ML020580391

Relief Request RR 3-28, Risk-Informed Inservice Inspection (RI-ISI) Program

ML020580391
Person / Time
Site:	Indian Point
Issue date:	02/05/2002
From:	Kansler M Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IPN-02-007
Download: ML020580391 (22)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Entergy 440 Hamilton Avenue P. 0. Box 5029 White Plains, NY 10601-5029 Tel 914 272 3500 February 5, 2002 IPN-02-007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001

SUBJECT:

Indian Point Nuclear Generating Unit No. 3 Docket No.60-286 Relief Request RR 3-28, Risk-Informed Inservice Inspection (RI-ISI) Program

Reference:

1. EPRI TR-1 12657, Rev. B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure"

2. USNRC letter to Electric Power Research Institute (EPRI), dated October 28, 1999, regarding "Safety Evaluation Report Related to EPRI Risk Informed Inservice Inspection Evaluation Procedure (EPRI TR-1 12657, Revision B, July 1999)"

3. USNRC letter from J. Clifford to M. Bellamy, dated May 2, 2001, regarding "Pilgrim Nuclear Power Station - Relief Request Regarding Approval of alternative Risk-Informed Inservice Inspection Program for the Third Inspection Interval (TAC No. MB0841)"

4. USNRC letter from M. Gamberoni to J. Knubel, dated September 12, 2000, regarding "James A. FitzPatrick Nuclear Power Plant, American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) - Relief for Risk-Informed Inservice Inspection of Piping (TAC No. MA 6926)"

Dear Sir:

Entergy Nuclear Operations Inc. (ENO) requests relief to use the proposed Risk-Informed Inservice Inspection Program (Attachment 1) as an alternative to current ASME Section XI inspection requirements for Class 1, Item Category B-F and B-J welds pursuant to 10 CFR 50.55a(a)(3)(i). The RI-ISI Program has been developed in accordance with the EPRI methodology contained in EPRI TR-1 12657, Rev. B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure" (Reference 1). EPRI TR-1 12657 was approved by NRC Safety Evaluation Report, dated October 28, 1999 (Reference 2). The attached IP3-specific RI ISI program supports the conclusion that the proposed alternative provides an acceptable level of quality and safety as required by 10 CFR 50.55a(a)(3)(i).

G I'7

ENO plans to implement the initial RI-ISI program during the inspection period in effect at the time of program approval. ENO will continue to evaluate industry events and experience.

Approval is requested by July 30, 2002 to support implementation for the upcoming R12 Refueling Outage.

Similar relief requests were approved for Entergy's Pilgrim Nuclear Power Plant (Reference 3) and James A. FitzPatrick Nuclear Power Plant (Reference 4).

There are no new commitments made in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.

Very truly yours, cael R. anse Senior Vice Preside and Chief Operating Officer

Attachment:

1. Indian Point Nuclear Generating Unit No. 3 Risk-Informed Inservice Inspection Program, Rev. 0 cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission 295 Broadway, Suite 3 P.O. Box 337 Buchanan, NY 10511-0337

ATTACHMENT I TO IPN-02-007 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 RISK INFORMED INSERVICE INSPECTION PROGRAM, Rev. 0 (Relief Request RR 3-28)

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 DPR-64

RISK-INFORMED INSERVICE INSPECTION PROGRAM PLAN INDIAN POINT UNIT 3 (REVISION 0)

Table of Contents

1. Introduction ..................................................................................................... ..2 1.1 Relation to NRC Regulatory Guides 1.174 and 1.178 ........................... 2 1.2 PRA Quality ........................................................................................... 2

2. Proposed Alternative to Current Inservice Inspection Programs ...................... 3 2.1 ASME Section XI .................................................................................. 3 2.2 Augmented Programs ........................................................................... 3

3. Risk-Informed ISI Process ................................................................................ 3 3.1 Scope of Program .................................................................................. 3 3.2 Consequence Evaluation ...................................................................... 4 3.3 Failure Potential Assessment ............................................................... 4 3.4 Risk Characterization ............................................................................. 4 3.5 Element and NDE Selection ................................................................. 5 3.5.1 Additional Examinations ............................................................ 5 3.5.2 Program Relief Requests ............................................................ 6 3.6 Risk Impact Assessment ...................................................................... 6 3.6.1 Qualitative Analysis ................................................................... 6 3.6.2 Defense-in-Depth ......................................................................... 8

4. Implementation and Monitoring Program .......................................................... 8

5. Proposed ISI Program Plan Change ............................................................... 9

6. References/Documentation ............................................................................. 9 Page 1 of 19

1. INTRODUCTION Indian Point Unit 3 is currently in the third Inservice Inspection (ISI) interval as defined by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Section Xl Code for Program B. Pursuant to 10 CFR 50.55a(g)(4)(ii), the applicable ASME Section Xl Code for Indian Point Unit 3 is the 1989 Edition, No Addenda.

