ML17187A031 Electric Power Research Materials Reliability Program: Pressurized Water Reactor December 2019 Institute (EPRI) Report Internals Inspection and Evaluation Guidelines MRP-227, ML20175A112 No. 3002017168, MRP- Revision 1-A 227, Revision 1-A LRA Table 3.1-1 Summary of Aging Management Programs for Reactor October 3, 2022 Vessel, Internals, and Reactor Coolant System LRA Table 3.1.2-2 Reactor Vessel Internals - Summary of Aging Management October 3, 2022 Evaluation During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

During the audit, the staff verified that the applicant addressed the guidance in SRP-LR Section A.1.2.3 for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP.

During the audit, the staff made following observations regarding AMP B.2.3.7:

• Audit AMP Topic No. 1 The staff observed that, in relation to the detection of aging effects program element of AMP XI.M16A of GALL-LR Report, Revision 2, LRA Section B.2.3.7 indicates that the CPNPP AMP will implement the guidelines in PWR Owners Group (PWROG) letter OG-21-160 as an additional guideline to address clevis insert degradation. The OG 160 report provides new guidance for ultrasonic testing (UT) inspections of the clevis insert bolts. The current aging management basis for clevis insert bolts and wear surfaces in Item W14 in Table 4-9 of MRP-227, Revision 1-A only calls for VT-3 visual inspections per the ASME Code,Section XI, of the clevis insert bolts and wear surfaces, as modified by the VT-3 visual examination criteria in Westinghouse Bulletin No.

TB-14-5. The staff notes that Item W14 in Table 4-9 of MRP-277, Revision 1-A does not 26

include or reference use of OG-21-160, although the OG-21-160 guidance was added to Item W14 in MRP 2018-022.

During the audit, the staff asked the applicant to discuss how Item W14 in Table 4-9 of MRP-227, Revision 1-A will be implemented during the period of extended operation for the CPNPP units and the scope of supplemental Westinghouse or PWROG guidance that will be implemented under the inspection and evaluation (I&E) criteria. In addition, if the guidance in OG-21-160 will be implemented in addition to Westinghouse Bulletin No. TB-14-5, the staff asked the applicant to discuss whether OG-21-160 will be identified as an Enhancement of Item W14 in Table 4-9 of MRP-227, Revision 1-A and an enhancement as part of LRA Section B.2.3.7. The applicant stated that currently, the PWRVI AMP is written to be consistent with the guidance contained in MRP-227, Revision 1-A. However, as stated in the AMP description in LRA Section B.2.3.7, the program will implement the requirements of Revision 1-A or the latest NRC-approved version of MRP-227. The applicant further stated that the PWRVI AMP at CPNPP will be implemented in accordance with NEI 03-08. Therefore, the applicant will evaluate NEI 03-08 Needed guidance, such as OG-21-160, and track the issue in its Alloy 600, ISI, and Reactor Internals Plan. Given that GALL-LR Report AMP XI.M16A permits use of supplemental methodologies in addition to MRP-227, Revision 1-A and that OG 160 provides additional guidance for performing UT inspections of clevis insert bolts, the staff considers this technical topic to be closed for the audit.

• Audit AMP Topic No. 2 The staff observed that, in relation to detection of aging effects, monitoring and trending, and operating experience program elements of AMP XI.M16A, LRA Section B.2.3.7 discusses industry OE of upper and lower assembly fuel alignment pins that have shown surface breaking indications induced by wear, as evaluated in Westinghouse Technical Bulletin No. TB-14-6. The applicant indicated that recommendations for managing wear in the pins is given in Westinghouse Bulletin TB-14-6 but clarified that the guidance only applies to the fuel alignment pins made from Type 304 stainless steel (SS) with a malcomized surface treatment. The applicant stated that this OE is not applicable to CPNPP because the fuel alignment pins at CPNPP are made of cold-worked Type 316 SS (316 SS). The staff notes that MRP-227, Revision 1-A is not to be used as a replacement for implementing ASME Code,Section XI inspections of reactor vessel internal components that are designated as ASME Code Class Internal components in the CLB.

During the audit, the staff asked the applicant to discuss whether the fuel alignment pins in the upper and lower reactor internal assemblies at CPNPP units are designed as ASME Code,Section XI Examination Category B-N-3 components. If so, discuss whether the ASME Code,Section XI inspection will be performed on the alignment pins regardless the alignment pins do not include a malcomized surface that would make them susceptible to wear. The staff also asked about whether the design of the alignment pins at CPNPP are susceptible to cracking based on the cold working of the 316 SS materials that were used in fabrications of the alignment pins. The applicant stated that fuel alignment pins at CPNPP are designed as Category B-N-3 components and are therefore inspected in accordance with the ASME Code,Section XI. As such, line items in LRA Table 3.1.2-2 for Examination Category B-N-3 internals components are inclusive of the fuel alignment pins. The applicant further stated that the cold-worked type 316 SS fuel alignment pins are susceptible to cracking per PWROG-15105-NP, 27

which assumes greater than 20% cold-work for 316 SS fuel alignment pins. However, the applicant explained that because the fuel alignment pins are not made from type 304 SS, the guidance of Westinghouse TB 16-4 is not applicable to CPNPP. The applicant indicated that no relevant flaws related to the 316 SS fuel alignment pins were identified during past ASME Section XI visual VT-3 inspections performed on the fuel alignment pins. Given that the staff has confirmed that cracking in the upper and lower fuel alignment pins is appropriately addressed by the generic AMR item in LRA Table 3.1.2-2 and that GALL-LR Report AMP XI.M16A permits VT-3 visual inspection methods to be applied as an nondestructive examination (NDE) method for managing cracking in redundant RVI component types (e.g., the fuel alignment pins), the staff considers this technical topic to be closed for the audit.

• Audit AMP Topic No. 3 The staff observed that, in relation to detection of aging effects, monitoring and trending, and operating experience program elements of AMP XI.M16A, LRA Section B.2.3.7 discusses industry OE with loss or material due to wear in Westinghouse-design control rod guide tube (CRGT) assembly support plates (guide cards) and how these components will be managed as Primary-category components at CPNPP using visual inspections in Westinghouse Proprietary Report No.

WCAP-17451-P, Revision 1. The staff noted that inspections of Westinghouse-design CRGT guide plates (guide cards) are covered by Item W1 in Tables 4-3 and 5-3 of MRP-227, Revision 1-A. The fourth paragraph in LRA Section B.2.3.7 on page B-60 states that during the Spring 2022 outage, all 53 Unit 1 guide tubes and associated guide cards were inspected and measured for wear based on guidance in Westinghouse report, WCAP-17451, Revision 1. The applicant stated that the low wear levels were observed at Unit 1. The applicant further stated that it will inspect Unit 2 guide cards in Spring 2023. Item W1 in Tables 4-3 and 5-3 of MRP-227, Revision 1-A includes the CRGT guide cards as Primary-category components that are subject to VT-3 visual inspections for wear-type flaw indications, without any designated or linked Expansion category components. Item W1 indicates that the inspections are done per the guidance in Westinghouse report, WCAP-17451, Revision 1. However, contrary to Item W1 in Table 4-3 of MRP-227, Revision 1-A, WCAP-17451, Revision 1 indicates that there are two types of Westinghouse CRGT assembly components that serve as Expansion components for Westinghouse-design CRGT guide cards, instead of being the Primary component.

During the audit, the staff asked the applicant to discuss CRGT guide card inspections and the results of past inspections performed at Unit 1. Specifically, the staff asked whether there are applicable Expansion components for the CRGT guide cards in LRA Section B.2.3.7. If so, identify the linked Expansion-category components for the Primary-category CRGT guide cards in the AMP. Also, the staff asked that if there are applicable Expansion-category components for the CRGT guide cards, whether the degree of wear detected from the Unit 1 inspections sufficient to call for sample-expansion to the linked CRGT Expansion-category component types. The applicant indicated that the date for the Unit 2 guide card inspection is incorrect. The applicant stated that a supplement is needed to correct this date from Spring 2023 to Fall 2024.

The applicant further stated that its document WO-5954259 provides an evaluation and conclusions of the minimal guide card wear observed during the initial Unit 1 inspections.

The applicant further stated that there are no applicable Expansion components for the CRGT guide cards because MRP-227, Revision 1-A does not provide an Expansion 28

link component for guide cards. The applicant explains that MRP-227, Revision 1-A references WCAP-17451-P, Revision1 for additional examination and acceptance criteria. The applicant further stated that should significant wear be detected on the CRGT guide cards, the guidance of WCAP-17451-P will be used. The staff will confirm that the Unit 2 guide card inspection is changed from Spring 2023 to Fall 2024 in an applicants supplement when preparing the SE. Based on the explanations from the applicant, the staff considers the inspection bases for the CRGT guide cards and linked Expansion-category components (as specified in WCAP-17451-P, Revision 1) to be closed for the audit.

• Audit AMP Topic No. 4 The staff observed that, in relation to PWRVIPs detection of aging effects, monitoring and trending, and operating experience program elements, LRA Section B.2.3.7 discusses industry OE with PWR control rod drive mechanism (CRDM) penetration nozzle thermal sleeves, as discussed and evaluated in Westinghouse Nuclear Safety Advisory Letters NSAL-18-01 and NSAL-20-01, Revision 1, and the guidelines in EPRI Letter MRP-2018-027. The staff observed that the third paragraph on page B-61 of the LRA states that At CPNPP, baseline inspections [of the CRDM thermal sleeves] were completed during the Fall 2021 outage for Unit 2. Normal wear was found during visual inspections with a recommendation to re-inspect within six cycles. Baseline inspections for Unit 1 were completed during the Spring 2022 outage, also showing normal wear with a recommendation to re-inspect in 12 cycles The staff noted that the re-inspection for the thermal sleeve flange wear at Unit 2 is 6 cycles but for Unit 1 the re-inspection is 12 cycles.

During the audit, the staff asked the applicant to confirm whether Unit 1 has a longer re-inspection interval because Unit 1 has a new reactor pressure vessel (RPV) head which has not had significant wear at the thermal sleeve flange. The applicant explained that the re-inspection interval is longer for Unit 1 because significantly less thermal sleeve flange wear than Unit 2 was observed during the initial measurements, due to the fact that the Unit 1 replacement RPV head has a shorter operating duration than the Unit 2 head. The applicant stated that initial wear measurements, evaluation, and conclusions are included in WO-5998393 for Unit 1 and WO-5668060 for Unit 2. Based on the applicants explanations, the staff considers the re-inspection interval for CPNPP CRDM penetration nozzle thermal sleeves to be closed for the audit.

• Audit AMP Topic No. 5 The staff observed that, in relation to PWRVIPs detection of aging effects, monitoring and trending, and operating experience program elements, LRA Section B.2.3.7 discusses inspection categories, inspective and evaluation criteria, relevant OE with Westinghouse-design core barrel (CB) assembly upper girth welds (UGWs) and upper flange welds (UFWs). The staff noted that in MRP-277, Revision 1-A, Table 4-6, the CB assembly UGW is established as an Expansion-category Item W3.1 weld for the linked Primary-category Item W3 UFW in Table 4-3 of MRP-227, Revision 1-A. The staff further noted that recently the licensee for an U.S. Westinghouse-design nuclear plant detected several significant circumferential flaws in the CB UGW of that unit during the Fall 2022 refueling outage.

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During the audit, the staff asked that considering recent OE of the degraded UGW in a domestic PWR plant, discuss whether CPNPP will inspect the CB UGWs in the near future. The staff also asked the applicant to discuss whether the UFWs and UGWs are designated as ASME Code,Section XI Examination Category B-N-3 weld for the CB assemblies. If so, discuss whether past ASME Code,Section XI VT-3 inspections have identified any flaws in the UFWs and UGWs. The applicant stated that CPNPP is currently following the CB focus group, made up of EPRI, Westinghouse, and industry experts. The applicant stated that developments from the industry focus group will be tracked under TR-2023-001108. Presently, CPNPP will follow the guidance of MRP-227, Revision 1-A. The applicant confirmed that UFWs and UGWs are part of the Category B-N-3 examination population at CPNPP. The applicant reported that no relevant flaws in these welds have been identified throughout past inspections performed on the welds. Given that the applicant has inspected the UGWs and is following the guidance of the industry focus group, this the staff considers this technical matter to be closed for the audit.

During the audit, the staff observed the following regarding the AMR of PWR Vessel Internals:

The staff noted that the applicant is conservatively using the updated set of AMR items for PWR RVI components in SRP-SLR Table 3.1-1 and GALL-SLR Report Table IV.B2 (as updated in SLR-ISG-2021-01-PWRVI) as the AMR item basis for the PWR RVI components at CPNPP.

The staff noted that this is permitted as an AMR development option for initial LRA PWRVIPs that have converted over to the EPRI MRP guidance in MRP-227, Revision 1-A, as discussed and clarified on Page 5 of SLR-ISG-2021-01-PWRVI. Thus, while the AMR items in SLR-ISG-2021-01-PWRVI are identified as being applicable to subsequent LRAs, they can be applied to initial LRA PWRVIPs at CPNNP that are based on MRP-227, Revision 1-A (without the need for a gap analysis of the MRP-227, Revision 1-A guidelines from 60 to 80 years).

• Audit AMR Topic No. 1 Items IV.B2.RP-345a and IV.B2.R-424 in LRA Table 3.1.2-2 on page 3.1-83 are identified as bottom-mounted instrumentation (BMI) flux thimble tubes with Notes C, D, and E. These two items are correlated to aging effects of loss of fracture toughness due to irradiation embrittlement (IE), loss of material due to wear, change of dimensions to void swelling (VS) or distortion, and loss of preload due to irradiation-assisted stress relaxation or creep (ISR/IC) that are associated with Items IV.B2.RP-345a, IV.B2.RP-345 and IV.B2.R-424 in Table 3.1-1 of SLR-ISG-2021-01-PWRVI and/or GALL-SLR Report.

The staff observed that these line items apply to the reactor vessel internal portion of the flux thimble tubes, which are not part of the reactor coolant pressure boundary.

However, the BMI flux thimble tubes extend to the outside of the reactor vessel which become part of pressure boundary and are associated with GALL/GALL-SLR Report Items IV.A2.RP-28, -154 and -284 (as updated in SLR-ISG-2021-01-PWRVI) in LRA Table 3.1.2-1 (page 3.1-62). The aging effects for portions of the flux thimble tubes outside of the RPV are different from the portions of the flux thimble tubes that are located inside of the RPV. However, the staff observed that LRA Section 3.1.2.2.9 (LRA page 3.1-13), indicates that the internal, non-reactor coolant pressure boundary portions of the flux thimble tubes are No Additional Measures components per MRP-227, Revision 1-A, as linked to SRP-SLR Table 3.1-1, Item 3.1-1, 055c and GALL-SLR Report Item IV.B2.RP-265.

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During the audit, the staff noted that a potential discrepancy exists regarding: (1) which line item or items should be used for the PWR vessel internals portions of the flux thimble per LRA Section 3.1.2.2.9 and those cited for the flux thimble tube non-pressure boundary portions in Table 3.1.2-2, and (2) whether the PWR vessel internal, non-pressure boundary portions of the BMI flux thimble tubes are being subject to MRP-227 aging management activities (i.e., condition monitoring inspections).

The applicant stated that the last paragraph of LRA Section 3.1.2.2.9 currently states that flux thimble tubes are No Additional Measures components. However, this section should be amended to state that flux thimble tubes are Existing Programs components, as discussed in Item 3.1-1, 053c. The applicant stated that no discrepancy exists in either Table 3.1.2-1 or Table 3.1.2-2 except that LRA Section 3.1.2.2.9 contains an error, Flux thimble tubes are not linked to item 3.1-1, 055c, but are instead linked to item 3.1-1, 053c. The staff will confirm that the applicant has amended the LRA Section 3.1.2.2.9 when preparing its SE.

• Audit AMR Topic No. 2 LRA Table 3.1.2-2, page 3.1-96, includes line items, IV.B2.RP-289 and IV.B2.RP-345 on cracking of the CB flanges that align to GALL-SLR Report Item IV.B2.RP-289 using either Note C or D. However, the staff noted that the applicable and corresponding Item IV.B2.RP-289 in SLR-ISG-2021-01-PWRVI applies specifically to MRP-227 Existing Program bases for Westinghouse-design lower core plates or extra-long lower core plates. The plates are subject to ASME Code,Section XI VT-3 visual inspections per Item W12.a in Table 4-9 of MRP-227, Revision 1-A and for loss of material due to wear per Item W12.b in Table 4-9 of MRP-227, Revision1-A. The staff also noted that GALL-SLR Report (as updated inclusive of changes made in SLR-ISG-2021-01-PWRVI) does not include an applicable AMR item for cracking of CB flanges.

During the audit, the staff asked the applicant to confirm that the aging effect of cracking on CB flanges associated with line item IV.B2.RP-289 is included in LRA Table 3.1.2-2 on page 3.1-83. The staff tried to determine that CB flange is aligned with Item IV.B2.RP-289 in SLR-ISG-2021-01-PWRVI for the ASME Section XI, VT-3 visual inspections that will be applied to the Existing Program category CB flanges per Item W10 in MRP-227, Revision 1-A. The applicant stated that Item IV.B2.RP-289, which credits the PWRVI and water Chemistry AMPs for management of cracking, is applied to CB flanges. The applicant further stated that the VT-3 visual inspections will be applied through the PWRVI AMP to confirm the effectiveness of the preventive maintenance Water Chemistry AMP. Based on the applicants explanations, the staff consider this technical topic to be closed for the audit.

• Audit AMR Topic No. 3 LRA Table 3.1.2-2, page 3.1-96 includes line items for neutron shield panel support pins that align to GALL-SLR Report Items IV.B2.RP-271 and IV.B2.RP-272 Note C or D.

These line items manage irradiation-assisted stress corrosion cracking (IASCC) and fatigue induced cracking, loss of material due to wear, loss of preload due to ISR/IC, and loss of fracture toughness due to IE in the pins. The staff noted that these two items also apply to management of applicable cracking, loss of preload, loss of fracture, changes in dimensions, and loss of material mechanism in Primary-category Westinghouse-design 31

baffle-to-former bolts using GALL-LR Report AMP XI.M16A, where the bolts are subject to augmented aging management inspections per Item W9 in Table 4-3 of MRP-227, Revision 1-A.

The staff observed that the LRAs adoption of these two items under Note C or D bases could only be applied to the neutron shield panel support pins if the pins were subject to augmented Primary item inspections in the manner that Primary-category UT inspections are applied to and performed on Westinghouse-design baffle-former-bolts per Item W9 in Table 4-3 of MRP-227, Revision 1-A. However, the staff observed that, in MRP-227, Revision 1-A, all neutron shield panel components are placed in the No Additional Measures category because the pins do not screen-in for any aging effects per MRP-227, Revision 1-A.

During the audit, the staff asked the applicant to discuss the discrepancies on the AMR items provided for neutron shield panel supports pins on LRA page 3.1-96. Specifically, (1) Will the referenced AMR line items for the neutron shield panel support pins be subject to augmented, Primary-category inspections per a plant-specific adjustment of the MRP-227, Revision 1-A protocols? (2) If the neutron shield panel support pins are justified for placement in the No Additional Measures category of AMP B2.3.7, discuss why LRA Table 3.1.2-2 is not giving a single line item for the neutron shield panel support pins that aligns to SRP-SLR Table 3.1-1, Item 3.1-1, 055c and GALL-SLR Report Item IV.B2.RP-265?

The applicant stated that neutron panel support pins will not be subject to augmented, primary-category inspections to be consistent with MRP-227, Revision 1-A. The applicant further stated that neutron shield panel support pins were conservatively included as primary components, akin to the management of thermal shield flexures for sites which utilize thermal shields. However, the applicant explained that, upon further consideration, the items for neutron shield panel support pins in LRA Table 3.1.2-2 which are linked to Items 3.1-1, 053a and 3.1-1, 059a should be deleted items as No Additional Measures in LRA Table 3.1.2-2. The staff will confirm that the applicant has amended the LRA when preparing the SE.

• Audit AMR Topic No. 4 LRA Table 3.1.2-2, page 3.1-97, includes line items IV.B2.RP-285 and IV.B2 RP-399 for radial support keys and associated bolts that align to either GALL-SLR Report Items IV.B2.RP-285 or RP-399 using Note C or D. These line items manage IASCC and fatigue induced cracking, changes in dimension due to VS or distortion, loss of material due to wear, loss of preload due ISR/IC, and loss of fracture toughness due to IE in the radial support key components.

The staff noted that the cross-referenced GALL-SLR Report Items IV.B2.RP-285 and IV.B2.RP-399 items (as updated in SLR-ISG-2021-01-PWRVI) apply to aging management of cracking due to stress corrosion cracking or fatigue, loss of material due to wear, and loss of preload due to ISR/IC (bolts only) in RPV interfacing clevis insert assembly components, including bolts or screws, dowels, and clevis insert surfaces. The staff observed that the GALL-LR Report line item calls out the ASME Code,Section XI inspection-based Existing Program criteria in Item W14 of Table 4-9 in MRP-227, Revision 1-A for the clevis insert assembly component types. The GALL-LR Report, Revision 2, and GALL-SLR Report do not include any similar Existing Program-based 32

AMR line items for the radial support key components. However, the staff observed that EPRI MRP added the radial support keys in as new Existing Program components in MRP-2018-022.

During the audit, the staff asked the applicant to discuss Note C or D-related AMR line items for radial support keys and associated bolts in LRA Table 3.1.2-2, page 3.1-97.

Specifically, the staff asked whether the proposed AMR line items are conservatively being included in LRA Table 3.1.2-2. page 3.1-97, to add in the radial support keys and associated bolts as ASME Code, Section XI-based Existing Program components for the LRA AMP B2.3.7 and the referenced aging effects, such that LRA Table 3.1.2-2 is consistent with the updated EPRI recommendations for Westinghouse-design radial support keys in MRP 2018-022.

The applicant stated that radial support keys and associated bolts were conservatively included as Existing Programs components in LRA Table 3.1.2-2 as integral alignment and interfacing components. The staff observed that this is consistent with the EPRI MRP supplemental guidelines in MRP 2018-022, which assesses aging through an 80-year subsequent LR service period and is conservative for the assessment of aging in the CPNPP RVI components through a 60-year service period. Thus, the staff considers this matter to be closed for the audit.

• Audit AMR Topic No. 5 LRA Table 3.1.2-2, page 3.1-98, includes two line items for the upper internals assembly (UIA) support ring that aligns to GALL-SLR Report Item IV.B2.RP-288 using Note C.