The objective of this submittal is to request the use of a risk-informed inservice inspection (RI ISI) approach for Class 1 piping. The RI-ISI process used in this submittal is described in Electric Power Research Institute (EPRI) Topical Report (TR) 112657 Rev. B-A "Revised Risk Informed Inservice Inspection Evaluation Procedure." The RI-ISI approach was also conducted in a manner consistent with ASME Code Case N-578 "Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method B."

1.1 Relation to NRC Regulatory Guides 1.174 and 1.178 As a risk-informed application, this submittal meets the intent and principles of Regulatory Guide 1.174 "An Approach for Using Probabilistic Risk Assessment in Risk Informed Decisions On Plant-Specific Changes to the Licensing Basis" and Regulatory Guide 1.178 "An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection of Piping". Further information is provided in Section 3.6.2 relative to defense-in-depth.

1.2 PRA Quality The Indian Point Individual Plant Examination (IPE) model [Revision 0, June 1994] was used as the initial basis to evaluate the consequences of pipe ruptures during power operation. The base core damage frequency (CDF) from this version of the IPE is 4.4E 5/yr.

Significant changes have been made to Revision 0 of the IPE model. These changes were made to reflect new data, calculations, and modifications to the plant design and procedures. Updated results from Revision 1 to the IPE model [Revision 1, June 2001]

were used to confirm that the consequence evaluations were current. The base core damage frequency (CDF) from the Revision 1 model is 1.35E-5/yr.

The NRC review of Revision 0 of the IPE concluded that the IPE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities. The review did not identify any weaknesses or possible improvements to the IPE model.

The Revision 1 model has undergone a WOG PRA certification review and there were no significant findings identified that would impact the RI-ISI consequence evaluation.

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2. PROPOSED ALTERNATIVE TO CURRENT ISI PROGRAM REQUIREMENTS 2.1 ASME Section XI ASME Section Xl Examination Categories B-F and B-J currently contain the requirements for the nondestructive examination (NDE) of Class 1 piping components.

The alternative RI-ISI program for piping is described in EPRI TR-1 12657. The RI-ISI program will be substituted for the currently approved program for Class 1 piping (Examination Categories B-F and B-J) in accordance with 10 CFR 50.55a(a)(3)(i) by alternatively providing an acceptable level of quality and safety. Other non-related portions of the ASME Section XI Code will be unaffected. EPRI TR-1 12657 provides the requirements for defining the relationship between the RI-ISI program and the remaining unaffected portions of ASME Section Xl.

2.2 Augmented Programs No augmented programs were affected by the RI-ISI application on Class 1 piping at Indian Point Unit 3.

3. RISK-INFORMED ISI PROCESS The process used to develop the RI-ISI program conformed to the methodology described in EPRI TR-1 12657 and consisted of the following steps:

0 Scope Definition 0 Consequence Evaluation 0 Failure Potential Assessment 0 Risk Characterization 0 Element and NDE Selection 0 Risk Impact Assessment 9 Implementation Program 0 Feedback Loop 3.1 Scope of Program The systems included in the RI-ISI program are provided in Table 3.1-1. The piping and instrumentation diagrams and additional plant information including the existing plant ISI program were used to define the Class 1 piping system boundaries.

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3.2 Consequence Evaluation The consequence(s) of pressure boundary failures were evaluated and ranked based on their impact on core damage and containment performance (isolation, bypass and large, early release). The consequence evaluation included an assessment of shutdown and external events. The impact on these measures due to both direct and indirect effects was considered using the guidance provided in EPRI TR-1 12657.

3.3 Failure Potential Assessment Failure potential estimates were generated utilizing industry failure history, plant specific failure history and other relevant information. These failure estimates were determined using the guidance provided in EPRI TR-1 12657.

Table 3.3-1 summarizes the failure potential assessment by system for each degradation mechanism that was identified as potentially operative.

3.4 Risk Characterization In the preceding steps, each run of piping within the scope of the program was evaluated to determine its impact on core damage and containment performance (isolation, bypass and large, early release) as well as its potential for failure. Given the results of these steps, piping segments are then defined as continuous runs of piping potentially susceptible to the same type(s) of degradation and whose failure will result in similar consequence(s). Segments are then ranked based upon their risk significance as defined in EPRI TR-1 12657.

The results of these calculations are presented in Table 3.4-1.

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3.5 Element and NDE Selection In general, EPRI TR-1 12657 requires that 25% of the locations in the high risk region (i.e. risk categories 1, 2 and 3) and 10% of the locations in the medium risk region (i.e.

risk categories 4 and 5) be selected for inspection using appropriate NDE methods tailored to the applicable degradation mechanism. In addition, per Section 3.6.4.2 of EPRI TR-1 12657, if the percentage of Class 1 piping locations selected for examination falls substantially below 10%, then the basis for selection needs to be investigated. For the Indian Point Unit 3 Station, the percentage of Class 1 welds selected for examination per the RI-ISI process is 10.1%.

A brief summary is provided below, and the results of the selection process are presented in Table 3.5-1.

Totals Description 631(1) Class 1 Piping Welds 64 RI-ISI Program Selections Notes

1. Includes all non-exempt Examination Category B-F and B-J locations. All in-scope piping components, regardless of risk classification, will continue to receive Code required pressure testing, as part of the current ASME Section XI program. VT-2 visual examinations are scheduled in accordance with the station's pressure test program that remains unaffected by the RI-ISI program.

3.5.1 Additional Examinations The RI-ISI program in all cases will determine through an engineering evaluation the root cause of any unacceptable flaw or relevant condition found during examination. The evaluation will include the applicable service conditions and degradation mechanisms to establish that the element(s) will still perform their intended safety function during subsequent operation. Elements not meeting this requirement will be repaired or replaced.

The evaluation will include whether other elements in the segment or segments are subject to the same root cause conditions. Additional examinations will be performed on these elements up to a number equivalent to the number of elements required to be inspected on the segment or segments initially. If unacceptable flaws or relevant conditions are again found similar to the initial problem, the remaining elements identified as susceptible will be examined. No additional examinations will be performed if there are no additional elements identified as being susceptible to the same root cause conditions.

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3.5.2 Program Relief Requests An attempt has been made to select RI-ISI locations for examination such that a minimum of >90% coverage (i.e., Code Case N-460 criteria) is attainable.

However, some limitations will not be known until the examination is performed, since some locations may be examined for the first time by the specified techniques.

At this time, the RI-ISI examination locations that have been selected are estimated to exceed >90% coverage.

No existing Indian Point Unit 3 relief request is being withdrawn due to the RI-ISI application.

3.6 Risk Impact Assessment The RI-ISI program evaluation has been conducted in accordance with Regulatory Guide 1.174 and the requirements of EPRI TR-1 12657, and the risk from implementation of this program is expected to remain neutral or decrease when compared to that estimated from current requirements.

This evaluation identified the allocation of segments into High, Medium, and Low risk regions of the EPRI TR-1 12657 and ASME Code Case N-578 risk ranking matrix, and then determined for each of these risk classes what inspection changes are proposed for each of the locations in each segment. The changes include changing the number and location of inspections within the segment and in many cases improving the effectiveness of the inspection to account for the findings of the RI-ISI degradation mechanism assessment. For example, for locations subject to thermal fatigue, examinations will be conducted on an expanded volume and will be focused to enhance the probability of detection (POD) during the inspection process.

3.6.1 Qualitative Analysis Table 3.6-1 presents a summary of the proposed RI-ISI program versus the current Section Xl program.

Table 3.6-1 identifies on a per system basis:

"* the applicable risk category,

"* the number of locations,

"* the consequence rank and degradation mechanism which supports the risk category,

"* the number of locations inspected by the current section Xl program, Page 6 of 19

"* the number of locations proposed for the RI-ISI program, crediting where appropriate, inspections from the augmented inspection programs,

"* the increase, decrease or no change in the number of locations inspected.

This assessment does not credit inspections required by augmented inspection programs unless these inspections are also credited in the Section XI program

"* the risk impact (change in risk) of the RI-ISI program as compared to the Section XI program.

The final columns (CDF impact/LERF impact) of Table 3.6-1 provide a conclusion as to the impact on risk for the RI-ISI program as compared to the Section XI program. The following discussion explains the terms used in this column.