These two line items manage loss of fracture toughness due to IE and loss of material due to wear in the UIA support rings. The staff observed that the cross-referenced Item IV.B2.RP-288 in SLR-ISG-2021-01-PWRVI applies to aging management of loss of material due to wear, and loss of fracture toughness due to IE, and changes in dimension due to VS or distortion.

During the audit, the staff asked the applicant to discuss the basis for the Note C or D-related AMR line items for the UIA support rings on LRA page 3.1-98. Specifically, the staff asked the applicant to confirm whether the proposed AMR line items are conservatively being included in LRA Table 3.1-2, page 3.1-98, to add loss of fracture toughness and loss of material due to wear as aging effects (i.e., in addition to cracking) for the ASME Code, Section XI-based Existing Program criteria for the UIA support rings that are aligned to Item W11 of Table 4-9 in MRP-227, Revision 1-A. The staff also asked whether the IV.B2.RP-288 based line items for UIA support ring in LRA Table 3.1.2-2 need to include an associated AMR line item on aging management of changes in dimension due to VS or distortion in the UIA support rings to be consistent with Item IV.B2.RP-288 in SLR-ISG-2021-01-PWRVI.

The applicant stated that the items in LRA Table 3.1.2-2 for loss of fracture toughness and loss of material of the UIA support ring were conservatively included. However, the applicant stated that, upon further consideration, these items should be deleted from LRA Table 3.1.2-2, leaving only the items for cracking of the UIA support ring, consistent with MRP-227, Revision 1-A. The staff will confirm that the applicant has amended the LRA 3.1.2-2 when preparing the SE.

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• Audit AMR Topic No. 6 LRA Table 3.1.2-2, pages 3.1-91 to 3.1-96, includes a number of AMR line items for lower support columns and associated column components that align to GALL-SLR Report Item IV.B2.RP-290 (for non-cracking effects) or IV.B2,RP-291 (for cracking) using Note A or B. These items correspond to Expansion Item W4.4 in Table 4-6 of MRP-227, Revision 1-A. However, the line item entries in LRA Table 3.1.2-2 differentiate between the lower support column components in Unit 1 and Unit 2.

During the audit, the staff asked the applicant to discuss any unit-specific differences between the design of the lower support columns and associated components in Unit 1 from those that are included in Unit 2. The staff further asked that if applicable, whether those design differences will cause any adjustments of the MRP-227, Revision 1-A I&E protocols for the Expansion-Category Item W4.4 in Table 4-6 of MRP-227, Revision 1-A, independent of whether the lower support columns are made from either cast austenitic stainless steel (CASS) materials or wrought SS materials.

The applicant stated that, as discussed in Section 4.1 of RVI screening and AMR document LUM00020-REPT-005, the core support columns and sleeves for Unit 1 are constructed from CASS (A351, Gr. CF8 or CF8A), whereas core support columns and sleeves for Unit 2 are constructed from 304 stainless steel. The applicant also explained that the material differences between Units 1 and 2 will not cause any adjustment of the MRP-227, Revision 1-A I&E protocols. The applicant stated that there is no significant difference in configuration of the core support columns between the two units. Based on the applicants explanations, the staff confirmed that thermal embrittlement has been generically eliminated as a concern for CF8 CASS lower support columns, as evaluated in Section 3.6.7 of the staffs April 25, 2019, SE for MRP-227, Revision 1-A. Therefore, based on the applicants explanations and staffs SE for MRP-227, the staff considers this matter to be closed for the audit.

• Audit AMR Topic No. 7 LRA Table 3.1.2-2, pages 3.1-85 to 3.1-86 includes line items for aging management of loss of material due to wear in the Primary Item W1 CRGT guide plates (i.e., CRGT guide cards). The staff noted that line Item IV.B2.RP-386 in Table IV.B2 of GALL, Revision 2 covers management of loss of material due to wear in Westinghouse-design CRGT C-tubes and sheaths. However, LRA Table 3.1.2-2 does not include corresponding AMR items for the CRGT C-tubes and sheaths.

During the audit, the staff asked the applicant to discuss why LRA Table 3.1.2-2 does not include any AMR item or items for managing loss of material due to wear in the CRGT C-tubes and sheaths. The applicant indicated that a line item for CRGT assemblies: C-tubes and sheaths with a structural support intended function, managing loss of material due to wear, and linked to GALL-LR Report Item IV.B2.RP-386 should be added to LRA Table 3.1.2-2. In addition, the applicant stated that a corresponding item for C-tubes and sheaths should be added to LRA Table 2.3.1-2. The applicant clarified that as identified in Section 4.1 of RVI screening and AMR document LUM00020-REPT-005, CRGT C-tubes and sheaths are constructed from 304 stainless steel. The staff will confirm that the applicant has amended the LRA 3.1.2-2 when preparing the SE.

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• Audit AMR Topic No. 8 LRA Table 3.1.2-2 does not include any component-specific AMR line items for CRGT support pins (spilt pins) that are included in the CPNPP unit-specific CRGT assembly designs. The staff noted that in SRP-SLR Table 3.1-1, Item 028 (as updated in SLR-ISG-2021-01-PWRVI), the basis for managing Westinghouse-design CRGT spilt pins was dependent on whether the pins were made from X-750 nickel-based alloy materials (versus Type 316 SS materials), and whether the spilt pins were designated as Examination Category B-N-3 components of Table IWB-2500-1 of the ASME Code,Section XI, where the ASME Section XI inspections would be credited for aging management of cracking in the pins.

The staff also observed that in the updated SRP-SLR Table 3.1-1, Item 028 (as updated in SLR-ISG-2021-01-PWRVI), the staff permitted CRGT split pins made from type 316 stainless pins (and not subject to ASME Code Class inspections credited for aging management) to be placed in the No Additional Measures category, as consistent with the criteria established for CRGT spilt pins in MRP-227, Revision 1-A. The staff notes that this is predicated on the condition that, if CRGT spilt pins are ASME Code Class components, the ASME Section XI inspections of the pins are not credited for Existing Program credit in MRP-227, Revision1-A such that the ASME inspections of the pins would be credited under the applicants AMP B.2.3.1 ISI Program per the staffs update of GALL-SLR Report Item IV.E.R-444 in the SLR-ISG-2021-01-PWRVI.

During the audit, the staff asked the applicant to discuss how the CRGT split pins are being managed for cracking consistent with criteria defined in the GALL-SLR Item column entry of Table 3.1-1, Item 028, in SLR-ISG-2021-01-PWRVI. The staff asked the applicant to discuss the following design-basis for the CRGT spilt pins: (1) material of fabrication for the pins in both units, (2) whether the CRGT spilt pins in both units are original pins or replacement pins, (3) whether the CRGT spilt pins are defined as ASME Code Class 1 components in the design-basis and are required to be inspected periodically under Examination Category B-N-3 of Table IWB-2500-1 of the ASME Code,Section XI, and (4) if the pins are ASME Code Class components, discuss whether the ASME Section XI inspections scheduled for the CRGT split pins are being credited for aging management of cracking in the pins per the LRA AMP B.2.3.1, ASME Section XI ISI Program versus ASME-based Existing Program basis in the LRA AMP B.2.3.7.

The applicant explained that the split pins in both Unit 1 and Unit 2 were replaced in 2004 and 2005, respectively, and that the replacement pins are made from Type 316 SS as a replacement material for the design of the original pins, which were made from Alloy X-750 Nickel-based alloy materials. The applicant also explained that the replacement CRGT split pins are Examination Category B-N-3 components of Table IWB-2500-1 of the ASME Code,Section XI. As such, the generic line items linked to GALL-SLR Report Item IV.E.R.444 (as updated in SLR-ISG-2021-01-PWRVI) for SS ASME Code,Section XI B-N-3 vessel internals components in LRA Table 3.1.2-2 are inclusive of the split pins. Based on the applicants explanations, the staff confirmed that the applicant is appropriately managing age-related degradation in the CRGT split pins using the applicants inservice inspection AMP. Therefore, the staff considers this matter to be closed for the audit.

35

The staff also audited the description of the LRA AMP B.2.3.7 provided in the FSAR supplement in LRA Appendix A, Section A.2.2.7. The staff verified that the description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.8, Flow-Accelerated Corrosion Summary of Information in the Application. The LRA states that AMP B.2.3.8, Flow-Accelerated Corrosion, is an existing condition monitoring program with an exception and enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M17, Flow-Accelerated Corrosion, as amended by ISG LR-ISG-2012-01, Wall Thinning Due to Erosion Mechanisms.

Audit Activities. The table below lists documents relevant to the program that were reviewed by the staff during the audit. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-045 Flow-Accelerated Corrosion Aging Management Program Basis Revision 1 Document LUM00020-REPT-003 Operating Experience Review Revision 0 EPG-9.04 Flow-Accelerated Corrosion Program Revision 3 STA-730 Corrosion Monitoring Program Revision 5 STA-170-1 Software Quality Assurance Form FAC Manager September 13, 2019 1RF22 EOC End of Cycle Report (November 2020 to April 2022) December 22, 2022 1RF21 EOC End of Cycle Report (May 2019 to October 2020 February 1, 2021 1RF20 EOC End of Cycle Report (November 2017 to April 2019) December 3, 2020 2RF19 EOC End of Cycle Report (Spring 2020 to Fall 2021) November 17, 2022 2RF18 EOC End of Cycle Report (January 2019 to April 2020) January 25, 2021 2RF17 EOC End of Cycle Report (May 2017 to December 2018) December 3, 2020 TERPT ER-ME-093 Flow-Accelerated Corrosion System Susceptibility Analysis for Revision 0 Comanche Peak Unit 1 TERTP ER-ME-095 Flow-Accelerated Corrosion CHECWORKS Database for Revision 0 Comanche Peak Unit 1 11-2235-TR-001 Flow-Accelerated Corrosion Program System Susceptibility Revision 0 Evaluation and Susceptible Non-Modeled Line Review During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP with the proposed enhancements will be consistent with the corresponding elements of the GALL-LR Report AMP, as amended by LR-ISG-2012-01.

The staff also reviewed the FSAR summary of the Flow-Accelerated Corrosion program provided in LRA Appendix A, Section A.2.2.8. The staff verified that this summary is consistent with the associated FSAR supplement in SRP-LR, Table 3.0-1, as amended by LR-ISG-2012-01, and appropriately documented the exception being taken to the earlier program guidance.

LRA AMP B.2.3.9, Bolting Integrity Summary of Information in the Application. The LRA states that AMP B.2.3.9, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M18, Bolting Integrity.

36

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only describe extent of audit (e.g., the program elements described in the applicants basis document).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-046 CPNPP Units 1 and 2 License Renewal, Bolting Integrity Aging Revision 1 Management Program Basis Document LUM00020-REPT-039 CPNPP Units 1 and 2 License Renewal, ASME Section XI Revision 1 Inservice Inspection, Subsections IWB, IWC, and IWD, Aging Management Program Basis Document LUM00020-REPT-041 CPNPP Units 1 and 2 License Renewal, Reactor Head Closure Revision 1 Stud Bolting Aging Management Program Basis Document LUM00020-REPT-066 CPNPP Units 1 and 2 License Renewal ASME Section XI, Revision 1 Subsection IWE Aging Management Program Basis Document STI-748.01 CPNPP Station Instruction Manual, System Monitoring and Revision 3 Health Reporting MSG-0695 CPNPP Maintenance Section - Generic Manual Revision 3 MSM-C0-7310 CPNPP Maintenance Section Mechanical Manual, Service Water Revision 10 Pump Maintenance EPG-703 CPNPP Engineering Programs Manual, Inservice Inspection Revision 4 Program MSM-G0-0203 CPNPP Maintenance Section Mechanical Manual, Flange Revision 8 Alignment and Fastener Torque Data MSM-G0-0209, CPNPP Maintenance Section Mechanical Manual, Torque Revision 1 Standard with Correction Factor for Adaptors STI-626.01 Controlled Material Approval Request Process (CMAR) Revision 0 U1 ISI Program Plan Unit 1 - Third Interval ASME Section Xi Inservice Inspection Revision 2 Program Plan U2 ISI Program Plan Unit 2 - Third Interval ASME Section Xi Inservice Inspection Revision 2 Program Plan CR-2016-003559 The flange between the Jacket Water Heater and the 2-01 Keep 04/21/2016 (Closed Warm Pump suction isolation is leaking Jacket Water at a rate of Date) approximately 4 dpm CR-2016-008691 EDG 2-01 right bank intercooler lower adaptor flange fasteners 02/13/2017 (Closed were loose. Date)

TR-2020-008159 Two of the body to bonnet bolts on valve 1DD-0069 have backed 11/04/2020 (Closed off and need to be tightened Date)

During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP, or will be consistent after implementation of the identified enhancements.

During the audit, the staff made the following observation:

• The staff noted that the system walkdown procedure referenced for the AMP Basis Document in the ePortal did not contain clear guidance on how to conduct closure bolting inspections for non-safety-related bolted connections.

The staff also audited the description of the LRA Bolting Integrity program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

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LRA AMP B.2.3.10, Steam Generators Summary of Information in the Application. The LRA states that AMP B.2.3.10, Steam Generators, is an existing program with exceptions that will be consistent with the program elements in GALL-LR Report AMP XI.M19, Steam Generators, as modified by LR-ISG-2016-01.

Audit Activities. The table below lists documents relevant to the program that were reviewed by the staff during the audit. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-047 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal Steam Generators Aging Management Program Basis Document Procedure No. NDE-7.10 Steam Generator Tube Selection and Examination Revision 16 Procedure No. NDE-7.13 Steam Generator Degradation Mechanism Assessment Revision 7 Procedure No. NDE-7.14 Steam Generator Tube Integrity Assessment Revision 6 Procedure No. NDE-7.15 Steam Generator Secondary Side Management Revision 6 Procedure No. STA-732 Primary-to-Secondary Leakage Revision 8 Procedure No. STA-733 Steam Generator Reliability Program Revision 14 PM 308483 Job Plan #34801 EDDY CURRENT INSP S/G TUBE Revision 10 CR-2012-000073 Westinghouse Proprietary. Admin CR built for trending INPOs Occurrence recommendations stemming from their 14 November 2011 Steam 01/03/2012 Generator Review visit Closed 7/9/2014 CR-2012-000075 No title. The description field starts with, The following is a Admin Occurrence CR built for trending INPOs recommendations stemming from 01/03/2012 their 14 November 2011 Steam Generator review Closed 07/09/2014 TR-2018-002217 No title. Action type is Tracking Report. The description field says, Occurrence The Steam Generator Management Program requires a 03/22/2018 component engineer and a backup component engineer to Closed oversee the program. At this time, not backup has been 11/21/2019 identified CR-2014-007718 No title. Description is 1RF16 sludge sample analysis report Occurrence contains photos depicting presence of whole-bead resin in all four 07/01/2014 SG sludge samples Closed 02/02/2015 TR-2015-007963 No title. During the performance of the Targeted Self-Assessment Occurrence of the Steam Generator Management Program, the following 09/03/2015 opportunity was made Closed 02/02/2017 Westinghouse LTR- Westinghouse Proprietary Responses to EPRI Checklist Revision 1 CECO-21-081 P- Guidance for Addressing Aging Management Plans for Steam Attachment Generator Channel Head Components, for Comanche Peak Nuclear Power Unit 2 Steam Generator Divider Plate Assemblies TR-2019-004928 Evaluation of corrosion for Unit 1 steam generators during 1RF20 Occurrence (also, under B.2.3.2 establishing wet layup chemistry 05/13/2019 Water Chemistry) Closed 06/18/2019 N/A Evaluation of Corrosion in Unit 1 Steam Generators Due to 05/21/19 Inadequate Wet Layup Chemistry During 1RF20 EPRI 1011774 Pressurized Water Reactor Steam Generator Lay-up: Corrosion Interim Report, Evaluation December 2005 During the audit, the staff verified the applicants claim that the preventive actions, detection of aging effects, monitoring and trending, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also verified the applicants claim that aspects of the scope of program, parameters monitored or inspected, and acceptance criteria, program elements not associated with the 38

exceptions identified in the LRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-LR Report AMP.

The staff also audited the description of the LRA Steam Generators Program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.11, Open-Cycle Cooling Water System Summary of Information in the Application. The LRA states that AMP B.2.3.11, Open-Cycle Cooling Water System, is an existing program with enhancements that will be consistent with NUREG-1801,Section XI.M20, Open-Cycle Cooling Water System, as modified by LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, and LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date Open-Cycle Cooling Water Aging Management Program LUM00020-REPT-048 Revision 1 Basis Document N/A Open Cooling Water Plant Specific Guidelines 08/04/2021 Service Water System Fouling Monitoring Program STA-734 06/15/2016 (GL 89-13 Response)

COP-501 Chemistry Operating Procedures Manual 11/12/2020 Deviation identified of fouling monitoring on the component CR-2012-013203 12/17/2012 cooling water heat exchanger during summer months Fouling monitoring program identified a lower than desired CR-2011-009305 08/19/2011 level of chemical treatment Identification of service water piping sections with stagnant CR-2014-013376 03/11/2015 water and determine flushing periodicity CR-2020-9117 Service Water Heat Exchanger Leaking 12/06/2020 CR-2020-002492 CCW Heat Exchanger Leaking 04/07/2020 CR-2016-004786 Service Water Piping Pitting 05/16/2016 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements. The staff also audited the description of the LRA AMP for the Open-Cycle Cooling Water System provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.12, Closed Treated Water Systems Summary of Information in the Application. The LRA states that AMP B.2.3.12, Closed Treated Water Systems, is an existing program with enhancements and one exception that will be 39

consistent with the program elements in GALL-LR Report AMP XI.M21A, Closed Treated Water Systems.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-049 XI.M21A Closed Treated Water Revision 0 300200590 EPRI Closed Cooling Water Chemistry Guideline Revision 2 System Health Report Turbine Plant Cooling Water 4th Quarter FY20 Chemistry Operating Procedures Manual, Turbine Plant Cooling COP-313A Revision 5 Water CHM-100 Chemistry Specifications Revision 4 Chemistry/Radiochemistry Manual - Closed Cooling Water CHM-150 Revision 4 Systems Chemistry Operating Procedures Manual, Component Cooling COP-502A/502B Revision 7 Water Unit 1/Unit 2 TR-2019-003741 Unit 2 TGPW system copper concentration remains high >5ppb 05/01/2019 CR-2015-007651 CHN Ventilation Chiller has leaking tubes 08/24/2015 CR-2015-002628 Leaking weld in coupling in pipe segment TW-1-011 03/23/2015 CR-2013-007967 CHS train A has bacterial infection and needs nitrite addition 08/29/2013 CR-2011-005600 TPCW Head Tank levels indicate Unit 2 TW leaking into Unit 1 05/04/2011 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements. The staff also verified the applicants claim that aspects of the parameters monitored or inspected program element not associated with the exception identified in the LRA are consistent with the corresponding program elements in the GALL-LR Report AMP.

The staff also audited the description of the LRA AMP for the Closed Treated Water Systems provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The LRA states that AMP B.2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancement(s) that will be consistent with the program elements in GALL-LR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

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Document Title Revision / Date TPMDA-MDA-402 Control of Load Handling Equipment Procedure, Revision 13 NO. MDA-402 TPMDA-MDA-402 Control of Load Handling Equipment Procedure, TPMDA-MDA- Revision 12 402 TDBD-DBD-ME-006 Control of Heavy Loads at Nuclear Plants, DBD-ME-006 40 TPDCS-DCS-109 Dry Cask Storage Procedure Manual 3 PCN-0001 TPMDA-MDA-308 Requirements for load handling Personnel Procedure, NO. MDA- 10 308 CR-2018-009059 During hoisting operations of RHR Motor 2-02, the one set of 03/19/2019 bearings on the permanently installed 5 ton hoist failed. The load was secured with two 3 ton chain falls and the load is 5100 lbs. A replacement solution is being pursued TPSTA-STA-606 Control of Maintenance and Work Activities Procedure, No. STA- 35 606 CR-2018-005660 Condition Report: use the right oil & will be good; sample oil & 10/31/2018 change periodically; run hoist unloaded before handling additional loads; continue with rebuild schedule (every 10 outages should be fine)

CR-2017-000801 Condition Report: The crane's 5 ton block's sheaves are starting 01/24/2017 to showing wear. On one in particular the wire rope is beginning to leave an impression in the metal WO-4598977 Fuel Handling Refueling Manipulator Crane 1-01. Preventive 05/25/2019 maintenance TR-2019-002369 Tracking Report: During 2RF17 hoisting operations of RHR Motor 011/15/2021 2-02, one set of bearings on the permanently installed 5 ton hoist failed. The hoist from 1-01RHR Pump was removed and transferred to the 2-02 RHR Pump. The degraded hoist has been inspected and repairs do not appear feasible. This IR is to track the purchase and installation of a new hoist for 1-01 RHR Pump /

Motor WO-5383403 Fuel Building Overhead Crane X Deficient Maintenance 07/3/2017 TPMSM_MSM-P0-2014 Containment Maintenance Building Jib Crane Mechanical 1 Inspection, NO. MSM-P0-2014 TPMSM-MSM-PX-2021 Fuel Building Wonder hoist Crane Pre-Operational 0 Checkout/Mechanical Inspection TR-2019-002369 Degraded hoist and generated IR for the purchase of new hoist. 01/15/2021 TR-2018-005487 Parts for the manipulator crane hoist inspections and 07/02/2020 refurbishments were obtained through Konecranes DBD-ME-006 Design-Basis Document - Control of Heavy Loads at Nuclear Revision 40 Plants MSM-PO-2012 Refueling Machine Mechanical Inspection Procedure Revision 6 CPNPP CPNPP Final Safety Analysis Report (FSAR): Amendment 111 Table 17A-1, Table 8.3-11 CMAA, Specification, Specification for Electric Overhead Travelling Cranes 1975 No.70 NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants May 1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants July 1980 ASME NUM-1 Rules for Construction of Cranes, Monorails, and Hoists (With 2016 ridge or Trolley or Hoist of the Underhung Type)

ASME NOG-1 Rules for Construction of Overhead and Gantry Cranes (Top 2015 Running Bridge, Multiple Girder)

ASME B30.2 Overhead and Gantry Cranes (Top Running Bridge, Single or 2005 Multiple Girder, Top Running Trolley Hoist)

ASME B30.16 Overhead Hoists (Underhung) 2016 41

During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the LRA AMP provided in the FSAR supplement in Section A.2.2.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.14, Compressed Air Monitoring Summary of Information in the Application. The LRA states that AMP B.2.3.14, Compressed Air Monitoring, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M24, Compressed Air Monitoring.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-051 Comanche Peak Nuclear Power Plant Units 1 and 2 License 07/27/2022 Renewal Compressed Air Monitoring Basis Document Revision 1 PROCEDURE NO. STA-422 Corrective Action Program Revision 36 09/08/2022 CR-2020-005882 Valve has a known leak. Ref CR-2015-003608 Revision 1 08/10/2020-10/07/2020 CR-2015-008751 During the 3rd quarter PM for instrument air sample testing 09/29/2015-(per WO 5066629 and 5066839), two of the five sample 04/12/2016 points for the Instrument Air (CI) System were reported by the testing lab (Trace Analytics) to have exceeded the maximum particle size requirement PM 345698 Perform Dryer Maintenance 07/25/2022 WO-5935531 Repair the 1-01 Instrument Air Dryer Outlet Isolation Valve 01/25/2022 PM 341871 Inspect Clean Tank at INSTRUMENT AIR RECEIVER 1-01 01/30/2020 PM 345699 Perform Dryer Maintenance 09/13/2021 PROCEDURE NO. SOP-509B Instrument Air System 11/30/2011 Revision No. 15 PM 350206 Inspect Tank at Instrument Air Receiver X-02 08/02/2021 PM 337738 Perform Dryer Maintenance 11/15/2021 PM 304094 Inspect/Clean Tank at Instrument Air Receiver 2-02 06/09/2016 PM 305332 Perform Dryer Maintenance at Instrument Air Dryer X-02 06/21/2021 PROCEDURE NO. STA-606 Control Of Maintenance and Work Activities Revision No. 35 Picture IAC 2002 12/15/2022 DBD-ME-218 Instrument Air System 10/31/2022 Revision 24 Picture 1-01 IAD 11/22/2022 PROCEDURE NO. SOP-509A Instrument Air System 01/26/2022 Revision No. 27 PM 341881 Inspect/Clean Tank at Instrument Air Receiver 2-01 09/15/2021 PM 350205 Inspect Tank at Instrument Air Receiver X-01 03/10/2022 PM 344913 Perform Dryer Maintenance at INSTRUMENT Air Dryer X-01 02/01/2022 PM 339607 Sample Instrument Air at UNIT 1 07/01/2021 42

Document Title Revision / Date PM 339606 Sample Instrument Air at Unit 2 07/01/2021 PM 341881 Inspect/Clean Tank at Instrument Air Receiver 2-01 09/15/2021 CR-2017-002554 Drain Valve 1-02 Instrument Air Dryer Leak 03/01/2017 Picture Air Receiver 1 12/15/2022 WO-5054968 Preventive Maintenance for Instrument Air Dryer X-02 09/21/2010 WO-5398976 Replace Solenoid Drain Valve 03/02/2017 PROCEDURE NO. STA-421 Control of Issue Reports Revision No. 21 09/09/2016 Picture Air Receiver 12/15/2022 Picture 1-02 IAD 11/22/2022 PROCEDURE NO. MSM-P0- Instrument Air Dryer Maintenance 02/22/2022 7336 Revision No. 2 During the audit, the staff verified Comanche Peaks claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific OE in the SE.

The staff also audited the description of the LRA AMP Compressed Air Monitoring program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.15, Fire Protection Summary of Information in the Application. The LRA states that AMP B.2.3.15, Fire Protection, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M26, Fire Protection.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title/Description Revision /

Date LUM00020-REPT-003 Final 2011-2021 OE Spreadsheet Revision 0 /

November 30, 2022 N/A Final 2011-2021 OE Spreadsheet - Additional Search Version 1 /

Requests December 9, 2022 N/A OE Spreadsheet (Filtered by AMP) XI.M26 December 5, 2022 CR-2021-000389 Degraded fireproofing material January 15, 2021 CR-2014-003171 Thermo-lag unsatisfactory condition March 21, 2014 CR-2015-004772 Missing material in penetration seal May 6, 2015 CR-2017-007406 Cracked penetration seal and cracked fire walls June 16, 2017 CR-2011-001600 Boric acid leak impacting cable trays February 11, 2011 CR-2014-001767 Thermo-lag exposed to water February 17, 2014 CR-2014-007705 Thermo-lag exposed to water June 1, 2014 43

Document Title/Description Revision /

Date CR-2015-005229 Seal damage and damper cleaning June 9, 2015 CR-2012-004353 Degraded fire doors April 26, 2012 CR-2012-002474 Damaged fire rated seals March 9, 2012 CR-2015-008133 Damaged fire damper September 9, 2015 CR-2012-006446 Degraded gravity damper June 26, 2012 CR-2015-000452 Fire wall - cracked cinder blocks and missing grout January 14, 2015 CR-2012-001373 Fire protection requirements February 9, 2012 CR-2021-007743 Crack in fire barrier November 12, 2021 CR-2012-009412 Damaged penetration seal September 19, 2012 CR-2014-011221 Damaged penetration seal October 12, 2014 CR-2017-002696 Damaged penetration seal February 28, 2017 CR-2016-006096 Rattling damper blade CR-2017-007746 2017 Triennial Fire Protection Baseline Inspection June 26, 2017 TR-2019-003186 Incorporate penetration seal list into FIR-310 April 18, 2019 WO 5459899 Repair damaged penetration seal September 5, 2017 WO 5459901 Repair cracks in fire rated wall May 2, 2018 WO 4971966 Fire water pumphouse diesel fire pump room gravity damper 2016 WO 4426374 Fire water pumphouse electric fire pump room gravity damper 2014 FIR-310 Penetration Seal Inspection Revision 6 /

October 25, 2021 FIR-311 Fire Rated Assembly Visual Inspection Revision 3 /

March 5, 2014 MSM-P0-0705 Fire Damper Inspection and Cleaning Revision 4 /

November 15, 2017 MSG-1005 Application of Thermo-lag Materials Revision 1 /

November 14, 2013 FIR-302 Fire Door Tests and Inspections Revision 9 /

January 19, 2022 FIR-303 Halon Fire Suppression System Inspection Revision 5 /

March 11, 2004 MSG-1018 Installation and Rework of Penetration Seals Revision 1 /

August 19, 2008 During the audit, the staff verified that for the program elements that the applicant declared was consistent, the preventive actions, acceptance criteria, and corrective actions program elements of the LRA AMP is consistent with the corresponding element of the GALL-LR Report AMP.

The staff also verified the applicants claim that aspects of the detection of aging effects, program element not associated with the enhancements identified in the LRA are consistent with the corresponding program elements in the GALL-LR Report AMP.

In addition, the staff found that for the scope of the program, parameters monitored or inspected, and monitoring and trending program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

44

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OE in the SE.

The staff also audited the description of the LRA Fire Protection program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.16, Fire Water System Summary of Information in the Application. The LRA states that AMP B.2.3.16, Fire Water System, is an existing program with exceptions and enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M27, Fire Water System.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title/Description Revision /

Date LUM00020-REPT-053 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 /

Renewal Fire Water System Aging Management Program Basis August 2, 2022 Document WO 4099265 Leaking fire protection strainer flange February 2011 WO-5481074 Deluge valve drain piping corroded and partially clogged March 2020 TR-2021-001032 Sprinkler pipe pinhole leak February 9, 2021 CR-2011-005044 Drain line blocked by obstruction April 20, 2011 CR-2017-009105 Clogged drain line August 9, 2017 WO-4564912 Hole in valve body September 2013 WO-5808240, WO- Engineering review of future underground loop flow testing March and April 5808241, WO- 2020 5808242, and WO-5808244 TR-2021-007069 Fire protection piping leak October 23, 2021 CR-2020-008911 Fire protection piping leak November 28, 2020 CR-2014-002027 Valve body crack February 21, 2014 CR-2017-005038 Leaking insulated fire suppression piping and corroded metal April 15, 2017 exterior of insulation CR-2013-005787 Rust on fire water storage tank May 22, 2013 CR-2021-008314 Through-wall leak on 6-inch fire protection pipe December 8, 2021 CR-2020-004585 Leaking fire hydrant June 16, 2020 TR-2021-002788 and Corroded fire protection piping April 23, 2021 TR-2021-002787 WO-4145841 Leaking flange, clogged drain, debris in gong June 2011 CR-2012-002209 Jockey pump running continuously February 23, 2012 WO-4786713 Corrosion buildup on trim piping strainer September 2014 CR-2011-012923 Jockey fire pump had zero discharge pressure November 14, 2011 CR-2014-001329 Corrosion buildup on trim piping February 5, 2014 45

Document Title/Description Revision /

Date WO-21-405717 Walk down of fire protection system and equipment on 2MTI June 2021 Transformer CR-2018-003010 Pitting of pipe wall due to corrosion April 24, 2018 MSG-0104 Fire Protection Piping and Sprinklers Revision 0 / June 18, 2004 CR-2013-000964 Hole in dry pipe sprinkler system low point drain isolation valve January 29, 2013 body CR-2011-001768 Fire protection strainer leaking February 16, 2011 WO-5291829 Piping and components with excessive rust October 2017 WO-5585159, WO- Fire protection sprinkler head fouling August 2020 5585160 CR-2013-009025 Fire protection piping through-wall leak August 29, 2013 CR-2017-012056 Fire protection deluge valve rust October 27, 2017 WO-5423836 Leaking insulated fire suppression piping and corroded metal April 2017 exterior of insulation CR-2016-006407 Fire protection piping through-wall leak on 90-degree elbow July 3, 2016 TR-2021-006759 Moderate corrosion and mineral deposits on sprinkler deluge October 15, 2021 piping TR-2021-003891 Walk down of fire protection system and equipment on 2MTI June 10, 2021 Transformer CR-2013-009785 Jockey fire pump discharge header vent valve line clogged September 23, 2013 CR-2017-007536 Engineering review of future underground loop flow testing June 20, 2017 WO-4479825 Strainer housing with through-wall leaks October 2016 CR-2012-009671 Strainer housing with through-wall leaks September 26, 2012 CR-2018-004753 Fire protection pipe leaking July 16, 2018 CR-2018-002302 Fire protection sprinkler head fouling March 26, 2018 FIR-P1-3301 Transformer Deluge Flow Test CP1-EPTRMT-01/02 and CP1- Revision 4 /

EPTRUT-01 September 26, 2017 OPT-220-11 Fire Hose Station Flow Test N/A FIR-PX-3601 Fire Hydrant Yearly Flow Test Revision 2 /

May 20, 2021 FIR-P2-3436 Main Feedwater Pump CP2-FWAPFP-02 Air Flow and Deluge Revision 4 /

Valve 2-TV-4102C Test January 26, 2021 FIR-P2-3120 Containment Building Hose Stations Air Flow and Deluge Valve Revision 6 /

2-HV-4075D Test April 12, 2021 FIR-P2-3432 Generator Hydrogen Seal Oil Air Flow and Flooding Valve 2- Revision 3 /

TV-4102A Test March 24, 2021 FIR-307-1 Sprinkler System Inspection Form Revision 3 FIR-PX-3801 Electric Driven Fire Protection Pump CPX-FPAPFP-04 Revision 5 /

Operability Test June 10, 2020 FIR-PX-3211 Fire Protection Branch Line Flow Test FP-X-037/38 Revision 0 /

July 30, 2020 FIR-307 Inspection of Sprinkler Systems Revision 4 /

January 31, 2017 FIR-P0-3141 Deluge Valves 1/2-TV-4107Y-1/2 for Charcoal Filter Units Revision 3 /

CP1/2-VAFUPK-17/18 August 27, 2020 FIR-P1-3437 Turbine Generator Main Bearing Air Flow and Deluge Valve 1- Revision 4 /

TV-4102G Test April 12, 2021 FIR-P2-3433 Lube Oil Storage Room Air Flow and Deluge Valve 2-TV-4103 Revision 4 /

Test March 24, 2021 FIR-PX-3802 Diesel Driven Fire Protection Pump CPX-FPAPFP-05 Revision 5 /

Operability Test January 26, 2021 FIR-309 Hose Station and Hydrant/Hose House Inspections Revision 5 /

August 24, 2021 46

Document Title/Description Revision /

Date FIR-PX-3200 Fire Suppression Loop Flow Test Revision 3 /

February 14, 2013 N/A Fire Protection Report Revision 33 /

July 1, 2020 MSM-C0-1856 Grinnell Strainer Maintenance (Models A and B-1) Revision 2 /

June 30, 1997 FIR-312 Hydrostatic Testing of Fire Hose Revision 1 /

August 6, 2012 STA-723 Fire Protection Systems/Equipment Requirements Revision 5 /

January 22, 2002 During the audit, the staff verified that for the program elements that the applicant declared was consistent, the preventive actions program element of the LRA AMP is consistent with the corresponding element of the GALL-LR Report AMP.

The staff also verified the applicants claim that aspects of the acceptance criteria and corrective actions program elements not associated with the exceptions and enhancements identified in the LRA are consistent with the corresponding program elements in the GALL-LR Report AMP.

In addition, the staff found that for the scope of the program, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OE in the SE.

The staff also audited the description of the LRA Fire Water System program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.17, Fuel Oil Chemistry Summary of Information in the Application. The LRA states that AMP B.2.3.17, Fuel Oil Chemistry, is an existing program with enhancements that, with exceptions, will be consistent with the program elements in GALL-LR Report AMP XI.M30, Fuel Oil Chemistry.

By letters dated April 6, 2023 (ML23096A302), the applicant provided a supplement to LRA Section B.2.3.17, page B-121, Fuel Oil Chemistry AMP. The supplement addresses staff audit questions by clarifying the tank sampling location.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

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Document Title Revision / Date 9.7 PM 352042, MSM-S0-5713 Clean DG 1-01 Fuel Oil STG TK 9.8 PM 352043, MSM-S0-5713 Clean DG 1-02 Fuel Oil STG TK 9.9 PM 352044, MSM-S0-5713 Clean DG 2-01 Fuel Oil STG TK 9.10 PM 352045, MSM-S0-5713 Clean DG 2-02 Fuel Oil STG TK 9.26 VISTRA OPCO CPNPP Revision 23 Quality Assurance Manual 9.47 TR-2019-007125 Feasibility and Actions Required to Extend the Frequency of EDG Fuel Oil Tank Cleaning and Inspection Activities Tracking Report TR-2019-007125 09/10/2019 IR to Determine the Feasibility and Actions Required to Extend the Frequency of Performing EDG Fuel Oil Storage Tank Cleaning and Inspection Activities PROCEDURE NO. OPT-214B DIESEL GENERATOR OPERABILITY TEST Revision No. 20 02/11/2021 COMANCHE PEAK NUCLEAR POWER PLANT UNIT 2 OPERATIONS TESTING MANUAL PM 352043 CLEAN DG 1-02 FUEL OIL STG TK 10/15/2020 PM 352044 CLEAN DG 2-01 FUEL OIL STG TK 07/13/2020 PM 352045 LEAN DG 2-02 FUEL OIL STG TK 07/13/2020 PM 350076 SAMPLE THE DIESEL FUEL OIL STORAGE TANK FOR 09/29/2020 OFFSITE ANALYSIS PROCEDURE NO. COP-904 COMANCHE PEAK NUCLEAR POWER PLANTUNIT 02/17/2021 COMMONCHEMISTRY OPERATING PROCEDURES Revision No. 8 MANUAL PROCEDURE NO. CHM-140 COMANCHE PEAK NUCLEAR POWER PLANTUNIT 01/28/2009 COMMONCHEMISTRY/RADIOCHEMISTRY MANUAL Revision No. 3 (FODT Drawing) DDVEN_H-2328_-_4 12/14/2022 DIESEL GENERATOR COMANCHE PEAK NUCLEAR POWER PLANTUNIT 1 02/11/2021 OPERABILITY TEST OPERATIONS TESTING MANUAL Revision No. 25 PROCEDURE NO. OPT-214 A PM 350075 SAMPLE THE DIESEL FUEL OIL STORAGE TANK FOR 05/18/2021 OFFSITE ANALYSIS PM 301012 FUEL OIL ANALYSIS 03/23/2021 PM 352042 CLEAN DG 1-01 FUEL OIL STG TK 07/13/2020 PM 301011 Fuel Oil Analysis 03/23/2021 Preventative Maintenance Form TEST DATA SHEET FOR DIESEL DRIVEN FIRE PUMP Revision 0 CHM-140-904-2 FUEL TANK DIESEL GENERATOR FUEL COMANCHE PEAK NUCLEAR POWER PLANTUNIT 1 Revision No. 0 OIL STORAGE TANK AND 2MAINTENANCE SECTION - MECHANICAL 08/26/2021 CLEANING PROCEDURE NO. MANUAL MSM-P0-3713 PM 350077 SAMPLE THE DIESEL FUEL OIL STORAGE TANK FOR 11/16/2020 OFFSITE ANALYSIS Picture CP1-DOATDT-01 (Representative FODT) Left December 14, 2022 Picture CPX-FPTNFP-05 (front label) December 14, 2022 Picture CPX-FPTNFP-05 (back label) December 14, 2022 Picture FOST Internal Top December 14, 2022 Picture Diesel Oil Storage Tank construction December 14, 2022 Picture CPX-FPTNFP-05 (front view) December 14, 2022 Picture CPX-FPTNFP-06 (front label) December 14, 2022 Picture CPX-FPTNFP-06 (back label) December 14, 2022 Picture FOST Internal Bottom December 14, 2022 Picture CP1-DOATDT-01 (Representative FODT) December 14, 2022 Picture CP1-DOATDT-01 (Representative FODT) Right December 14, 2022 Picture CPX-FPTNFP-06 (front view) December 14, 2022 Picture CP1-DOATDT-01 (Representative FODT) Top December 14, 2022 Picture CPX-FPTNFP-05 (side view) December 14, 2022 Picture CP1-DOATDT-01 (Representative FODT) Label December 14,2022 48

During the audit, the staff verified Comanche Peaks claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the GALL-LR Report AMP with enhancements stated in Elements 3 through 6, to the corresponding elements and with exceptions in Element 4. During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OE in the SE.

The staff also audited the description of the LRA Fuel Oil Chemistry program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.18, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP B.2.3.18, Reactor Vessel Surveillance is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M31, Reactor Vessel Surveillance.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the Reactor Vessel Surveillance program. The staff will document its review of this information in the SE.

Document Title Revision /

Date STA-502-R16 Comanche Peak Nuclear Power Plant Station Administration Revision 16, Manual Effective Date 10/26/2022 TBX/TCX-IPA-AMP- Reactor Vessel Surveillance Aging Management Program Basis Revision 1, XI.M31 Document 07/29/2022 NA Comanche Peak Operating Experience Spreadsheet - XI.M31 12/05/2022 Vessel Surveillance LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License 08/31/2022 Renewal Operating Experience Review WCAP-18630-NP Comanche Peak Units 1 and 2 Time Limited Aging Analysis on 05/2021 Reactor Vessel Integrity WCAP-17269-NP Analysis of Capsule W from the Comanche Peak Unit No. 2 09/2010 Reactor Vessel Radiation Surveillance Program (ML102920160)

WCAP-1661-NP Analysis of Capsule X from the TXU Energy Company Comanche 09/2006 Peak Unit 1 Reactor Vessel Radiation Surveillance Program (ML063050191)

NA Comanche Peak Nuclear Power Plant Units 1 and 2 License 10/2022 Renewal Application (ML22276A082)

TR-2019-005570 Tracking Report - The Comanche Peak Units 1 and 2 Pressure 07/01/2019 Temperature Limits Report (PTLR) needs to be updated to account for the latest test results from the reactor vessel surveillance program During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

49

During the audit, the staff made the following observations:

• The staff confirmed that reinsertion of Capsule W or V, in lieu of Capsule Z, into the Unit 1 reactor vessel for an additional 13 effective full power years (EFPY) of operation would be capable of achieving at least a reactor vessel equivalent neutron fluence 5.23 x 1019 n/cm2.

• The staff confirmed that reinsertion of Capsule Y or V, in lieu of Capsule Z, into the Unit 2 reactor vessel for an additional 14 EFPY of operation would be capable of achieving at least a reactor vessel equivalent neutron fluence of 4.83 x 1019 n/cm2.

• With respect to the enhancement in LRA Section B.2.3.18 and FSAR supplement (A.2.2.18), the LRA lacked sufficient clarity and details regarding the capsule withdrawal schedule (e.g., capsule identification and EFPY withdrawal time) for Units 1 and 2. By letter dated April 6, 2023 (ML23096A302), the applicant supplemented LRA Table A-3, and LRA Section B.2.3.18, to provide explicit details regarding stating when they plan to withdraw capsules at the necessary EFPY for multiple available capsules, which will be addressed in the staffs SE.

• With respect to the monitoring and trending and operating experience program elements, the staff noted an instance that the PTLR may not have been assessed in a timely manner based on surveillance data from a recent capsule withdrawal. By letter dated April 6, 2023 (ML23096A302), the applicant supplemented LRA Section B.2.3.18, to include an enhancement to the monitoring and trending program element to ensure an update to the PTLR consistent with the surveillance test results, which will be addressed in the staffs SE.

The staff also audited the description of the Reactor Vessel Surveillance program, as supplemented by letter dated April 6, 2023, provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.19, One-Time Inspection Summary of Information in the Application. The LRA states that AMP B.2.3.19, One-Time Inspection, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M32, One-Time Inspection.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-056 XI.M32 One-Time Inspection AMP Basis Document Revision 1 Responses to EPRI Checklist Guidance for Addressing Aging Management Plans for Steam Generator Channel Head LTR-CECO-21-081 Revision 1 Components, for Comanche Peak Nuclear Power Unit 2 Steam Generator Divider Plate Assemblies 50

CR-2012-008911 DG Fuel Oil Storage Tank Unit 2 East - cracked gasket 09/04/2012 CR-2012-008993 DG Fuel Oil Storage Tank Unit 2 West - gasket leakage 09/04/2012 CR-2018-000888 Diesel Oil Storage Tank 1 corrosion particulate found 01/30/2018 EDG Starting Air Compressors 2-03 and 2 both show an CR-2018-002118 03/19/2018 increase in wear particle concentration Priming pump fuel line to the 1-02 alternate power diesel CR-2019-001676 02/20/2019 generator leaking CR-2019-002541 1-PI-3410-1 differential pressure fuel oil filter gauge leak 03/25/2019 Update procedure to discontinue 3-level sampling for specific TR-2020-003049 04/26/2020 gravity on diesel fuel oil During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA AMP for the One-Time Inspection program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.20, Selective Leaching Summary of Information in the Application. The LRA states that AMP B.2.3.20, Selective Leaching, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M33, Selective Leaching, as amended by LR-ISG-2011-03, Changes To The GALL-LR Report Revision 2 Aging Management Program XI.M41, Buried And Underground Piping And Tanks, and LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the keyword graphiti (to capture graphitic corrosion or graphitization) which did not return any results.

The table below lists the document that was reviewed by the staff and was found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-057 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 Renewal Selective Leaching Aging Management Program Basis Document During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. In addition, the staff found that for the scope of program and detection of aging effects program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify 51

whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Selective Leaching program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Selective Leaching program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.21, One-Time Inspection of ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The LRA states that AMP B2.3.21, One-Tme Inspection of ASME Code Class 1 Small-Bore Piping, is a new condition monitoring program that will inspect a sample of Class 1 piping less than nominal pipe size (NPS) 4 and greater than or equal to NPS 1. When implemented it will be consistent with the program elements in GALL-LR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the One-Time ASME Code Class 1 Small-Bore Piping program. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-058 One-Time Inspection of ASME Code Class 1 Small-Bore Revision 1 Piping Aging Management Program Basis Document 08/01/2022 LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/03/2022 LUM00020-REPR-039 ASME Section XI Inservice Inspection, Subsections IWB, Revision 1 IWC, and IWD Aging Management Program Basis Document 08/20/2022 LR-AMP-017-IWBDC ASME Section XI, Subsections IWB, IWC, and IWD Inservice Revision 9 Inspection Program Basis Document for License Renewal CR-2013-004868 OPT 303, Reactor coolant System (RCS) Water Inventory, 04/25/2013 has been performed indicating a 0.5gpm RCS leak. U1 has entered Action Level 3 Response actions per OPT 303 and U1 CR has dispatched personnel to find leak CR-2013-006270 Unit 1 entered Action Level 2 for OPT-303 leakrate for 2 of 3 06/07/2013 consecutive leak rates being above the average plus 2 times the standard deviation CR-2014-011871 U1 Reactor Cavity Sump pumps have run 3 times during 10/24/2014 1RF17 while the Reactor cavity was flooded. This is abnormal and an inspection of below the vessel for leak sources needs to be scheduled CR-2015-006001 Discovered potential through wall leak from pipe segment SI- 07/07/2015 2-070 in Unit 2 Train B SI pump room. There is a 1-2 cup boric acid accumulation on the floor underneath 2SI-0055.

There is a drip hanging from the bottom of the insulation on SI-2-070 pipe segment below 2SI-0055 - evidence of active leakage. All accumulations are white 52

Document Title Revision /

Date CR-2016-004610 Socket weld #FW1-4 in safety injection line #3/4-1501R-2 05/13/2016 (1SI-0119) in Unit 1 has been examined with phased array ultrasonics. This is a non-ASME Code exam done in response to a similar weld that leaked last year in Unit 2.

WestDyne and Electric Power Research Institute (EPRI) have analyzed this data and have concluded there is relevant indication in the weld. The indication is 0.2 inches long in the circumferential axis and is in the vicinity of the fusion line between the root and the toe CR-2016-001844 U2 has entered Action Level 3 for RCS leakage based on 02/25/2016 Deviation from the Baseline Mean; One unidentified RCS Inventory Balance >3 standard deviations CR-2018-009224-1 Possible boric acid accumulation was identified at 2-TE- 12/30/2018 0443A, Reactor Coolant System Hot Leg 2-04 Temperature Element 0443A IN 2007-21, Supp. 1 Pipe Wear Due to Interaction of Flow-Induced Vibration and Supplement 1 ML20225A204 Reflective Metal Insulation 12/11/2020 OE 2021-0004 Information Notice (IN) 07-21. Supplement 1, Pipe Wear Due 01/21/2021 to Interaction of Flow-Induced Vibration and Reflective Metal Insulation During the audit, the staff verified applicants claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding program elements in the GALL-LR Report AMP.

For the audit of the operating experience program element, the staff reviewed the OE provided by the applicant in the AMP basis document and on the ePortal. The staff performed a search of the provided OE using keywords: RCS leakage, sockolet, stress corrosion, PWSCC, small bore, socket weld, and weldolet. The staff will document its review of relevant OE in the SE.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.22, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The LRA states that AMP B.2.3.22, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in the GALL-LR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date External Surfaces Monitoring of Mechanical Components Aging LUM00020-REPT-059 Revision 1 Management Program Basis Document 53

STI-748.01 System Monitoring and Health Reporting Revision 3 TR-2021-001284 Ruptured piping downstream of 2HD-0857 and 2HD-0759 02/18/2021 TR-2019-007943 Corrosion of valve bonnet XSW-0025 10/11/2019 CR-2019-001830 Piping segment 30-SW-X-009-100-5 has surface corrosion 02/26/2019 NRC green NCV finding for inadequate engineering operability CR-2016-006524 07/07/2016 input for degraded conditions involving piping corrosion CR-201-012370 Main Condenser Drain Valve 2CO-0295 has surface corrosion 12/30/2015 CR-2014-011075 Corrosion of the 2 carbon steel pipes CV-1-013 and CV-1-042 10/09/2014 CR-2013-001016 Water trapped in insulation on pipe segment CH-2-248 01/30/2013 CR-2012-008723 Degraded conditions in the SSW pipe tunnel 08/30/2012 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the LRA AMP for the External Surfaces Monitoring of Mechanical Components provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.23, Flux Thimble Tube Inspection Summary of Information in the Application. LRA AMP B.2.3.23, Flux Thimble Tube Inspection, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M37, Flux Thimble Tube Inspection.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-060 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision1 Renewal Flux Thimble Tube Inspection Aging Management Program Basis Document Comanche Peak Nuclear Power Plant Units 1 and 2 License October 3, 2022 Renewal Application PWROG-21043-P Flux Thimble Eddy Current Inspections Frequency Decrease - Revision 0 Task 2 Report WCAP-12866 Bottom-Mounted Instrumentation Flux Thimble Wear January 1991 Comanche Peak Nuclear Power Plant Units 1 and 2 License April 6, 2023 Renewal Application Supplement 1, Attachment C MRS-GEN-1180 Generic Flux Thimble Tube Eddy Current (FTEC) Inspection Field Revision 3 Service Procedure MRS-GEN-1304 Generic Flux Thimble Tube Eddy Current (FTEC) Field Service Revision 7 Procedure Using Corestar System 8.1 WO 5669174 Perform Seal Table Eddy Current Test - Unit 2 (inspection May 8, 2020 results)

WO 5172648 Perform Seal Table Eddy Current Test - Unit 2 (inspection April 27, 2017 results)

WO 5258047 Perform Seal Table Eddy Current Test - Unit 1 (inspection October 19, 2017 results)

WO 5743564 Perform Seal Table Eddy Current Test - Unit 1 (inspection October 18, 2020 results) 54

During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

During the audit, the staff made the following observations:

• WCAP-12866, a report that has not been generically approved by the NRC, provides the plant-specific wear projection methodology and acceptance criteria.

o As it relates to Comanche Peak Units 1 and 2, wall thickness is projected using plant-specific data and a methodology that includes sufficient conservatism to ensure that wall thickness acceptance criteria continue to be met during plant operation between scheduled inspections.

o As it relates to Comanche Peak Units 1 and 2, the acceptance criteria are technically justified to provide an adequate margin of safety to ensure that the integrity of the reactor coolant system pressure boundary is maintained. The acceptance criteria include allowances for factors such as instrument uncertainty, uncertainties in wear scar geometry, and other potential inaccuracies, as applicable, to the inspection methodology chosen for use in the program.

• The LRA and AMP Basis Documents had conflicting information about the frequency of eddy current testing for the flux thimble tubes. This discrepancy was corrected by the applicant in letter dated April 6, 2023 (ML23096A302).

• The applicant indicated participation in a PWROG effort towards possibly extending the interval between flux thimble tube inspections.

• The AMP has employed capping, moving, and replacing flux thimble tubes to reduce wear or prevent it in the case of the acceptance criteria being exceeded.

• No through-wall wear has been recorded at Comanche Peak Unit 1 or 2.

The staff also audited the description of the Flux Thimble Tube Inspection provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.24, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B.2.3.24, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, as modified by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

55

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-061 Comanche Peak Nuclear Power Plant Units 1 And 2 License Revision 1 Renewal Inspection of Internal Surfaces In Miscellaneous Piping And Ducting Components Aging Management Program Basis Document CR-2013-000747 Through Wall Leak In Pipe Segment VD-X-045 01/23/2013 TR-2021-004074 Multiple New Leaks Developing on Pipe VD-X-061 06/18/2021 TR-2019-001908 Pinhole Leak Downstream of 2VD-0017 02/28/2019 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, monitoring and trending, and corrective actions program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP.

The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.25, Lube Oil Analysis Summary of Information in the Application. The LRA states that AMP B.2.3.25, Lubricating Oil Analysis, is an existing program that will be consistent, with enhancement stated in Element 6, to the program elements in GALL-LR Report AMP XI.M39, Lubricating Oil Analysis.

Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Lubricating Oil Analysis. These documents were provided by the applicants ePortal. The staff will document its review of relevant OE in the SE.

Document Title Revision / Date LUM00020-REPT-062 Comanche Peak Nuclear Power Plant Units 1 and 2 License 07/27/2022 Renewal Lubricating Oil Analysis Basis Document Revision 1 Condition Report FWP 1A Tripped After Experiencing Speed, Flow, and 03/29/2021-CR-2021-002216 Pressure Oscillations 09/27/2022 Condition Report Binding in SV-13 Lockout Solenoid or Hydraulic Trip Relay 10/10/2020-CR-2020-007334 Due to Poor Oil Quality 03/09/2021 Procedure No. MSM-PO 3360 Emergency Diesel Generator Oil Sampling February 5, 1999 Revision 3 Procedure No. MSM G0-0101 Lubricating Sample 09/09/2021 Revision No. 5 56

Document Title Revision / Date Condition Report Oil samples from the CCW Pump 1-02 Outboard Bearing has 05/08/2013-CR-2013-005274 an Elevated Wear Particle Concentration (WPC) 05/09/2013 Condition Report Oil Sample from Main Feed Water Pump 1-01 (CP1- 12/14/2015-CR-2015-011917 MSTDFP-01) Shows Indication of Water Ingression 03/24/2016 Condition Report Thrust Bearings not Secured Against the Shaft Shoulder 02/01/2018-CR-2018-000941 Allowing (for impacting between the bearings) the Increased 01/29/2019 Wear Particulate Seen in the Oil Sample INSTRUCTION NO. TSP-514 Lubricant Analysis Program Revision 4 02/22/2021 Procedure No. STA-421 Control Of Issue Reports 09/09/2016 Revision No. 21 Procedure No. SE-P0-4312 RHR Pump Motor Inspection 05/02/18 Revision No. 7 Condition Report Oil Samples from Containment Spray Pump 2-04 Show 08/15/2018-CR-2018-005481 Increasing Wear Particle Concentration (WPC) 08/21/2018 Tracking Report CR-2021-002216 was Rejected by MRC Resulting in a 04/13/2021-TR-2021-002559 Fourth Holdover 04/20/2021 During the audit, the staff verified Comanche Peaks claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP will be consistent after implementation of the identified enhancement stated in Element 6. During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific OE in the SE.

The staff also audited the description of the LRA Lubricating Oil Analysis program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.26, Monitoring of Neutron-Absorbing Materials Other Than Boraflex Summary of Information in the Application. The LRA states that AMP B2.3.26, Monitoring of Neutron-Absorbing Materials Other Than Boraflex, is an existing program that, with enhancements, will be consistent with the program elements in NUREG-1801,Section XI.M40, Monitoring of Neutron-Absorbing Materials Other Than Boraflex.

Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Monitoring of Neutron-Absorbing Materials Other Than Boraflex Program.

These documents were provided by the applicant and identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant OE in the SE.

Document Title Revision /

Date DCVDI_HI-2188305_- Comanche Peak Boral Coupon Surveillance Report 10/12/2018

_0 DCVDI_HI-2002436_- Criticality Safety Analysis of Holtec Spent Fuel Racks for Revision 9

_9 Comanche Peak HI-2135720R1_R01 Comanche Peak Boral Coupon Surveillance Report 09/25/2013 TS Technical Specifications for Comanche Peak Nuclear Power Plant Units 1 and 2 DCVDI_Hpp-2303-1_- Test Procedure for Comanche Peak Spent Fuel Pool Neutron Revision 0

_0 Absorbing Materials Surveillance Program 57

Document Title Revision /

Date TPNUC_NUC-211_7_- SFP Storage Limitations for Reactivity Control 01/28/2019

_-(2)

NUC-211 Comanche Peak Boral Coupon Surveillance Report 10/12/2018 101618_1_NA HI-2156882R1_R01 Comanche Peak Boral Coupon Surveillance Report 12/23/2015 STA-422 Corrective Action Program 8/31/2016 TFNUC_NUC-211- Boral Coupon Documentation Form Revision 1 1_1_-_-(1)

TFNUC_NUC-211- Boral Coupon Visible Degradation Trending Revision 0 2_0_-_-

During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also verified the applicants claim that aspects of the corrective actions program element not associated with the enhancement identified in the LRA are consistent with the corresponding program element in the GALL-LR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific OE in the SE.

The staff also audited the description of the LRA AMP Monitoring of Neutron-Absorbing Materials Other Than Boraflex program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.27, Buried and Underground Piping and Tanks Summary of Information in the Application. The LRA states that AMP B.2.3.27, Buried and Underground Piping and Tanks, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-LR Report AMP XI.M41, Buried and Underground Piping and Tanks, as amended by LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-064 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Buried and Underground Piping and Tanks Aging Management Program Basis Document CR-2020-006151 Underground Water Leak Between Protected Area Fence and 08/20/2020 Delay Fence North Of The Admin Building CR-2018-000888 Corrosion Product Particulate Found in The Well Portion Of 01/30/2018 Diesel Oil Storage Tank 1-02 CR-2015-003427 Buried Fire Protection Piping was Exposed and Noted to Have 04/15/2015 Coating (Coal Tar Wrap) Damage CR-2012-005813 2012 WANO Peer Review Evaluation Area for Improvement 06/08/2012 CR-2015-010120 Service Water Pipe Support Issues Identified By NRC Resident 10/22/2015 MSE-P0-1328 Cathodic Protection Annual Survey Revision 4 58

Document Title Revision / Date MSE-P0-1327 Bi-Monthly Cathodic Protection Inspection Revision 7 2323-SS-008 Excavation And Backfill Revision 7 EPG-9.03 Underground Pipe and Tank Program Revision 5 CPES-M-1128 Linings and Coatings Outside Containment Safety-Related and Revision 0 Reliability-Important MSM-P0-3713 Diesel Generator Fuel Oil Storage Tank Cleaning Revision 0 EV-TR-2019-007125-2 Evaluate the Technical Basis For Extension Of The Fuel Oil 10/24/2019 Storage Tank Cleaning/Inspection PM Beyond 10 Years CP-201000067 Soil Analysis for Comanche Peak Nuclear Power Plant Project 02/04/2010 2323-MS-67A Comanche Peak Steam Electric Station Unit Nos. 1 and 2 Diesel 01/24/1977 Generator Oil Storage Tanks Specification During the audit, the staff verified the applicants claim that the scope of program program element of the LRA AMP is consistent with the corresponding element of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancement. In addition, the staff found that for the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Buried and Underground Piping and Tanks program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Buried and Underground Piping and Tanks program. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application. The LRA states that AMP B.2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-LR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as added by LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-065 Comanche Peak Nuclear Power Plant Units 1 And 2 License Revision 0 Renewal Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, And Tanks Aging Management Program Basis Document TR-2021-004953 1-02 CCW [Component Cooling Water] Heat Exchanger Fouling 07/28/2021 CR-2017-011789 1-02 CCW Heat Exchanger Noted Significant Coating Pitting at 10/22/2017 Both The Inlet And Outlet Manway Sealing Flanges CR-2012-010973 CCW Heat Exchanger 2-02 Discharge (CP2-CCAHHX-02) Has 10/20/2012 Coatings with Less Than Desirable Adhesion 59

Document Title Revision / Date CR-2012-010936 Circulating Water System Was Disassembled and It Was Noted 10/19/2012 That Plasite 7122 Coatings In All These Areas Has Reached Its End Of Life EPG-5.01 Engineering Support - Protective Coatings Program Revision 2 MSM-C0-5877 Component Cooling Water Heat Exchanger Maintenance Revision 5 MSM-P0-3357 Emergency Diesel Engine Jacket Water Cooler Cleaning Revision 1 MSM-G0-0908 Maintenance Of Linings And Coatings Outside Containment Revision 1 Safety-Related And Reliability-Important EPG-5.03 Certification and Qualification of Personnel Performing Inspection Revision 1 of Lining/Coating Work MSM-G0-0101 Lubricant Sampling Revision 5 TSP-514 Lubricant Analysis Program Revision 4 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements. In addition, the staff found that for the parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program provided in the FSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The LRA states that AMP B.2.3.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S1, ASME Section XI, Subsection IWE.

Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff conducted additional searches of the applicants CAP database, using the following phrases:

containment liner, moisture barrier, IWE examination, liner augmented examination, liner thickness loss, liner distress, liner discontinuities, liner irregularities.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-066 ASME Section XI, Subsection IWE Aging Management Program Revision 1 Basis Document, Comanche Peak NPP Units 1 and 2 License Renewal LUM00020-REPT-003 Operating Experience Review Revision 0 60

Document Title Revision / Date N/A OE Spreadsheet Filtered by AMP XI.S1 12/05/2022 N/A IWE Additional Search Requests 12/14/2022 N/A IWE OE Search Results from 12/15/2022 Discussion 12/15/2022 OER-2016-004606 Operating Experience Report: RIS-2016-07 Containment Shell or 05/13/2016 Liner MB Inspection CR-2015-005740 IWE U1 Containment Personnel Air Lock: Site OE PAL Door Seals 06/29/2015 CR-2014-0005950 IN 2014-07 Degradation of Leak Chase Channel Systems 05/12/2014 AI-CR-2011-008866-1 & Condition Report for IN 2011-1: Steel Containment Degradation 08/09/2011 EV-CR-2011-0088662-2 and Associated License Renewal Aging Management Issues CR-2011-004424 Unit 2 Containment Personnel Air Lock (CP2-MEMEPE-01) 04/12/2011 XI.S1- IWE Recordable Loose bolt N/A 1RF22 IWE Pictures of Unit 1 Containment Liner Provided on ePortal 12/21/2022 CR-2010-006271 NRC IN 2010-12: Containment Liner Corrosion 06/23/2010 TX-ISI-IWE Metal Containment Visual Examination (Viewed on Teams with Revision 5 &

Westinghouse on 1/5/23) Revision 6 N/A Comanche Peak Unit 1 1RF22 Spring 2022 IWE/IWL Inspection 05/02/2022 Final Report Interval 3, Period 3; Interval 4, Period 1, Westinghouse Inspection Services N/A Comanche Peak Unit 2 2RF19 Fall 2021 IWE Final Report 10/29/2021 Interval 3, Period 3; Interval 4, Period 1, Westinghouse Inspection Services N/A Comanche Peak NPP Unit 1 IWE/IWL Examinations Outage 05/2019 1RF20 Interval 3 Period 3 / IWL Period 2, Prepared for Luminant by Wesdyne, Book 1 of 1 N/A Comanche Peak NPP Unit 1 IWE Examinations Outage 1RF19 10/2017 Interval 3 Period 3, Prepared for Luminant by Wesdyne, Book 1 of 1 N/A ISI Program Health Scorecard (CPNPP: 2019 - Post 1RF20 and 08/19/2019 2RF17)

N/A ISI Program Health Scorecard (CPNPP: 2020 - 2nd Half Post 07/20/2020 1RF18)

N/A ISI Program Health Scorecard (CPNPP: 2021 - Post 1RF21) 02/21/2021 EPG-703 Inservice Inspection Program Procedure Revision 4 EPG-731 ASME Section XI Repair/Replacement Activities Procedure Revision 6 CP-202100660 Containment Inservice Inspection Program Plan Units 1 and 2 - Revision 1 Third CISI Interval (September 10, 2012 to September 9, 2021)

CP-202100693 Containment Inservice Inspection Program Plan Units 1 and 2 - Revision 0 Fourth CISI Interval (September 10, 2021 to September 9, 2031)

Specification No. 2323- Comanche Peak Units 1 & 2, Containment Personnel Air Lock, Revision 3 SS-15 Equipment Hatch and Emergency Airlock Specification During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, monitoring and trending, acceptance criteria and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP In addition, the staff found that for the preventive actions, detection of aging effects, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will use a voluntary LRA supplement offered by the applicant or consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

During the audit, the staff made the following observations:

61

• The staff reviewed the program basis document (LUM00020-REPT-066, Revision 1) and the LRA with respect to the program enhancements and noted that the language of all four program enhancements needed additional clarification or revision to make the LRA AMP consistent or adequate to manage the aging effects. These issues are indicated in the breakout questions and the staff will consider issuing RAI(s) or use a voluntary LRA supplement offered by the applicant to address the issues.

• The staffs review of the operating experience description of LRA B.2.3.29 noted that the factual description of plant-specific OE appeared to not adequately support the stated conclusion, and therefore needed to be supplemented with a description of the general observed material condition of the containment pressure-retaining boundary components within the scope of the AMP based on past inspections. The staff will consider issuing an RAI or use a voluntary LRA supplement offered by the applicant to address the issue.

The staff also audited the description of the LRA AMP ASME Section XI, Subsection IWE provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR. However, the staff may consider issuing RAI(s) to verify the sufficiency of the FSAR supplement program description if conforming changes related to revised wording of enhancements offered by the applicant in a voluntary LRA supplement are not reflected in the corresponding LR Commitments in LRA Table A-3.

LRA AMP B.2.3.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The LRA states that AMP B.2.3.30, ASME Section XI, Subsection IWL, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S2, ASME Section XI, Subsection IWL.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-067 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal ASME Section XI, Subsection IWL Aging Management Program Basis Document CP-202100660 CISI Program Plan, Units 1 and 2 - Third Containment ISI Revision 1 Interval, September 10, 2012, to September 9, 2022 09/29/21 CISI Program Plan, Units 1 and 2 - Fourth Containment ISI Revision 0 Interval, September 10, 2021, to September 9, 2031 10/12/21 EPG-703 Inservice Inspection Program Procedure No. EPG-703 Revision 4 08/3/14 TR-2022-002161 Document and Evaluate the Unit 1 and Unit 2 ASME Section XI 03/30/22 Tracking Report IWL examinations and Unit 1 IWE examinations performed in the Spring of 2022 TX-ISI-8 VT-1 and VT-3 Visual Examination Procedure Revision 11 PROP TX-ISI-IWL Concrete Structural Visual Examination Revision 8 PROP Comanche Peak 1RF22, Spring 2022, IWE/IWL Final Report 05/02/22 Interval 3, Period 3, Interval 4, Period 1 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are 62

consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the LRA ASME Section XI, Subsection IWL AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.31, ASME Section XI, Subsection IWF Summary of Information in the Application. The LRA states that AMP B.2.3.31 ASME Section XI, Subsection IWF, is an existing program with an exception and enhancements, when implemented, will be consistent with the program elements in GALL-LR Report, Revision 2, AMP XI.S3, ASME Section XI, Subsection IWF.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision/Date Enercon Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2 07/27/2022 LUM00020-REPT-068 License Renewal, ASME Section XI, Subsection IWF AMP Basis Document Enercon Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2 07/27/2022 LUM00020-REPT-066 License Renewal, ASME Section XI, Subsection IWE AMP Basis Document Procedure NO. STI-422.04 Processing of Condition Reports Revision 1 Procedure No. EPG-731 ASME Section XI Repair/Replacement Activities Revision 6 Procedure No. EPG-703 Inservice Inspection Program (ISI) Revision 4 Procedure No. STA-703 Inservice inspection Program Revision 14 Procedure No. STA-422 Corrective Action Program 09/07/2022 Procedure No. STA-677 Preventive Maintenance Program 05/05/2022 Procedure No. STA-744 Maintenance Effectiveness Monitoring Program 02/09/2017 Procedure No. STA-746 Industry Operating Experience Program 03/31/2022 Procedure No. MSM-G0-0210 Constant and Variable Spring Pipe Support Maintenance Revision 0 Procedure No. MSG-0103 Installation, Modification and Removal of Sway Struts and Revision 0 Snubbers Procedure No. MSG-1008 Pipe Support Adjustments and Verifications Revision 0 CPES-M-1078 Specification Fabrication and Erection of Piping (ASME Code Revision 13 Class 1, 2, & 3,ANSI Safety Class 1, 2, & 3, and ANSI B31.1 CPES-P-1079 Specification Fabrication and Erection of Pipe Supports Revision 11 WESDYNE 2RF15 Interval 3, Period 1 ISI Examinations (see pgs. 42 to 10/23/2015 Westinghouse Report 45 for CRDM seismic support examinations)

WESDYNE Westinghouse 1RF18 Interval 3, Period 2 (see Pages 22 & 35 for CRDM 06/19/2016 Report WDI-PJF-1316363- seismic support examinations)

FSR-001 Westinghouse Final Report CPNPP Fall 2021 2RF19 ISI Report, Interval 3, Period 2 & 10/29/2021 Interval 3, Period 3 Westinghouse Final Report CPNPP Spring 2022 1RF22 ISI Report, Interval 4, Period 2 & 05/02/2022 Interval 4, Period 3 Luminant CP-201900257 Unit 1 ISI Program Plan, Third Interval, (Unit 1: 2007 Edition Revision 2 of ASME Code Section XI, 2008 Addenda, Start Date 08/13/2010)

Shaw - CPSES -200800331 Unit 2 ISI Program Plan, Second Interval, (Unit 2: 1998 Revision 3 Edition of ASME Code Section XI, 1999 and 2000 Addenda, Start Date 08/03/2004)

WESDYNE Unit 1 Aug. Examinations Originals, Outage 1RF20, Interval 05/13/2019 Westinghouse Report three, Period Three 63

Document Title Revision/Date CR-201-007061 Mechanical Stress Improvement Process (MSIP) Squeeze of 11/17/2021 Unit 2 RCS Cold Leg 1 CR-2011-009629 OE 34106- RV supports not included in the ISI Program 08/302011 (Cook Nuclear Power Plant). CPNPP need to determine if inspection of RFV supports is required as part of the ISI program CR-2021-003041 CPNPP Unit 1 and Unit 2 RV supports have been classified 05/05/2021 as inaccessible for examination of ASME Section XI Table IWF-2500-1 requirements. Investigated examination history and requirements. Perform the examination in the next Unit 1 and Unit 2 refueling outages CR-2018-008440 2RF17 ISI visual examination of pipe support H-SI-2-RB-034- 12/13/2018 704-1 (ISI support TCX-1-4205-H25) cotter pins missing CR-2015-009272 2RF15 ISI VT-3 examination of the CRDM seismic supports 10/30/2015 with following conditions found multiple cotter pins not spread, loose jam nut and insufficient thread engagement CR-2021-003041-3 Examination of Unit 2 RV Supports 05/05/2021 CR-2021-003041-2 Examination of Unit 1 RV Supports 02/22/2022 CR 2014-010074 Based on Sequoyah (SQN) OE312397, CPNPP failed to 03/17/2015 include and execute ISI VT-3 of CRDM seismic supports resulting in a Green non-cited violation WO-21-374015_1 AI-CR-2021-003041-2, ISI Examination of Unit 1 RV Supports 05/19/2022 WO-21-373898_1 AI-CR-2021-003041-3, ISI Examination of Unit 2 RV Supports 11/01/2021 WO 4952046 U1 RF18 CRDM Support Examination 05/2/2016 WO 4834769 U2 RF15 CRDM Support Examination 10/23/2015 WO-21-807879 ISI Examination of Unit 2 Cold Leg 1 RV support following 10/25/2021 MSIP malfunction Trident Presentation Reactor Vessel Supports 03/08/2023 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report, Revision 2, AMP, or will be consistent after implementation of the identified enhancements.

The staff also verified the applicants claim that aspects of the scope of program, program element not associated with the exception identified in the LRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-LR Report, Revision 2, AMP.

In addition, the staff found that for the operating experience, program element sufficient information was not available to determine whether the RV Class 1 supports would be adequately managed by LRA AMP B.2.3.31, ASME Section XI, Subsection IWF, for the period of extended operation. The staff will consider issuing RAIs, RCIs or use the applicants voluntary supplement in order to obtain the information necessary to verify whether there is reasonable assurance of program adequacy to manage the effects of aging for the RV Class 1 supports consistent with the GALL-LR Report, Revision 2, XI.S3 AMP for the period of extended operation.

During the audit, the staff made the following observations:

• The CPNPP Inservice Inspection (ISI) Program Plan outlines the requirements for the ASME Code,Section XI, Subsection IWF inspections of Class 1, 2, and 3 component supports. Inspection requirements for ASME Class MC component supports are 64

included in the CPNPP Containment Inservice Inspection Program Plan as documented in staff reviewed IWF and IWE basis documents.

The staff also audited the description of the LRA AMP ASME Section XI, Subsection IWF provided in the FSAR supplement. The staff verified this description is consistent with the general description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The LRA states that AMP B.2.3.32, 10 CFR Part 50, Appendix J, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.S4, 10 CFR Part 50, Appendix J.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-069 CPNPP Units 1 and 2 License Renewal,10 CFR Part 50, Revision 1 Appendix J Program Basis Document LUM00020-REPT-056 CPNPP Units 1 and 2 License Renewal, One-Time Inspection Revision 1 Aging Management Program Basis Document LUM00020-REPT-059 External Surfaces Monitoring of Mechanical Components Aging Revision 1 Management Program Basis Document TXX-15001 LAR 14-002 Extension of Containment Leakage Test Frequency 11/28/2015 TSP-734 10 CFR Part 50, Appendix J, Option B Test Intervals and Revision 3 Administrative Limits TXX-15001_CP- License Amendment Request 14-002 Extension of Containment 01/28/2015 201500034_1 Leakage Rate Testing Program PPT-S1-7014 CPNPP Testing Manual, Unit 1, Containment Integrated Leakage Revision 2 Rate Test STA-734 CPSES Station Administration Manual, 10 CFR Part 50, Revision 2 Appendix J Containment Leakage Rate Testing Program PPT-S2-7014 CPNPP Testing Manual, Unit 2, Containment Integrated Leakage Revision 1 Rate Test OER- 2015-004707 Operating Experience Report 02/27/2019 WO-4776569 CPNPP Routine Test-Surveillance Containment Integrated Leak 04/10/2022 Rate Test TR-2017-011293 SI-0035 and 1SI-0034 had seat leakage 10/17/2017 CR-2018-006944 2CA-0016 Failed LLRT 09/30/2019 CR-2017-010071 Elevated leakage, EAL Local leak rate test 09/12/2017 CR-2015-005769 A 6 Portion of the inner door seal fell off 07/01/2015 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA 10 CFR Part 50, Appendix J provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

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LRA AMP B.2.3.33, Masonry Walls Summary of Information in the Application. The LRA states that AMP B.2.3.33, Masonry Walls, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S5, Masonry Walls.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only describe extent of audit (e.g., the program elements described in the applicants basis document).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-070 CPNPP Units 1 and 2 License Renewal, Masonry Walls Aging Revision 1 Management Program Basis Document STI-744.09 CPNPP Station Instruction Manual, Structural Monitoring Revision 0 Inspection Guide LUM00020-REPT-031 CPNPP Units 1 and 2 License Renewal, Screening and Aging Revision 0 Management Review Report for the Auxiliary Building and Other Structures LUM00020-REPT-071 CPNPP Units 1 and 2 License Renewal, Structures Monitoring, Revision 1 Aging Management Program Basis Document 2323-AS-004 Unit Masonry Specification Revision 0 STA-722 CPNPP Station Administration Manual, Fire Protection Program Revision 8 LUM00020-REPT-052 CPNPP Units 1 and 2 License Renewal Fire Protection Program Revision 1 Aging Management Program Basis Document STA-422 Corrective Action Program Revision 34 LUM00020-REPT-003 CPNPP Units 1 and 2 License Renewal Operating Experience Revision 0 Review CR-2021-002911 Rain water leaking from removable block on roof on to motor of 04/29/2021 SSWP 2-02 CR-2021-002670 Multiple leaks in the roof at the SWIS 04/17/2021 CR-2020-006451 Multiple leaks in the roof at the SWIS 09/02/2020 WO-5098306 Preventive Maintenance. Perform Cross Functional Walkdown 02/16/2017 Aux Bldg. Unit1, TRN A WO-6032169 Applied sealant outer edge of gasket area an verified no leakage 04/17/2021 while raining WO-4805895 Preventive Maintenance. Structural inspection of Fuel building 01/27/2020 and associate SSCs to satisfy STA-744 requirements During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP, or will be consistent after implementation of the identified enhancements.

During the audit, the staff made the following observation:

• A degradation mechanism checklist applicable to masonry walls referenced in Section 4.3 of the AMP basis document in the ePortal does not mention gaps between supports and masonry walls as recommended by GALL-LR Report AMP XI.S5 Masonry Walls Element 3, Parameters Monitored or Inspected.

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The staff also audited the description of the LRA Masonry Walls program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.34, Structures Monitoring Summary of Information in the Application. The LRA states that AMP B.2.3.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S6, Structures Monitoring.

Audit Activities. To support its audit of the program, the staff also conducted an onsite audit. On January 31 - February 1, 2023, the staff participated in an onsite audit at CPNPP to gain a general overview of current conditions of the structures compared to the provided OE, and an understanding of current conditions for: (1) water leaks in the Service Water Intake Structure (SWIS), Auxiliary Boiler Building, Emergency Diesel Building, Turbine Building, Fuel Building, Train B Switchgear area fan cooler room (room 1-105) roof penetration and others; (2) aging effects of loss of material (spalling, scaling) and cracking due to freeze-thaw at plant site; and (3) aging effect of Increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide and carbonation at the interior concrete walls below grade at plant site. While onsite, the staff engaged with the applicant staff, conducted walkdowns, and reviewed additional documentation provided by the applicant.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-071 Comanche Peak Nuclear Power Plant Units 1 and 2, License Revision 1 Renewal Structures Monitoring Aging Management Program Basis Document STI-744.09 Structural Monitoring Inspection Guide Revision 0 STA-422 Corrective Action Program Revision 34 STA-730 Corrosion Monitoring Program Revision 5 MSG-1006 Fabrication of Structural & Embedded Steel and Erection of Revision 0 Structural Steel CR-2016-001562 Develop a plan to repair building roof leaks 02/18/2016 CR-2016-002175 Multiple roof leaks reported around site from heavy rain 03/08/2016 CR-2021-002670 Multiple leaks in the roof at Service Water Intake Structure 04/07/2021 CR-2018-005963 Roof plug in room 2-108F is leaking, approximately 12dpm onto 09/06/2018 2-HV-2336B when it is raining CR-2018-006373 Observed leak from Train B Switchgear Area Fan Cooler Room 09/24/2018 (RM-1-105) roof penetration CR-2017-012537 Rainwater leaking through the room 1-108G 11/08/2017 CR-2016-001446 Long standing roof leaks in the Fuel Building that drip into the 02/16/2016 841 elevation new fuel receipt area CR-2014-005576 Cracks in the concrete foundation at northeast corner of heater 04/30/2014 drain tank CP2-HDATDT-2 at Turbine Building elevation 803 CR-2013-007544 Degradation of the grout base and some corrosion of steel in 07/22/2013 several pipe supports in Units 1 and 2, Turbine Building basements CR-2014-011321 Roof leaks at SG-1-103, Unit 1 Train B Switchgear Room 10/14/2014 WO 4929153 Contractor to repair the switchgear roof 10/27/2014 CR-2013-007544 Degradation of the grout base and some corrosion of steel in 07/22/2013 several pipe supports in the Units 1 and 2 Turbine Building basements 67

During the audit, the staff verified the applicants claim that the monitoring and trending, and corrective actions program elements of the LRA AMP are consistent with the corresponding element of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements. In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

During the audit, the staff made the following observations:

• For the Scope of Program program element, the staff noted that several SCs identified in the LRA as within the scope of the AMP were not clearly identified in the scope of current procedures or as an enhancement.

• For the Preventive Actions program element, the staff noted that AMPs enhancement is vague, and AMP does not include preventive action of proper selection of lubricants for the structural bolting integrity.

• For the Parameters Monitored or Inspected and Acceptance Criteria program elements, the staff noted that the AMP does not include structural sealants which are in the scope of LR.

• For the Detection of Aging Effect program element, the staff noted that the AMP does not include the subsequent steps if groundwater leakage is identified.

• The staff noted that the Table 2 items for aging management of Group 8 foundations need to be clarified.

During the onsite audit, the staff performed walkdowns of the SWIS, Auxiliary Boiler Building, Emergency Diesel Building, Turbine Building, Fuel Building, Train B Switchgear Area Fan Cooler Room (room 1-105) roof penetration, Diesel General Building, and Fuel Building, etc.

The staff made the following observations during walkdowns:

• During the walkdown of various buildings at site, the staff noted that appropriate corrective actions had been taken to address the water leaks at roofs or penetrations.

The staff interviewed the applicants staff and found that the applicant had installed new roofing for many buildings and has a plan to install new roofing for the rest of the buildings.

• During the walkdown of various buildings at site, the staff discussed with the applicants staff that the aging effect of loss of material (spalling, scaling) and cracking due to freeze-thaw is applicable to this site. However, the staff did not identify this aging effect during the walkdown.

• During the walkdown of the SCs within the scope of LR, the staff noted the degradations observed during the walkdowns were found to be consistent with the OE for which the GALL-LR Report program was evaluated.

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The staff also audited the description of the LRA Structures Monitoring program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Structures Monitoring Program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The LRA states that AMP B.2.3.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants.

Audit Activities. To support its audit of the program, the staff also conducted an onsite audit. On January 31 - February 1, 2023, the staff participated in an onsite audit at CPNPP to gain a general overview of current conditions of the structures compared to the provided OE, and an understanding of current conditions of concrete degradation on the ceiling of the SWIS. While onsite, the staff engaged with the applicant staff, conducted walkdowns, and reviewed additional documentation and calculations provided by the applicant.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-072 Comanche Peak Nuclear Power Plant, Units 1 and 2, License Revision 0 Renewal, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Aging Management Program Basis Document STI-744.09 Structural Monitoring Inspection Guide Revision 0 PPT-SX-7517 Safe Shutdown Impoundment Revision 2 VDRT-5953371 2020 Safe Shutdown Impoundment (SSI) dam inspection report 09/30/2020 VDRT-6034538 NRC Dam safety inspection report-2021 03/17/2022 VDRT-6034728 2022 SSI dam inspection report 08/29/2022 VDRT-5674546 Evaluation of concrete deterioration bay 1 - 01 slab opening - 11/12/2018 elevation 796-0 Service Water Intake Structure W126-D4580 Work instruction: detecting delamination in reinforced concrete by 12/15/2017 sounding per ASTM D4580 CR-2017-011512 Falling concrete from the ceiling of the Service Water Intake 10/17/2017 Structure W126-D4580 Detecting delamination in reinforced concrete by sounding per 12/15/2017 ASTM D4580 CR-2017-011560 Assessment of degraded Service Water Intake Structure floor 10/27/2017 slab at elevation at Elevation 796-0 due to concrete spalling Calculation No. CSB-057 Service Water Intake Structure - slab and beam design at Revision 0 elevation 796-0 CR-2014-010585 2014 SSI annual inspection recommendations for additional 09/30/2014 maintenance actions During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the 69

corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements. In addition, the staff found that for the scope of program program element, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.

During the audit, the staff made the following observations:

• For the Scope of Program program element, the staff noted that clarification is needed to address the inconsistency of LR scope among LRA Section B.2.3.35, Section 2.4.7 and Section 2.4.8.

• The staff noted that: (1) Table 1 item 3.5-1, 056 does not include concrete elements for foundation and interior slab; (2) Table 1 item 3.5-1, 059 does not include all the concrete components subject to aging management; and (3) the claim of applicability of Table 1 Item 3.5-1, 060 is inconsistent with ASTM C33-90.

The staff made the following observations during walkdowns:

• During the walkdown of the SWIS, the staff noted that significant OE related to falling concrete from the ceiling of SWIS had been evaluated and the concrete tested and repaired to maintain its structural integrity and intended function.

• During the walkdown of the SCs within the scope of LR, the staff noted the degradations observed during the walkdowns were found to be consistent with the OE for which the GALL-LR Report program was evaluated.

The staff also audited the description of the LRA Inspection of Water-Control Structures Associated with Nuclear Power Plants program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Inspection of Water-Control Structures Associated with Nuclear Power Plants program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA AMP B.2.3.36, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The LRA states that AMP B2.3.36, Protective Coating Monitoring and Maintenance, is an existing program that, with enhancements, will be consistent with NUREG-1801,Section XI.S8, Protective Coating Monitoring and Maintenance.

Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Protective Coating Monitoring and Maintenance Program. These documents were provided by the applicant and identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant OE in the SE.

Document Title Revision /

Date CMPK_FSAR_A111 CPNPP/FSAR PM 336111-WI Containment Coatings Repairs 02/05/2020 70

Document Title Revision /

Date CR-2014-002598-SELF- Condition Report 09/15/2014 ASSESSMENT PM 342691-GI Containment Coatings Repairs 03/06/2013 PM 336111-GI Containment Coatings Repairs 10/03/2021 PM 336110-WI Containment Coatings Repairs 04/15/2019 PM 336110-GI Containment Coatings Repairs 10/19/2020 PM 34692-GI Containment Coatings Repairs 11/7/2021 CR-2011-010181 Condition Report 09/16/2011 CR-2013-004190 Condition Report 04/15/2013 TR-2020-001428(U2- Tracking Report 02/26/2020 CCMR-2RF18)

CR-2011-007901-SELF- Condition Report 07/13/2021 ASSESSMENT TERPT_ER-ME-124_0_- Engineering Report Evaluation of CPSES Protective Coatings 11/28/2007 TR-2020-007636(U1- Tracking Report 10/17/2020 CCMR-1RF21)

WO-3932439_1 Work Order 11/08/2014 TSMS_CPES-M-1068_2 Supplemental Record Form 04/24/2010 TPMSM_MSM-GO- Protective Coatings - Containment Procedure Revision 6 0216_6_PCN_0003 TPSTA_STA-692_5_-_- Maintenance Coatings Program Revision 5 TPEPG_EPG-5.02_1_-_- Certification and Qualification of Coating/Lining Applicators Revision 1 TPEG_EPG- Certification and Qualification of Personnel Performing Revision 1 5.03_1_PCN_0001 Inspection of Lining/Coating Work TPEG_EPG- Engineering Support - Protective Coatings Program Revision 2 5.01_2_PCN_0001 PM 342691-WI Protective Coatings Program Unit 1 Refueling Inspection Revision 0 PM 342692-WI Protective Coatings Program Unit 2 Refueling Inspection Revision 2 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also verified the applicants claim that aspects of the monitoring and trending, program element not associated with the enhancement identified in the LRA are consistent with the corresponding program element in the GALL-LR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific OE in the SE.

The staff also audited the description of the LRA AMP Protective Coating Monitoring and Maintenance program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA notes that AMP B.2.3.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements 71

in GALL-LR Report AMP XI.E1, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit only addressed the applicants basis document as well as the available current relevant maintenance procedures.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-074 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 1 /

Renewal Insulation Material for Electrical Cables and 06/02/2022 Connections Not Subject To 10 CFR50.49 Environmental Qualification Requirements Aging Management Program Basis Document TR-2021-007619 Tracking Report; TCX-RCPCPX-04; REACTOR COOLANT 11/12/2021 PUMP 2-04 MOTOR TR-2021-007481 Tracking Report; CP2-MSTDFP-02; FEEDWATER PUMP 09/13/2022 TURBINE 2-B TR-2019-005926 Tracking Report; CPX-EPDPNB-30; U2 CWIS HEAT TRACE 07/23/2019 CONTROL PANEL XHT-7 TR-2019-004081 Tracking Report; 1-LS-202TB; FEEDWATER HEATER 1-1A 05/14/2019 EXTRACTION STEAM DRIP POT 1-01 LEVEL SWITCH TR-2017-011889 Tracking Report; TBX-RCPCPX-04; REACTOR COOLANT 10/27/2017 PUMP 1-04 MOTOR TR-2016-009721 Tracking Report; 1-LS-3220; MAIN STEAM SUPPLY TO 08/22/2019 AUXILIARY STEAM HDR DRIP POT 1-03 LEVEL SWITCH CR-2015-010248 Op Related Condition Report: BX-FHSCFB-01 05/10/2016 CR-2015-010182 Condition Report; Containment Fan Cooler Fan 2-04 Motor 11/08/2015 CR-2014-010283 Condition Report; 2-TV-2370E-LC1; MN STM DMP TO CNDSR 09/23/2014 2-B VLV 2370E LSC CR-2012-010360 Condition Report; 2-HV-6583-1-MO; MSL 2-02 TO MSR 2-A 10/15/2012 HTG STM EQUAL VLV MO During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also conducted an onsite audit where the staff interviewed the applicants staff and performed walkdowns of the CPNPP, Units 1 and 2. Specifically, the staff conducted onsite walkdowns of the switchyard and cable raceways and examined pictures of electrical manholes.

The staff also audited the description of the LRA Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

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LRA AMP B.2.3.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Summary of Information in the Application. The LRA notes that AMP B.2.3.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.E2, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in instrumentation circuits.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants basis document as well as the available current relevant maintenance procedures.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-075 Insulation Material for Electrical Cables and Connections Not Revision 0 Subject to 10 CFR 50.49 Environmental Qualification 05/18/2022 Requirements Used in Instrumentation Circuits Program Basis Document CR-2021-006723 Condition Report; TCX-RCPCPR-01; PRESSURIZER 2-0 10/19/2021 CR-2020-004052 Condition Report; 2-N-0050B; NEUTRON FLUX MONITORING 06/02/2020 SYSTEM (GAMMAMETRICS)

TR-2017-008869 Tracking Report; 1-JE-0430B; REACTOR COOLANT LOOP 1-03 02/12/2020 N16 UPSTREAM DETECTOR 0430B CR-2017-005713 Condition Report; 2-NE-0032; (EITER-B) NIS SOURCE RANGE 05/02/2017 NEUTRON FLUX PROPORTIONAL COUNTER 2-32 TR-2017-001742 Tracking Report; CWP1/19/BKR; CWISEL 795 FLOOD 02/09/2017 LIGHTING BREAKER 19 CR-2016-005269 Condition Report; 1-NE-0043A; (EITER-B) NIS POWER RANGE 05/27/2016 ION CHAMBER NEUTRON DETECTOR 1-43A PROT CHAN III CR-2014-010125 Condition Report; 1-JE-0430B; REACTOR COOLANT LOOP 1- 01/14/2015 03 N16 UPSTREAM DETECTOR 0430B CR-2013-012772 X-RE-5701; AUXILIARY BUILDING VENTILATION EXHAUST 08/21/2014 RADIATION DETECTOR CR-2013-009642 Condition Report; 1-RE-2325; MAIN STEAM LINE 1-01 09/19/2013 RADIATION DETECTOR CR-2013-005183 Condition Report; 2-RE-6293; UNIT 2 SFGD EL 831 PIPE 05/07/2013 PENET AREA HRAM RADIATION DETECTOR CR-2012-011112 Condition Report; 1-FT-0414; REACTOR COOLANT LOOP 1-01 07/21/2014 FLOW TRANSMITTER 0414 PROT CHAN I During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits provided in the FSAR supplement. The staff verified this description is consistent with the description provided in in SRP-LR, Table 3.0-1.

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LRA AMP B.2.3.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA notes that AMP B.2.3.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in the NUREG-1801, Revision 2, GALL-LR Report AMP XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49.

At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this program. Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. To support its audit of the program, the staff also conducted an onsite audit. On January 31 - February 1, 2023, the staff participated in an onsite audit at CPNPP. During the onsite audit the staff performed interviews and walkdowns of the facility. Specifically, the staff looked at a sample of in-scope cables, connections, and manholes associated with the LR and installed in adverse localized environments. The applicant was also able to provide water trend fluctuation operating experience work orders that are within the scope of the LR. Lastly, the applicant was able to further elaborate on the cable reliability program put in place as a site procedure for Tan-Delta Cable Insulation Resistance Testing.

The table below lists the documents that were reviewed by the staff and were found relevant to the Electrical Insulation for Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. The staff will document its review of relevant OE in the SE.

Document Title Revision/

Date LUM00020-Rept-076 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Basis Document LUM00020-Rept-035 Comanche Peak Units 1&2 License Renewal Aging Management Revision 0 Review-Electrical & I&C Commodities ABN-907 Acts of Nature Revision 16 EPG-9.05 Cable Reliability Program Revision 5 FDA-2004-003620-01-06 Final Design Authorization Revision 6 TR-2016-009264 Engineering Targeted Self-Assessment on the Cable Reliability 2016 Program CR2015-004803 Assessment of deferral of PMs 349287, 349289, 349291. These 2015 PMs perform tan-delta testing of 6.9 kV power cables CR2010-011067 Evaluation of IN 2010-26; Submerged Electrical Cables 2010 CR2010-003399 Track key initiatives for the CPNPPs Cable Aging Management 2010 Program that will satisfy EPRI guidelines and INPO expectations CR2015-004409 ~2gpm leak coming from conduit (C-1PA-A303) 2015 WR4160865, Manhole inspections and pump outs 2012-2013 4329142,4540006,4593784 TR2019-000712 Project to install permanent de-watering capability in the SSW cable 2019 vaults TR2017-011708 Calibration trends of feedwater pump switches 2017 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and 74

trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the NUREG-1801, Revision 2 GALL-LR Report AMP.

The staff also audited the description of the LRA Section A.2.3.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements of Appendix A Final Safety Analysis Report Supplement, The staff verified that the description is consistent with the descriptions provided in SRP-LR, Table 3.0-1.

LRA AMP B.2.3.40, Metal Enclosed Bus Summary of Information in the Application. The LRA notes that AMP B.2.3.40, Metal Enclosed Bus, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.E4, Metal Enclosed Bus.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the information provided by the applicant, available procedures, and referenced documents.

Audit Activities. To support its audit of the program, the staff also conducted an onsite audit. On January 31 - February 1, 2023, the staff participated in an onsite audit at CPNPP. The staff interviewed the applicants staff and performed walkdowns of the CPNPP, Units 1 and 2.

Specifically, the staff observed exposed metal enclosed buses, cables, connections, and electrical manholes associated with the LRA. The staff was unable to walkdown and observe internal elements of metal enclosed buses associated with this AMP since the CPNPP, Units 1 and 2, were online and access to enclosed buses was not available. The staff did not identify any adverse or abnormal conditions with equipment associated with metal enclosed buses during the walkdowns.

The table below lists the documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision/

Date INPO SER 5-09 6.9-kV Nonsegregated Bus Failure and Complicated Scram November 2009 CR-2009-006813-00 Non-Segregated Bus Inspections Rev.2 May 2020 CR-2011-001512 and Belleville washers Bulletin by Eaton January 2011 CR-2011-000366 and April 2011 AR02324951 License Renewal PSPM AMP Effectiveness Review August 2019 LUM00020-REPT-077 Metal-Enclosed Bus Aging Management Program Basis Revision 0 Document PROCEDURE MSE-PO- Iso Phase Bus Cleaning and Inspection Revision 3 6004 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Metal Enclosed Bus provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

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LRA AMP B.2.3.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA notes that AMP B.2.3.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in NUREG-1801, Revision 2, GALL-LR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-079 Comanche Peak Nuclear Power Plant Units 1 and 2 Electrical Revision 1 Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Basis Document CR-2012-001058 Diesel Generator 2-01 Lube Oil Heater Connection heating due February 2012 to lose connection CR-2013-004039 Diesel engine 1-01 control panel inspection April 2013 WO 4114469 Thermography on 480V Motor Control Center January 2012 WO 4267793 Diesel Generator 1-01 Control Panel Inspection January 2013 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.

The staff also audited the description of the LRA Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provided in the FSAR supplement.

The staff verified this description is consistent with the description provided in SRP-LR, Table 3.0-1.

LRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses Summary of Information in the Application. LRA Section 4.1, Identification of Time-Limited Aging Analyses, discusses the methodology for the identifying of TLAAs in the LRA.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-080 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 2 Renewal Time Limited Aging Analysis (TLAA) and Exemption Identification LTR-SDA-II-20-19 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal - Identification of Time Limited Aging Analyses 76

LTR-SDA-II-21-12 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal - Identification of 10 CFR 50.12 Exemption Time Limited Aging Analyses During the audit, the staff verified that the applicant has provided its basis and methodology for identifying TLAAs in accordance with disposition of 10 CFR 54.21(c).

During the audit, the staff made the following observations:

• The staff reviewed LUM00020-REPT-080 and LTR-SDA-II-20-19 and confirmed that CLB and design-basis documentation were searched to identify potential TLAAs. The staff noted that specific key words were used during this search that would identify potential TLAAs.

• The staff reviewed LUM00020-REPT-080 and LTR-SDA-II-20-19, and confirmed that each potential TLAA was reviewed against the six criteria of 10 CFR 54.3(a) and that those that met all six criteria were identified as TLAAs, which require evaluation for the period of extended operation.

• The staff reviewed LUM00020-REPT-080 and LTR-SDA-II-21-12, and confirmed that a search of docketed licensing correspondence, the operating license, and the FSAR identified exemptions granted pursuant to 10 CFR 50.12. Additionally, the staff noted that LUM00020-REPT-080 identifies the exemptions currently in effect that were granted pursuant to 10 CFR 50.12.

• The staff reviewed LUM00020-REPT-080 and LTR-SDA-II-21-12, and confirmed that these active exemptions were then reviewed to determine whether the exemption was based on a TLAA.

LRA TLAA Section 4.2.1, Neutron Fluence Projections Summary of Information in the Application. LRA Section 4.2.1, Neutron Fluence Projections, discusses the analysis for the neutron fluence in the RPV as an input to other RPV neutron embrittlement analyses.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision / Date WCAP-18630-NP Comanche Peak Units 1 and 2 Time-Limited Aging Analysis on Revision 0 Reactor Vessel Integrity LTR-SDA-21-059-NP Comanche Peak Units 1 & 2 License Renewal: Reactor Vessel Revision 0 Integrity Final Safety Analysis Report (FSAR), Pressure and Temperature Limits Report (PTLR), and Technical Specifications Markups During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI or using the voluntary supplement offered by the applicant during the audit.

77

The staff also audited the description of the LRA neutron fluence TLAA provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR was an adequate description of the LRA neutron fluence TLAA. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA TLAA Sections 4.2.2 - 4.2.5 Summary of Information in the Application. The staffs audit addresses the following TLAAs collectively due to their relationship in analyzing the reactor vessel neutron embrittlement:

• LRA Section 4.2.2, Pressurized Thermal Shock, discusses the analysis for assessing the pressurized thermal shock (PTS) of the RPV as required by 10 CFR 50.61. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

• LRA Section 4.2.3, Upper-Shelf Energy, discusses the analysis for assessing the projected reduction in the upper-shelf energy (USE) properties of RPV base metal and weld components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

• LRA Section 4.2.4, Adjusted Reference Temperature, discusses the analysis for assessing the use of adjusted reference temperature (ART) limits to adjust the pressure-temperature limit curves to account for irradiation effects. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

• LRA Section 4.2.5, Pressure-Temperature (P/T) Limits Including Low Temperature Overpressure Protection (LTOP) Analysis, discusses the assessment of P/T limits and LTOP setpoints for the RPV. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date FSAR Comanche Peak Nuclear Power Plant, Units 1 and 2 - Final Amendment Safety Analysis Report No. 110 WCAP-18630-NP Comanche Peak Units 1 and 2 Time Limited Aging Analysis on Revision 0 Reactor Vessel Integrity WCAP-18607-NP Analysis of Capsule X from the NextEra Energy Seabrook Unit 1 Revision 0 Reactor Vessel Radiation Surveillance Program WCAP-16524-NP Analysis of Capsule 230 degree from Arizona Public Service Revision 0 Company Palo Verde Unit 2 Reactor Vessel Radiation Surveillance Program LTR-SDA-21-059-NP Comanche Peak Units 1 & 2 License Renewal: Reactor Vessel Revision 1 Integrity Final Safety Analysis Report (FSAR), Pressure and Temperature Limits Repot (PTLR), and Technical Specification Markups LD-79-036 I&E Bulletin 78-12, Atypical Weld Material in Reactor Pressure June 8, 1979 Vessel Welds 78

CE NPSD-1119 Updated Analysis For Combustion Engineering Fabricated Rev. 1 Reactor Vessel Welds Best Estimate Copper And Nickel Content (ML15103A309)

During the audit, the staff made the following observations:

• The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE, margin values) for the Beltline materials for Unit 1 and Unit 2 contained in LRA Tables (Unit 1 - LRA Tables 4.2.2-1, 4.2.3-1, 4.2.4-1 and 4.2.4-2; Unit 2 - Tables 4.2.2-2, 4.2.3-2, 4.2.4-3 and 4.2.4-4) are consistent with the applicants CLB (e.g., FSAR, license amendments associated with power uprates, and Pressure-Temperature Limits Reports)

• The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE) for the Extended Beltline materials for Unit 1 contained in LRA Tables 4.2.2-1, 4.2.3-1, 4.2.4-1 and 4.2.4-2; were based on information from certified material test reports, fabrication records, database containing reactor vessel material information and/or the FSAR for the specific material. Additionally, based on this verification, the staff observed that the appropriate margin value consistent with Regulatory Guide (RG) 1.99, Revision 2, were applied for each Unit 1 reactor vessel material for the purposes of addressing PTS and ART.

• The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE) for the Extended Beltline materials for Unit 2 contained in LRA Tables 4.2.2-2, 4.2.3-2, 4.2.4-3 and 4.2.4-4 were based on information from certified material test reports, fabrication records, database containing reactor vessel material information and/or the FSAR for the specific material. Additionally, based on this verification, the staff observed that the appropriate margin value consistent with RG 1.99, Revision 2, were applied for each reactor vessel material for the purposes of addressing PTS and ART.

• The staff noted that WCAP-18630-NP, Revision 0, provides the applicants assessment of surveillance data applicable to the reactor pressure vessels at Units 1 and 2. The staff reviewed Sections 4, Surveillance Data, and 5, Chemistry Factor, and Appendix B, Comanche Peak Units 1 and 2 Surveillance Program Credibility Evaluation, and verified the following:

o The applicants use of applicable surveillance data is credible in accordance with 10 CFR 50.61 and RG 1.99, Revision 2, for the following RPV materials:

Unit 1

• Lower Shell Plate R-1108-2

• Beltline Region Weld Metal (Heat # 88112)

• Upper Shell Longitudinal Weld Seams 101-122 A, B, and C (Heat # 4P6052)

Unit 2

• Intermediate and Lower Shell Longitudinal Welds (Heat # 89833)

• Intermediate to Lower Shell Girth Weld (Heat # 89833)

• Upper Shell to Inter. Shell Girth Weld Seam 103-121 (Heat # 3P7317) 79

o The applicants use of applicable surveillance data is non-credible in accordance with 10 CFR 50.61 and RG 1.99, Revision 2, for the following RPV materials:

Unit 2

• Intermediate Shell Plate R-3807-2 The staff also audited the summary description provided in the FSAR supplement of the TLAAs identified in LRA Sections 4.2.2, 4.2.3, 4.2.4 and 4.2.5. The staff verified this description is consistent with the description provided in the SRP-LR.

LRA TLAA Section 4.3.1, Transient Cycle Projections for 60 Years Summary of Information in the Application. LRA Section 4.3.1, Transient Cycle Projections for 60 Years, discusses the 60-year transient cycle projections for ASME Code,Section III, Class 1, 2, and 3 fatigue analyses. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LTR-SDA-II-21-28 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 2 Renewal - 60 Year Transient Projections for Class 1 RCS and 08/05/2022 Auxiliary Systems, Class 2 Heat Exchangers, and Class 1, 2 and 3 Valves CN-SDA-21-012 Comanche Peak Unit 1 and Unit 2 60-Year Transient Cycle Revision 3 Projections 08/05/2022 LTR-SEE-21-31 Comanche Peak, Units 1 and 2, Transient Set and Cycles Revision 2 Considered in License Renewal Project 11/04/2021 STI-706 Station Administration Manual: Transient and Fatigue Cycle Revision 2 Monitoring 09/12/2014 STI-706.01 Station Instruction Manual: Transient and Fatigue Cycle Revision 0 Monitoring 09/23/2014 ER-ME-103 Summary Information: Thermal Monitoring Data and Evaluation Revision 14 04/02/2018 LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/03/2022 CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring CR-2015-002780 Strategic Self-Assessment of the Reactor Coolant System 03/26/2015 (RCS) Materials Management Program TR-2021-000782 Track and Document the Planning, Performance and Reporting 02/01/2021 for 2021 Self-Assessment for the Thermal Stratification Monitoring Program LTR-SDA-II-21 Comanche Peak Unit 1 and 2 License Renewal: Class 2 and 3 Revision 2 P/NP Piping Fatigue Evaluation 08/10/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

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During the audit, the staff made the following observations.

• The title of LRA Table 4.3.1-3, CPNPP 60-year Transients Normal Condition Auxiliary System Transient Events, indicates that this table describes the transients for the auxiliary systems and their 60-year projected cycles. However, the LRA does not clearly describe differences between this table and LRA Table 4.3.1-4 that also addresses auxiliary system transients.

• The title of LRA Table 4.3.1-4 is CPNPP 60-year Projected Transient Cycles For Auxiliary System Transients and Applicable Components. The staff noted that the following reference describes the detailed design transients associated with the piping systems listed in LRA Table 4.3.1-4 (

Reference:

LTR-SDA-II-21-32-P/NP, Revision 2, Comanche Peak Unit 1 and 2 License Renewal: Class 2 and 3 Piping Fatigue Evaluation). However, the LRA does not clearly describe whether LRA Table 4.3.1-4 includes the transient cycle projections for non-Class 1 piping systems other than the auxiliary piping systems.

The staff also audited the description of the LRA TLAA on 60-year cycle projections for Class 1, 2 and 3 components provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.3.2, ASME Section III, Class 1 Fatigue Analysis of Piping, Piping Components, and Equipment Summary of Information in the Application. LRA Section 4.3.2, ASME Section III, Class 1 Fatigue Analysis of Piping, Piping Components, and Equipment, discusses the fatigue TLAA for ASME Code,Section III, Class 1 piping, components and equipment. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date CN-MRCDA-07-42 Comanche Peak Unit 1 and Unit 2 Power Uprate - Reactor Revision 1 Vessel Evaluation 08/07/2007 CN-RIDA-07-36 Comanche Peak Unit 1 and Unit 2 Reactor Internal Revision 0 Components Evaluation 2007 CN-SDA-II-19-014 Comanche Peak Units 1 and 2 Thermal Event and Fatigue Revision 0 Monitoring Update for 1/1/2018 to 12/31/2018 07/19/2019 LTR-SDA-II-21-02 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 5 Renewal Fatigue AOR Usage and Material Inputs 08/20/2021 WCAP-16477-P Addendum to Analytical Reports for the Comanche Peak Unit September 2005 No. 1 Reactor Vessel (Replacement Steam Generator Project)

CN-MRCDA-14-14 Comanche Peak Units 1 and 2 Reactor Vessel Thread Damage Revision 0 Evaluation 09/10/2014 LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/3/2022 CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring CR-2015-002780 Strategic Self-Assessment of the Reactor Coolant System 03/26/2015 (RCS) Materials Management Program 81

Document Title Revision /

Date TR-2021-000782 Track and Document the Planning, Performance and Reporting 02/01/2021 for 2021 Self-Assessment for the Thermal Stratification Monitoring Program CN-SDA-21-012 Comanche Peak Unit 1 and Unit 2 60-Year Transient Cycle Revision 3 Projections 08/05/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

During the audit, the staff made the following observations.

• LRA Section 4.3.2 indicates that the reactor coolant pumps conform to the waiver of fatigue requirements of ASME Code,Section III and therefore do not require a detailed fatigue evaluation. However, the LRA does not describe specific ASME Code provisions that the applicant used in the fatigue waiver evaluation. Additionally, the Unit 1 letdown flow shutoff with prompt return to service transient is projected to have 60-year cycles greater than the 40-year design cycles. It is unclear to the staff whether the projected cycles greater than the 40-year design cycles do not affect the validity of the fatigue waiver evaluation.

The staff also audited the description of the LRA TLAA for ASME Code,Section III, Class 1 piping, components and equipment provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.3.3, ASME Section III, Class 2 and 3 Allowable Stress Analyses Summary of Information in the Application. LRA Section 4.3.3, ASME Section III, Class 2 and 3 Allowable Stress Analyses, discusses the fatigue TLAA for the allowable stress of ASME Code,Section III, Class 2 and 3 piping lines. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LTR-SDA-II-21 Comanche Peak Unit 1 and 2 License Renewal: Class 2 and 3 Revision 2 P/NP Piping Fatigue Evaluation 08/10/2022 CN-SDA-21-012 Comanche Peak Unit 1 and Unit 2 60-Year Transient Cycle Revision 3 Projections 080/5/2022 LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/03/2022 CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

82

During the audit, the staff made the following observations.

• As discussed in the audit report section for 60-year cycle projections (LRA Section 4.3.1), the title of LRA Table 4.3.1-4 is CPNPP 60-year Projected Transient Cycles For Auxiliary System Transients and Applicable Components. The staff noted that the following reference describes the detailed design transients associated with the piping systems listed in LRA Table 4.3.1-4 (

Reference:

LTR-SDA-II-21-32-P/NP, Revision 2, Comanche Peak Unit 1 and 2 License Renewal: Class 2 and 3 Piping Fatigue Evaluation). However, the LRA does not clearly describe whether LRA Table 4.3.1-4 includes the transient cycle projections for non-Class 1 piping systems other than the auxiliary piping systems.

The staff also audited the description of the LRA TLAA for the allowable stress of ASME Code,Section III, Class 2 and 3 piping lines provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.3.4, Environmentally Assisted Fatigue Summary of Information in the Application. LRA Section 4.3.4, Environmentally Assisted Fatigue, discusses the EAF TLAA for ASME Code,Section III, Class 1 pressure boundary piping and components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date WCAP-18711-P/NP Comanche Peak Units 1 and 2 NUREG/CR-6260 Revision 1 Environmentally Assisted Fatigue Results in Support of First 08/18/2022 License Renewal LTR-SDA-II-21 Comanche Peak Units 1 & 2 License Renewal: Primary Revision 1 P/NP Equipment and Piping Environmentally Assisted Fatigue 01/11/2022 Screening Evaluation Results CN-SDA-21-011 Comanche Peak Units 1 & 2 License Renewal: Primary Revision 1 Equipment and Piping Environmentally Assisted Fatigue 12/01/2021 Screening Evaluation Results CN-SDA-20-26 Comanche Peak Units 1 and Reactor Vessel Environmentally Revision 0 Assisted Fatigue Analysis for License Renewal 12/02/2020 CN-SDA-II-21-003 Assessment Record of CN-SDA-II-21-003 for CAP IR-2022- 08/18/2022 6325 CN-SDA-II-21-015 Comanche Peak Units 1 & 2 License Renewal: Hot Leg Surge Revision 0 Nozzle Environmentally Assisted Fatigue Evaluation 11/03/2021 LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/03/2022 CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring TR-2021-000782 Track and Document the Planning, Performance and Reporting 02/01/2021 for 2021 Self-Assessment for the Thermal Stratification Monitoring Program CN-SDA-21-012 Comanche Peak Unit 1 and Unit 2 60-Year Transient Cycle Revision 3 Projections 08/05/2022 83

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

• LRA Section 4.3.4 indicates that, in the detailed evaluation of EAF for sentinel (limiting) location identification, the applicant considered the technical rigor of different stress analysis methods and the level of conservatism associated with the stress analysis methods. The LRA explains that the results of determining the technical rigor and the associated conservatism are the stress analysis method rankings for EAF locations (also called stress basis comparison rankings). The LRA also indicates that EAF locations with the lower screening CUFen values and lower rankings may be removed from the sentinel location list in comparison with the other EAF locations. However, the applicant did not clearly discuss the stress analysis method rankings and their technical bases. In addition, the staff needs clarification on whether EAF locations are removed from the sentinel location list only if both the screening CUFen value and stress analysis method ranking are lower than those of a more limiting location, respectively.

• LRA Table 4.3.4-2 describes the sentinel locations of EAF for piping lines and the associated 60-year projected CUFen values. The table identifies only SS as a fabrication material of piping lines and does not include carbon steel, low alloy steel or nickel-alloy.

In contrast, LRA 4.3.4 indicates that the sentinel location is identified for each material type in a given transient section, which is a group of subcomponents and locations that experience the same transients. In addition, LRA Section 4.7.1 indicates that the reactor vessel nozzle welds are fabricated with nickel-alloys. It is unclear to the staff whether the limiting locations in Table 4.3.4-1 or 4.3.4-2 are bounding for the nickel-alloy weld locations of the reactor vessel nozzle in terms of CUFen and environmental fatigue correction factor (Fen) in the EAF analysis.

• The following document indicates that there was a need to revise the CUEen calculations for the accumulator nozzles based on corrections to 60-year transient cycle projections

(

Reference:

Westinghouse CN-SDA-II-21-003-R0-ASMT-1, Assessment Record of CN-SDA-II-21-003 for CAP IR-2022-6325, 8/18/2022). The reference document indicates that the 60-year projection cycles of the following transients needed to be corrected: (1) refueling transient; (2) tube leak test transient; (3) accumulator line refueling transient; (4) reactor coolant system (RCS) venting transient; (5) reactor vessel stud tensioning transient; (6) accumulator check valve test transient. Specifically, the projected cycles of the refueling transient and tube leak test transient are used in the EAF analysis for the accumulator nozzles. However, the revised 60-year CUFen value for the crotch region of the nozzle (180 degree location) in the reference, also called analysis Section Number 20, is not consistent with that listed in LRA Table 4.3.4-2.

The staff also audited the description of the LRA EAF TLAA for ASME Code,Section III, Class 1 pressure boundary piping and components provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA EAF TLAA.

LRA Section 4.3.4 indicates that the EAF TLAA is dispositioned in accordance with 10 CFR 54.21(c)(1)(iii) and the aging effects of EAF will be managed by using the Fatigue Monitoring AMP and Steam Generators AMP. In contrast, the FSAR supplement cites 10 CFR 54.21(c)(1)(ii) instead of 10 CFR 54.21(c)(1)(iii) as a TLAA disposition. The staff will 84

consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.

LRA TLAA Section 4.3.5, Reactor Vessel Internals Fatigue Analyses Summary of Information in the Application. LRA Section 4.3.5, Reactor Vessel Internals Fatigue Analyses, discusses the fatigue TLAA for reactor vessel internals. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date CN-MRCDA-07-42 Comanche Peak Unit 1 and Unit 2 Power Uprate - Reactor Revision 1 Vessel Evaluation 08/07/2007 CN-RIDA-07-36 Comanche Peak Unit 1 and Unit 2 Reactor Internal Revision 0 Components Evaluation 2007 WCAP-16840-P/NP Comanche Peak Nuclear Power Plant Stretch Power Uprate Revision 0 Licensing Report August 2007 LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 8/3/2022 CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring TR-2021-000782 Track and Document the Planning, Performance and Reporting 02/01/2021 for 2021 Self-Assessment for the Thermal Stratification Monitoring Program During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

• LRA Section 4.3.5 indicates that the following reference includes the most recent fatigue evaluations in the CPNPP CLB for reactor vessel internals (

Reference:

WCAP-16840-NP, Comanche Peak Nuclear Power Plant Stretch Power Uprate Licensing Report, Rev. 0). The staff noted a potential inconsistency in the design transients between LRA Table 4.3.1-2 and WCAP-16840-NP, Table 2.2.6-1. Specifically, LRA Table 4.3.1-2 includes the bypass line tempering valve transient, which is only applicable to CPNPP Unit 2 and has 20 design cycles. However, this transient is not included in WCAP-16840-NP, Table 2.2.6-1. In addition, WCAP-16840-NP, Table 2.2.6-1 includes the split flow bypass valve transient, which is only applicable to CPNPP Unit 2 and has 40 design cycles. However, this transient is not included in LRA Table 4.3.1-2.

The staff also audited the description of the LRA fatigue TLAA for reactor vessel internals provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.3.6, High-Energy Line Break Summary of Information in the Application. LRA Section 4.3.6, High-Energy Line Break, discusses the HELB TLAA for high-energy piping lines. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

85

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LTR-SDA-II-21-42-P Comanche Peak Unit 1 and 2 License Renewal: ASME Code Revision 1 Class 1 Piping High Energy Line Break (HELB) TLAA 12/05/2022 Evaluation LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/03/2022 CR-2012-003683 Strategic Self-Assessment of Thermal Stratification and Fatigue 04/11/2012 Cycle Monitoring TR-2021-000782 Track and Document the Planning, Performance and Reporting 02/01/2021 for 2021 Self-Assessment for the Thermal Stratification Monitoring Program During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

• LRA Section 4.3.6 indicates that the time-limited portion of the HELB analysis is related to the screening criterion of a CUF value 0.1 for break location postulation. In comparison, FSAR, Section 3.6B.2 describes the CLB screening criteria that are used to determine the intermediate locations of postulated breaks for the HELB analyses.

Specifically, FSAR Section 3.6B2.1.2 indicates that the CUF value of 0.1 is included in the screening criteria for HELB location postulation for ASME Code,Section III, Class 1 piping. FSAR Section 3.6.B2.1.2 also indicates that the postulation of HELB locations for ASME Code non-Class 1 piping is, in part, based on the allowable stress range for expansion stress (SA), consistent with Branch Technical Position MEB 3-1 (ML052340555). SA may need to be adjusted by a stress range reduction factor that is determined by the number of thermal cycles, as addressed in the implicit fatigue analysis in LRA Section 4.3.3. However, LRA Section 4.3.6 does not clearly discuss whether the HELB location postulation for ASME Code non-Class 1 piping, which involves SA, is a basis for identifying the HELB analysis as a TLAA. In addition, LRA Section 4.3.6 does not address whether additional break locations and their effects will be evaluated in the HELB analyses as part of corrective actions under the Fatigue Monitoring AMP if new additional piping break locations are identified based on (1) the CUF threshold of 0.1 or (2) the reduction in SA.

The staff also audited the description of the LRA HELB TLAA for high-energy piping lines provided in the FSAR supplement. The staff also audited the description of the LRA HELB TLAA for high-energy lines provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.4, Environmental Qualification of Electrical Equipment Summary of Information in the Application. LRA Section 4.4, Environmental Qualification of Electrical Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and I&C components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

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Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title/Description Revision /

Date LUM00020-REPT-038 Comanche Peak Nuclear Power Plant Units 1 and 2 - License Revision 0 Renewal Environmental Qualification of Electric Components -

Aging Management Program Basis Document LUM00020-REPT-081 Comanche Peak Nuclear Power Plant Units 1 and 2 - License Revision 1 Renewal Time-Limited Aging Analysis - Environmental Qualification of Electrical Equipment DBD-EE-031 Comanche Peak Nuclear Power Plant Units 1 and 2 - Design- Revision 9 Basis Document - Environmental Qualification of Safety-Related Electrical Equipment TR-2018-000995 Tracking Report - Track Items Associated with the 2018 EQ Created:

Excellence Plan 02/05/2018 TR-2020-001719 Tracking Report - Review EPRI Technical Report A Review of Closed:

Equipment Aging Theory and Technology: Revision 1 of NP- 10/18/2020 1558 (Product ID 3002018283) for incorporation into the EQ program During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).

The staff also audited the description of the LRA Environmental Qualification of Electric Components provided in the FSAR supplement. The staff verified that the description is consistent with the acceptance criteria provided in SRP-LR Section 4.4.3.2.

LRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analyses Summary of Information in the Application. LRA Sections 4.6.1 Containment Liner Plate and 4.6.2, Containment Penetrations, discuss the fatigue analyses for the containment liner plate and hot process piping penetrations (i.e., main steam, feedwater, and steam generator blow down penetrations), respectively. The applicant dispositioned these TLAAs in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-REPT-0082 Time Limited Aging Analysis - Containment Liner Plate Revision 1 and Penetrations Fatigue, Comanche Peak Nuclear 05/20/2022 Power Plant Units 1 and 2 License Renewal Calculation 16345/6-CS(B)- Reactor Containment Building Liner Analysis Units 1 Revision 1 028 and 2 02/21/1989 Calculation 16345-CS(B)- Analysis of Sleeved Containment Penetrations Revision 6 015 02/28/2007 LTR-SDA-II-21-28 Comanche Peak Nuclear Power Plant Units 1 and 2 Revision 1 License Renewal - 60 Year Transient Projections for 01/26/2022 Class 1 RCS and Auxiliary Systems, Class 2 Heat Exchangers, and Class 1, 2 and 3 Valves 87

Document Title Revision /

Date DBD-CS-074 Comanche Peak Steam Electric Station Units 1 & 2, Revision 8 Design-Basis Document, Containment Liner and 02/05/2008 Penetrations During the audit of the TLAAs, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available, due to lack of clarity, to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs or use a voluntary LRA supplement offered by the applicant during the audit.

During the audit, the staff made the following observations:

• The staff reviewed Section 3.1 of LUM00020-REPT-0082, Revision 1, and pages 51, 67-68, 81-83 of Calculation 16345/6-CS(B)-028, Revision 1, and verified that the six fatigue waiver conditions of the ASME Code,Section III, Division 1, Subsection NB-3222.4(d) E were documented and satisfied for the carbon steel containment liner plate in accordance with NE-3131(d) and NB-3222.4.

• The staff reviewed Section 3.2 of LUM00020-REPT-0082, Revision 1, and pages 51, 59.4 thru 59.9 of Calculation 16345-CS(B)-015, Revision 6, and verified that the six fatigue waiver conditions of the ASME Code,Section III, Division 1, Subsection NB-3222.4(d) E were documented and satisfied for the carbon steel containment process piping hot penetrations (main steam, feedwater, steam generator blowdown penetrations) in accordance with NE-3131(d) and NB-3222.4.

• The staff noted that there was a lack of clarity in LRA Sections 4.6.1 and 4.6.2 and their FSAR supplements regarding the material based on which the fatigue waiver analyses were performed and how it was bounding or representative of the other materials of the containment liner (including anchors and integral attachments) and containment penetrations.

• The staff also noted that the FSAR supplement in LRA Section A.3.5.1 did not describe the cycles considered for all the transients that were used in the fatigue waiver analysis of the containment liner plate.

The staff also audited the descriptions of the LRA TLAAs for Containment Liner Plate Fatigue and Containment Penetrations Fatigue provided in the FSAR supplement in LRA Section A.3.5.1 and LRA Section A.3.5.2, respectively. The staff found that sufficient clarity of information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA TLAAs Containment Liner Plate Fatigue and Containment Penetrations Fatigue. The staff will consider issuing RAIs or use a voluntary supplement offered by the applicant during the audit in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program descriptions.

LRA TLAA Section 4.7.1, Leak-Before-Break Summary of Information in the Application: LRA Section 4.7.1 Leak-Before-Break describes the Comanche Peak TLAA on the leak-before-break (LBB) evaluation for the RCS piping.

CPNPP dispositioned the TLAA with 10 CFR 54.21(c)(1)(ii) for the reactor coolant primary loop 88

piping and dispositioned the TLAA with 10 CFR 54.21(c)(1)(i) for accumulator injection lines, residual heat removal (RHR) lines, and pressurizer surge lines.

Audit Activities: In addition to the OE documentation contained in the LRA and ePortal, the staff conducted additional searches of the applicants CAP database, using keywords: leak-before-break, rupture, crack, leak rate, leaks in RCS primary piping, through wall leaks in RCS primary piping.

The table below lists the documents that were reviewed by the staff and were found to be relevant to TLAA Section 4.7.1, Leak-Before-Break. These documents were identified in the staffs search of the CPNPP operating experience database. During the audit of the operating experience program element, the staffs independent database search did not identify any OE that would indicate the LBB analysis may not be adequate to manage the aging effects. The staff will document its review of relevant OE in the SE.

Document Title Revision /

Date NUREG-0797, Supplement Safety Evaluation Report related to the operation of Revision 0, 23 Comanche Peak Steam Electric Station, Units 1 and 2 February 1990 NUREG-0797, Supplement Safety Evaluation Report related to the operation of Revision 0, 26 Comanche Peak Steam Electric Station, Unit 2 February 1993 CPNPP LRA Comanche Peak Nuclear Power Plant License Renewal Revision 0, Application October 2022 WCAP-10527 Technical Justification for Eliminating Large Primary Loop Revision 0, Pipe Rupture as the Structural Design-Basis for the April 1984 Comanche Peaks Units 1 and 2 WCAP-13167 Technical Justification for Eliminating 10 Inch Accumulator Revision 0, Lines Rupture as the Structural Design-Basis for the January 1992 Comanche Peak Nuclear Plant Unit 2 WCAP-13165 Technical Justification for Eliminating Residual Heat Revision 0, Removal Lines Rupture as the Structural Design-Basis for December 1991 Comanche Peak Nuclear Power Plant Units2 WCAP-12258 Supplement 2 Evaluation of Thermal Stratification for Comanche Peak Revision 0, Unit 1 Residual Heat Removal Lines August 1989 WCAP-12248 Supplement 3 A Supplementary Assessment of Leak-Before-Break for Revision 0, the Pressurizer Surge Line of Comanche Peak Unit 1 June 1990 WCAP-13100 Technical Justification for Eliminating Pressurizer Surge Revision 0, Line Rupture from the Structural Design-Basis for December 1991 Comanche Peak Unit 2 WCAP-10527 Technical Justification for Eliminating Large Primary Loop Revision 3, Pipe Rupture as the Structural Design-Basis for the January 2023 Comanche Peaks Units 1 and 2 for License Renewal Program (60 years) PROPRIETARY NUREG-0800, Section 3.6.3 Leak-Before-Break Evaluation Procedures Revision 1, March 2007 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii) for the reactor coolant primary loop piping for the period of extended operation. The staff also verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i) for the accumulator injection lines, RHR lines, and pressurizer surge lines piping for the period of extended operation. The staff found that sufficient information was available to complete its review of the applicants basis for its TLAA disposition. If further information is needed to complete the staffs SE input, the staff will consider issuing RAIs.

89

The staff also audited the description of the LRA LBB TLAA provided in the FSAR supplement.

The staff verified that this description is consistent with the information provided in the FSAR supplement of the LRA LBB TLAA. If further information is needed to complete the staffs SE input, the staff will consider issuing RAIs.

LRA TLAA Section 4.7.2, Reactor Coolant Pump Casings ASME Code Case N-481 Summary of Information in the Application. LRA Section 4.7.2, Reactor Coolant Pump Casings ASME Code Case N-481, discusses the analysis for the acceptability of applying code case N-481, Alternatives Examination Requirements for Cast Austenetic Pump Casings to the reactor coolant pump casings at Comanche Peak. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i)..

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LTR-SDA-20-093-P Comanche Peak Units 1 and 2 Reactor Coolant Pump Revision 0 Westinghouse Letter Report Casings ASME Code Case N-481 Analysis for 60-year 04/14/2021 License Renewal ASME Code Case N-481 Alternative Examination Requirements for Cast Austenitic 03/28/2004 Pump Casings,Section XI, Division 1 WCAP-13045 Compliance to ASME Code Case N-481 of the Primary Loop Revision 0 Pump Casings of Westinghouse Type Nuclear Steam Supply August 1991 Systems PWROG-17033-NP-A Update for Subsequent License Renewal: WCAP-13045, Revision 1 Compliance to ASME Code Case N-481 of the Primary Loop November 2019 Pump Casings of Westinghouse Type Nuclear Steam Supply Systems LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review 08/03/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports the disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the LRA reactor coolant pump code case N-481 provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

LRA TLAA Section 4.7.3, Reactor Coolant Pump Flywheel Fatigue Crack Growth Analysis, Audit Report Input Summary of Information in the Application. LRA Section 4.7.3, Reactor Coolant Pump Flywheel Fatigue Crack Growth Analysis, discusses the analysis underlying the 20-year inspection interval for the reactor coolant pump flywheel. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

90

Document Title Revision / Date N/A Comanche Peak Nuclear Power Plant Units 1 and 2 License October 2022 Renewal Application N/A Comanche Peak Nuclear Power Plant, Unit No. 1 Facility April 1990 Operating License, Appendix A - Technical Specifications N/A Comanche Peak Nuclear Power Plant, Unit No. 2 Facility April 1993 Operating License, Appendix A - Technical Specifications N/A Comanche Peak Nuclear Power Plant Final Safety Analysis September 2020 Report During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RCI.

During the audit, the staff made the following observations:

• The applicants LRA, FSAR, and Technical Specifications consistently communicated the applicants basis for the 20-year inspection interval for the reactor coolant pump flywheel.

• The applicants LRA did not explicitly address the conditions listed in the staffs SE for Topical Report PWROG-17011, Revision 2 (ML19198A056).

• The applicants staff responded to the NRC staffs breakout questions, clarifying that Comanche Peaks reactor coolant pump flywheels are bounded by conditions in the staffs SE referenced in item 2.

• The NRC staff communicated to the applicants staff that an RCI would be issued to confirm on the docket that the actual number of start/stop cycles for the reactor coolant pump flywheels are bounded by that assumed in the analysis.

The staff also audited the description of the LRA reactor coolant pump flywheel fatigue crack growth analysis TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

LRA TLAA Section 4.7.4, Crane Load Cycle Limit Summary of Information in the Application. The LRA Section 4.7.4, Crane Load Cycle Limit discusses the analyses for the Auxiliary Filter Hoist, Containment Access Rotating Platform Hoist, Containment Fuel Handling Bridge Crane, Containment Polar Crane, Containment Telescopic Jib Crane, Drumming Storage Area Crane, Fuel Building Overhead Crane, Fuel Handling Bridge Crane, Refueling Machine, Safety Chiller Hoist, SWIS Crane and Vertical Cask Transporter. The applicant dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

91

Document Title Revision / Date DBD-ME-006 Control of Heavy Loads at Nuclear Plants Revision 40 LUM00020-REPT-083 TLAA - Fatigue of Cranes (Crane Cycle Limits) Revision 3 LUM00020-REPT-050 Comanche Peak Nuclear Power Plant Units 1and 2 License Revision 1 Renewal Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Aging Management Program Basis Document LUM00020-REPT-080 Comanche Peak Units 1 and 2 License Renewal Time Limited Revision 2 Aging Analysis (TLAA) and Exemption Identification LUM00020-LRPI-006 Comanche Peak Nuclear Plant License Renewal Project Revision 0 Instruction, Time Limited Aging Analyses Identification and Exemption LUM00020-REPT-033 Comanche Peak Nuclear Plant License Renewal Screening and Revision 0 Aging Management Review Report for the Structural Commodities FDA-2019-000039-02 Replace entire trolley, bridge motors and brakes and entire Revision 0 control system as part of a comprehensive upgrade of Fuel Building Overhead Crane (FBOC) components CPNPP FSAR CPNPP Final Safety Analysis Report (FSAR): Amendment 111 Table 17A-1, Table 8.3-11 CP-0041A-005 Containment Fuel Handling Bridge Crane Revision 2 NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants May 1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants July 1980 CMAA, Specification, Specification for Electric Overhead Travelling Cranes 1975 No.70 NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants May 1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants July 1980 ASME NUM-1 Rules for Construction of Cranes, Monorails, and Hoists (With 2016 ridge or Trolley or Hoist of the Underhung Type)

ASME NOG-1 Rules for Construction of Overhead and Gantry Cranes (Top 2015 Running Bridge, Multiple Girder)

ASME B30.2 Overhead and Gantry Cranes (Top Running Bridge, Single or 2005 Multiple Girder, Top Running Trolley Hoist)

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the LRA provided in the FSAR supplement in Section A.3.6.4., Crane Load Cycle Limits TLAA. The staff verified this description is consistent with the description provided in the SRP-LRfor TLAAs.

LRA TLAA Section 4.7.5, Spent Fuel Pool Metal Corrosion Allowance Summary of Information in the Application. LRA Section 4.7.5, Spent Fuel Pool Metal Corrosion Allowance, discusses the Spent Fuel Pool metal corrosion allowance to ensure that minimum wall thickness requirements are maintained through the life of the component. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-084 CPNPP UNITS 1 and 2 License Renewal Plant Specific TLAA Revision 2 Evaluation 92

FSAR Section 9.1.3.2.1, Component Description Amendment 110 NUREG-0797 Safety Evaluation Report to the operations of the Comanche July 1981 Peak Electric Station, Units 1 and 2, DOCKET Nos 50-455 and 50-446 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the LRA TLAA for Spent Fuel Pool Metal Corrosion Allowance provided in the FSAR supplement in LRA Appendix A.3.6.5, Spent Fuel Pool Metal Corrosion Allowance. The staff found that this description provided in FSAR supplement provides adequate description of the LRA TLAA Spent Fuel Pool Metal Corrosion Allowance.

LRA TLAA Section 4.7.6, Protective Coatings Summary of Information in the Application. LRA Section 4.7.6, Protective Coatings, discusses the analysis for the ability of the qualified coatings in containment to resist environmental radiation for the life of the plant. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LUM00020-CALC-001- Comanche Peak Total for Containment Coatings in Steam Revision 1 Rev1.pdf Generator Compartments and Surroundings During an Unpressurized Loss of Coolant Accident TERPT_ER-ME-124-0_- Evaluation of CPNPP Protective Coatings Revision 0

_-.pdf During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the Protective Coating TLAA in the FSAR supplement.

The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.7.7, Steam Generator Tubes Metal Corrosion Allowance Summary of Information in the Application. LRA Section 4.7.7, Steam Generator Tubes Metal Corrosion Allowance, discusses the analysis for the corrosion allowance for steam generator tube wall thickness for Unit 2. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date Westinghouse Comanche Peak Unit 2 License Renewal Application Assessment Revision 1 LTR-CECO-21-076 of Steam Generator Tubes Metal Corrosion Allowance 93

TR-2021-002734 Tracking Report (Identified error in FSAR Section 5.4.2B.5.4 04/21/2021 related to primary side corrosion rate of steam generator tubing)

ENERCON LUM00020- Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 2 REPT-084 Renewal Plant Specific TLAA Evaluation Comanche Peak Section 5.4.2B.5.4 Allowable Tube Wall Thinning Under Accident Certified FSAR Updated Final Safety Conditions Amendment 111, Analysis Report 02/01/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the LRA Steam Generator Tubes Metal Corrosion Allowance provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.7.8, Steam Generator Flow-Induced Vibration and Tube Wear Evaluations Summary of Information in the Application. LRA Section 4.7.8, Steam Generator Flow Induced Vibration and Tube Wear Evaluation, describes the analysis for steam generator (SG) tube wear from vibration resulting from the thermal hydraulic conditions within the Unit 1 and Unit 2 SGs. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i) for the Unit 1 SGs and 10 CFR 54.21(c)(1)(ii) for the Unit 2 SGs.

Audit Activities. The table below lists the document that was reviewed by the staff and was found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date Westinghouse Comanche Peak Units 1 and 2 License Renewal Application Revision 1 LTR-CECO-20-082-P Assessment of Steam Generator Flow Induced Vibration and Tube Wear Evaluations and Steam Generator U-Bend Tube Vibration and Fatigue Assessment During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i) for Unit 1 and 10 CFR 54.21(c)(1)(ii) for Unit 2.

The staff also audited the description of the LRA Steam Generator Flow-Induced Vibration and Tube Wear Evaluations provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.7.9, Steam Generator U-Bend Tube Vibration and Fatigue Assessment Summary of Information in the Application. LRA Section 4.7.9, Steam Generator U-Bend Tube Vibration and Fatigue Assessment, discusses the analysis of the steam generator tubes for vibration and high cycle fatigue. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i) by demonstrating that the U-Bend tube vibration and fatigue are either not applicable (Unit 1) or the current fatigue assessment adequately considers the period of extended operation (Unit 2).

Audit Activities. The table below lists the document that was reviewed by the staff and was found relevant to the TLAA. The staff will document its review of this information in the SE.

94

Document Title Revision /

Date Westinghouse Comanche Peak Units 1 and 2 License Renewal Application Revision 1 LTR-CECO-20-082-P Assessment of Steam Generator Flow Induced Vibration and Tube Wear Evaluations and Steam Generator U-Bend Tube Vibration and Fatigue Assessment During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the LRA Steam Generator U-Bend Tube Vibration and Fatigue Assessment provided in the FSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-LR.

LRA TLAA Section 4.7.10, Flaw Tolerance Evaluation for Susceptible Reactor Coolant Loop Cast Austenitic Stainless Steel Piping Components Summary of Information in the Application. LRA Section 4.7.10, Flaw Tolerance Evaluation for Susceptible Reactor Coolant Loop Cast Austenitic Stainless Steel Piping Components, discusses the flaw tolerance evaluation for the susceptible CASS components at CPNPP. It also states that the flaw tolerance evaluation was performed to demonstrate that even with thermal aging, the susceptible CASS components are flaw tolerant for 60 years of service. The applicant dispositioned this TLAA in accordance with 10 CFR 54.21(c)(1)(i).

Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff conducted additional searches of the applicants CAP database, using alternate keywords.

The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.

Document Title Revision /

Date LTR-SDA-20-087-NP Flaw Tolerance Evaluation for Susceptible Reactor Coolant Revision 0 Loop Cast Austenitic Stainless Steel Piping Components in September 24, Comanche Peak Units 1 and 2 for 60 Year License 2021 Renewal TBX-TCX-IPA-AMP- Comanche Peak Units 1 and 2 License Renewal, Thermal Revision 1 XI.M12 Aging Embrittlement of CASS Program Basis Document January 3, 2023 CR2012-002117 Strategic Self-Assessment of the RCS Materials Revision 1 Management System WCAP-10528-NP Technical Justification for Eliminating Large Primary Loop Revision 3 Pipe Rupture as the Structural Design-Basis for Comanche Peak Units 1 and 2 for the License Renewal Program (60 years)

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). The staff also audited the description of the LRA TLAA for the subject components provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

95

LRA TLAA Section 4.7.11, Safe Shutdown Impoundment Sedimentation Summary of Information in the Application. LRA Section 4.7.11, Safe Shutdown Impoundment Sedimentation, discusses the sediment reduction in the Service Water Intake Channel for the Safe Shutdown Impoundment (SSI) that was required by the Technical Requirement Manual to maintain adequate cooling capacity for the plant. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-084 CPNPP UNITS 1 and 2 License Renewal Plant Specific TLAA Revision 2 Evaluation FSAR Subsections Amendment Nos.

2.5.6.2.2 Safe Shutdown Impoundment Dam (SSI Dam), 104 2.4.8.2.2, Safe Shutdown Impoundment (SSI), 110 2.4.11.6, Heat Sink Dependability Requirements, 110 9.2.5.2, System Description, and 111 9.2.5.3, Safety Evaluation 111 Technical Specification LCO 3.7.9, The Safe Shutdown impoundment {SSI) shall be Amendment OPERABLE No. 156 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).

The staff also audited the description of the LRA TLAA for Safe Shutdown Impoundment Sedimentation provided in the FSAR supplement in LRA Appendix A.3.6.11, Safe Shutdown Impoundment Sedimentation. The staff found that this description provided in FSAR supplement provides adequate description of the LRA TLAA Safe Shutdown Impoundment Sedimentation.

AMR Items Not Associated with an AMP LRA AMR Further Evaluation (FE) Sections 3.2.2.2.3.2, 3.2.2.2.6, 3.3.2.2.3, 3.3.2.2.5, 3.4.2.2.2, and 3.4.2.2.3 Summary of Information in the Application. The LRA addresses further evaluation of cracking due to stress corrosion cracking, and loss of material due to pitting or crevice corrosion, of SS in the Engineered Safety Features, Auxiliary, and Steam and Power Conversion Systems. The LRA sections for these further evaluation discussions are: 3.2.2.2.3.2, 3.2.2.2.6, 3.3.2.2.3, 3.3.2.2.5, 3.4.2.2.2, and 3.4.2.2.3.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the LRA further evaluation sections listed above. The staff will document its review of this information in the SE.

Document Title Revision / Date LUM00020-REPT-017 License Renewal Screening and Aging Management Review Revision 0 Report for the Compressed Air and Gas Systems LUM00020-REPT-010 License Renewal Screening and Aging Management Review Revision 1 Report for the Containment Spray System 96

LUM00020-REPT-036 Mechanical Aging Management Review Further Evaluation Revision 0 and Summary LRA AMR FE Section 3.6.2.2.2, Reduced Insulation Resistance due to Presence of Any Salt Deposits and Surface Contamination, and Loss of Material due to Mechanical Wear Caused by Wind Blowing on Transmission Conductors Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in LRA Section 3.6.2.2.2 and the following:

• LRA Table 3.6-1, Summary of Aging Management Evaluations for Electrical Commodities, Item Number 3.6-1, 002 - High-voltage insulators composed of porcelain; malleable iron; aluminum; galvanized steel; cement exposed to air - outdoor

• LRA Table 3.6-1, Item Number 3.6-1, 003 - High-voltage insulators composed of porcelain; malleable iron; aluminum; galvanized steel; cement exposed to air - outdoor The LRA states that high-voltage (HV) insulators are subject to AMR if they are necessary for restoration of offsite power following a station blackout (SBO) event. The HV insulators evaluated for Comanche Peak LR are those used to support uninsulated, HV electrical components such as transmission conductors. The LRA notes that based on the type of HV insulators, the plant-specific configuration of the conductors connected to the insulators, and environmental conditions at the plant the type of aging mechanisms identified in the GALL-LR Report are not applicable to the HV insulators at CPNPP, Units 1 and 2. The applicant considers current inspection process as adequate.

Audit Activities. To support its audit of the program, the staff also conducted an onsite audit. On January 31 - February 1, 2023, the staff participated in an onsite audit at CPNPP where the staff interviewed the applicants staff and performed walkdowns of the CPNPP, Units 1 and 2.

Specifically, the staff observed HV insulators associated with the LRA. The staff did not identify any adverse or abnormal conditions with HV insulators during the walkdowns. During the onsite audit, the applicant confirmed that the type of aging parameters, for HV insulators, identified in the GALL-LR Report had not been experienced at the CPNPP, Units 1 and 2, and therefore had not developed a program for LR.

The table below lists documents that were reviewed by the staff and were found relevant to the LRA further evaluation section listed above. The staff will document its review of this information in the SE.

Title Revision /

Document Date LUM00020-REPT-003 Comanche Peak Nuclear Power Plant Units 1 and 2 License Revision 0 Renewal Operating Experience Review LUM00020-REPT-034 Comanche Peak Units 1 and 2 License Renewal Screening - Revision 1 Electrical, Instrumentation & Controls LUM00020-REPT-035 Comanche Peak Units 1 and 2 License Renewal Aging Revision 1 Management Review - Electrical and I&C Commodities AR 1866053 Chipped and cracked insulators and epoxy repaired sections 04/20/2013 falling off. The cause is mostly old age of the insulators and improper repairs. This also applies to the following ARs:

1866231, 2086837, 2266011 97

During the audit, the staff made the following observations:

• The CPNPP, Units 1 and 2, switchyard has both porcelain and polymer type of HV insulators. The LRA did not identify any adverse events documented via the CAP. In report # LUM00020-REPT-035, the applicant stated that visual inspections of the switchyard are performed on an annual basis. These inspections include a ground-based inspection (using binoculars) of polymer dead-end HV insulators for loose hardware, corrosion, damaged insulators, and indications of corona on polymer composite dead ends. These inspections also include an inspection for bird nests at the base of under hung insulators. Any anomalies discovered during these routine inspections would warrant their replacement in a timely manner. The staff notes that the applicant concluded that the periodic inspections and the absence of plant-specific OE verifies that this aging effect is not significant for polymer HV insulators associated with the offsite power system required for recovery from an SBO event and no updates to existing maintenance programs or plant licensing documents is required.

LRA AMR FE Section 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in LRA Section 3.6.2.2.3 and the following:

• LRA Table 3.6-1, Summary of Aging Management Evaluations for Electrical Commodities, Item Number Table 3.6-1, 004 - Transmission conductors composed of aluminum; steel exposed to air - outdoor

• LRA Table 3.6.1, Item Number 3.6-1, 005 - Transmission connectors composed of aluminum; steel exposed to air - outdoor

• LRA Table 3.6.1, Item Number 3.6-1, 006 - Switchyard bus and connections composed of aluminum; copper; bronze; stainless steel; galvanized steel exposed to air - outdoor

• LRA Table 3.6.1, Item Number 3.6-1, 007 - Transmission conductors composed of aluminum; steel exposed to air - outdoor

• LRA Table 3.6.1, Item Number 3.6-1, 020 - Transmission conductors composed of aluminum exposed to air - outdoor The LRA states that transmission conductors are subject to AMR if they are necessary for restoration of offsite power following a SBO event. At Comanche Peak, a common overhead transmission line from the 138 kilo Volt (kV) switchyard to startup transformer XST1 and alternate startup transformer XST1A coupled with a common overhead line from the 345kV switchyard to startup transformer XST2 and alternate startup transformer XST2A support SBO recovery paths.

Audit Activities. To support its audit of the program, the staff also conducted an onsite audit. On January 31 - February 1, 2023, the staff participated in an onsite audit at CPNPP where the staff interviewed the applicants staff and performed walkdowns of the CPNPP, Units 1 and 2.

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Specifically, the staff observed transmission conductors, switchyard bus, and connections associated with the LRA. The staff did not identify any adverse or abnormal conditions with these items during the walkdowns.

The table below lists documents that were reviewed by the staff and were found relevant to the LRA further evaluation section listed above. The staff will document its review of this information in the SE.

Title Revision /

Document Date LUM00020-REPT-003 CPNPP Units 1 and 2 License Renewal Operating Experience Revision 0 Review LUM00020-REPT-034 Comanche Peak Units 1 and 2 License Renewal Screening - Revision 1 Electrical, Instrumentation & Controls LUM00020-REPT-035 Comanche Peak Units 1 and 2 License Renewal Aging Revision 1 Management Review - Electrical and I&C Commodities During the audit, the staff made the following observations:

• The overhead conductors at CPNPP, Units 1 and 2, are Aluminum Conductors that are Steel Reinforced similar to those that have been evaluated for degradation due to environmental factors by Ontario Hydro and accepted by the NRC staff. The LRA did not identify any adverse events documented via the CAP. In report # LUM00020-REPT-003, the applicant stated that keyword searches of the LR related OE report did not find any instances where transmission conductor and connections have experienced the types of aging effects/mechanisms applicable to the overhead conductors.

LRA AMR FE Section 3.6.2.3, AMR Results Not Consistent With or Not Addressed in the GALL Report - Fuse Holders (Not Part of Active Equipment): Metallic Clamps Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in LRA Section 3.6.2.3 pertaining to fuses and fuse holders and the following:

• LRA Table 3.6-1, Summary of Aging Management Evaluations for Electrical Commodities, Item Number 3.6-1, 016 - Fuse holders (not part of active equipment):

metallic clamps composed of various metals used for electrical connections exposed to air - indoor, uncontrolled

• LRA Table 3.6.1, Item Number 3.6-1, 017 - Fuse holders (not part of active equipment):

metallic clamps composed of various metals used for electrical connections exposed to air - indoor, controlled or uncontrolled

• LRA Table 3.6-1, Item Number 3.6-1, 021 - Fuse holders (not part of active equipment):

insulation material, Metal enclosed bus: external surface of enclosure assemblies composed of insulation material: bakelite; phenolic melamine or ceramic; molded polycarbonate; other, galvanized steel; aluminum, Steel exposed to Air - indoor, controlled or uncontrolled LRA Section 3.6.2.3 states that CPNPP performed an evaluation of fuse holders at CPNPP to determine the population of fuse holders that were not located in active devices for an AMR.

The applicant eliminated fuses in the EQ program, spare fuses, and fuses located in active 99

devices such as switchgear, power, supplies, power inverters, battery chargers, and circuit boards. The LRA also states that fuse holders that were inside panels, racks, and termination cabinets were also considered to be part of active equipment consistent with the guidance provided in ISG-5 and were eliminated from the AMR. The LRA further states that the applicants screening process determined that CPNPP has no fuses supporting a system intended function that are not part of an active equipment such as switchgear, power supplies, power inverters, battery chargers, load centers, and circuit boards. In the LRA, the applicant concluded that fuses and fuse holders are considered piece parts of the active equipment, and therefore, the fuse holders (metallic clamps) are not subject to AMR. LRA Section 2.5.1.3, Elimination of Electrical and I&C Commodity Groups Not Applicable to CPNPP, included a similar conclusion.

Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the LRA further evaluation sections listed above. The staff will document its review of this information in the SE.

Title/Description Revision /

Document Date LUM00020-REPT- Comanche Peak Units 1 and 2 License Renewal Revision 1 034 Screening - Electrical, Instrumentation & Controls LUM00020-REPT- Comanche Peak Units 1 and 2 License Renewal Revision 1 035 Aging Management Review - Electrical and I&C Commodities During the audit, the staff made the following observations:

• The staffs audit addressed only the applicants assessment for panels, racks, and termination cabinets as active equipment and the location of Class 1E fuses associated with LR.

• The CPNPP FSAR, Section 8.3.1.2.1, Compliance, page 8.3-40, described Class 1E fuses that protect isolation devices through which conductors are routed to terminal blocks within Class 1E electronics boxes.

• Based on the guidance in ISG-5, panels, racks, and termination cabinets would be considered active components if they include active electrical/electronic components.

The applicant did not list racks and termination cabinets as electrical and I&C component commodity group in the LRA, Table 2.5-1, Electrical and I&C Component Commodity Groups Installed at CPNPP. During the audit, the applicant clarified that the panels, racks, and termination cabinets include active components; the panels and termination cabinets are included in the distribution panels listed in Table 2.5-1; and the racks are instrument racks (structural element) that support instruments, indicators, or elements, which are listed in Table 2.5-1. The applicant noted that it will supplement the LRA with information that clarifies the screening of the panels, racks, and termination cabinets.

• Based on the description of the Class 1E fuses on page 8.3-40 of the FSAR, it was not clear to the staff if the Class 1E fuses are inside an active electrical equipment/enclosure/electronic box or in a passive enclosure. During the audit, the applicant clarified that the above-mentioned Class 1E fuses in the FSAR are inside the 100

electronic boxes that contained active electrical components, and therefore, they are screened out of AMR.

3. Supplements to the LRA By letters dated April 6, 2023 (ML23096A302) and April 24, 2023 (ML23114A377), Vistra OpCo voluntarily submitted two supplements to the LRA resulting from discussions held during the audit.

4. Audit Questions Provided to Vistra OpCo Over the course of the audit, the NRC staff provided audit questions to Vistra OpCo to facilitate the audit discussions (ML23172A147).

Subject Area Meeting Date Onsite Audit 1/30/23 - 2/1/23 Breakout Session: PWR Vessel Internals AMP 2/28/23 3/6/23 Breakout Session: RCP Flywheel TLAA 3/2/23 Breakout Session: Fatigue Monitoring AMP 3/2/23 3/13/23 3/14/23 Breakout Session: Reactor Head Closure Stud Bolting AMP 3/6/23 3/13/23 Breakout Session: RPV Embrittlement TLAAs 3/6/23 Breakout Session: Fire Protection Scoping and Screening 3/7/23 Breakout Session: Aboveground Metallic Tanks and External 3/7/23 Surfaces Monitoring of Mechanical Components AMPs Breakout Session: Inspection of Overhead Heavy Load and 3/7/23 Light Load (Related to Refueling) Handling Systems AMP and Crane Load Cycle Limits TLAA Breakout Session: Reactor Surveillance AMP 3/8/23 3/21/23 Breakout Session: Leak-Before-Break TLAA 3/8/23 Breakout Session: Flow-Accelerated Corrosion AMP 3/9/23 Breakout Session: Boric Acid Corrosion AMP 3/9/23 Breakout Session: Metal Fatigue TLAAs 3/9/23 Breakout Session: Thermal Aging Embrittlement of Cast 3/13/23 Austenitic Stainless Steel AMP Breakout Session: Buried and Underground Piping and Tanks 3/13/23 AMP Breakout Session: EQ of Electric Components AMP 3/14/23 Breakout Session: Structural Scoping and Screening and 3/14/23 ASME Section XI, Subsection IWL AMP Breakout Session: Containment Liner Plate and Containment 3/14/23 Penetrations TLAAs Breakout Session: Neutron Fluence Projections TLAA 3/15/23 Breakout Session: Bolting Integrity and Masonry Wall AMPs 3/15/23 Breakout Session: ASME Section XI, Subsection IWE and 10 3/15/23 CFR Part 50 Appendix J AMPs Breakout Session: Cracking of Nickel-Alloy Components and 3/16/23 Loss of Material Due to Boric Acid-Induced Corrosion in RCPB Components Breakout Session: ASME Section XI, Subsection IWF AMP 3/16/23 Breakout Session: Fire Water System AMP 3/16/23 Breakout Session: Structures Monitoring AMP 3/16/23 101

Subject Area Meeting Date Onsite Scoping and Screening Audit 3/20/23 - 3/22/23 Breakout Session: Flux Thimble Tube AMP 3/21/23 Breakout Session: Identification of Structures and Components 3/23/23 Subject to AMR 3/29/23 Breakout Session: Open-Cycle Cooling Water AMP 3/23/23 Breakout Session: One-Time Inspection of ASME Code Class 1 3/23/23 Small-Bore Piping AMP Breakout Session: Steam Generators AMP 3/23/23 Breakout Session: Fire Protection AMP 3/27/23 Breakout Session: Aluminum AMR 3/27/23 Breakout Session: Internal Coatings/Linings for In-Scope 3/27/23 Piping, Piping Components, Heat Exchangers, and Tanks AMP Breakout Session: Closed Treated Water System AMP 3/28/23 Breakout Session: Fuel Oil Chemistry AMP 3/28/23 Breakout Session: Selective Leaching AMP 3/29/23 Breakout Session: Water Chemistry AMP and Stainless Steel 3/29/23 AMR Breakout Session: Inspection of Internal Surfaces in 3/29/23 Miscellaneous Piping and Ducting Components AMP

5. Applicant Personnel Contacted During the Audit Name Affiliation Todd Evans Luminant Amit Kalia Luminant Taylor Smith Luminant Nicholas Boehmisch Luminant Thomas Crippes Luminant Michael Fraley Luminant Ramiz Gilada Luminant Thomas Hughes Luminant Dino Scorziello Luminant Gary Adkins Enercon Andrew Arend Enercon Spencer Feuerstein Enercon Jeff Gromatzky Enercon James Hamlen Enercon Michael Hernandez Enercon Kenneth Putnam Enercon Laura Swenzinski Enercon Guy Wilkerson Enercon Dodge Williams Enercon Leo Zimmerman Enercon Allison Hoke Enercon Tristen Hunnewell Enercon Mitch McFarland Enercon Andrew Hawk Westinghouse Greg Imbrogno Westinghouse Susan Jaques Westinghouse Brett Lynch Westinghouse Tim Nowicki Westinghouse 102

6. Exit Meeting An exit meeting was held with the applicant on May 18, 2023, to discuss the results of the regulatory audit. The staff is considering the issuance of RAIs and RCIs to support the completion of the staffs LRA review.

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