Forlocations identified as risk category 6 or 7:

Negligible as discussed in TR-1 12657 (section 3.7.1) the impact on risk of removing inspections from risk category 6 and 7 locations is negligible. Thus, the risk impact will be "Negligible" for category 6 and 7 locations, whenever there is a reduction in the number of locations inspected.

No Change When there is no change in the number of locations inspected (i.e.

the same before, as after), the risk impact will be "No Change."

Forlocations identified as risk category 1, 2, 3, 4 or 5.

No Change As with risk category 6 and 7 locations, when there is no change in the number of locations inspected (i.e. the same before, as after), the risk impact is classified as "No Change." This will be conservative when the RI-ISI inspection calls for a larger inspection volume with its accompanying increase in probability of detection.

Improvement When there is an increase in the number of locations being inspected, there is a resultant decrease in the risk associated with piping failure.

Thus, whenever the number of RI-ISI locations exceeds the number of Section XI locations inspected, "Improvement" will be found in the Risk Impact column. This conservatively does not credit the added benefit of increased inspection volumes for applicable degradation mechanisms (e.g. thermal fatigue).

Increase When there is a decrease in the number of locations being inspected, there is the potential for a resultant increase in the risk associated with piping failure. Thus, for locations not managed by an augmented inspection program, when the number of Section XI locations exceeds the number of RI-ISI locations inspected, "Increase" will be found in the Risk Impact column.

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As identified in Table 3.6-1, there is an overall increase of 18 inspection locations in the high risk region (i.e. Risk Categories 1, 2, and 3). Also, as identified in this table, there is an overall decrease of 9 locations in the medium risk region (i.e.

Risk Categories 4 and 5). Not crediting the benefit of increased inspections in the high risk region, there is a net increase of 9 inspection locations in the high and medium risk regions. This shows an overall decrease in the risk associated with implementing the RI-ISI program, which meets the requirements of TR 112657 and Reg. Guide 1.174. In addition, a separate quantitative evaluation was conducted consistent with TR-1 12657, section 3.7 and as expected, met TR 112657 and Reg Guide 1.174 quantitative criteria.

3.6.2 Defense-in-Depth The intent of the inspections mandated by ASME Section XI for piping welds is to identify conditions such as flaws or indications that may be precursors to leaks or ruptures in a system's pressure boundary. Currently, the process for picking inspection locations is based upon structural discontinuity and stress analysis results. As depicted in ASME White Paper 92-01-01 Rev. 1, "Evaluation of Inservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds," this method has been ineffective in identifying leaks or failures. EPRI TR-1 12657 and Code Case N-578 provide a more robust selection process founded on actual service experience with nuclear plant piping failure data.

This process has two key independent ingredients, that is, a determination of each location's susceptibility to degradation and secondly, an independent assessment of the consequence of the piping failure. These two ingredients assure defense in depth is maintained. First, by evaluating a location's susceptibility to degradation, the likelihood of finding flaws or indications that may be precursors to leaks or ruptures is increased. Secondly, the consequence assessment effort has a single failure criterion. As such, no matter how unlikely a failure scenario is, it is ranked High in the consequence assessment, and at worst Medium in the risk assessment (i.e., Risk Category 4), if as a result of the failure there is no mitigative equipment available to respond to the event. In addition, the consequence assessment takes into account equipment reliability, and less credit is given to less reliable equipment.

All locations within the reactor coolant pressure boundary will continue to receive a system pressure test and visual VT-2 examination as currently required by the Code regardless of its risk classification.

4. IMPLEMENTATION AND MONITORING PROGRAM Upon approval of the RI-ISI program, procedures that comply with the guidelines described in EPRI TR-1 12657 will be prepared to implement and monitor the program. The new program will be integrated into the third Inservice Inspection interval. No changes to the Updated Final Safety Analysis Report are necessary for program implementation.

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The applicable aspects of the ASME Code not affected by this change will be retained, such as inspection methods, acceptance guidelines, pressure testing, corrective measures, documentation requirements, and quality control requirements. Existing ASME Section Xl program implementing procedures will be retained and modified to address the RI-ISI process, as appropriate.

The monitoring and corrective action program will contain the following elements:

A. Identify B. Characterize C. (1) Evaluate, determine the cause and extent of the condition identified (2) Evaluate, develop a corrective action plan or plans D. Decide E. Implement F. Monitor G. Trend The RI-ISI program is a living program requiring feedback of new relevant information to ensure the appropriate identification of high safety significant piping locations. EPRI is currently working within the industry to develop guidelines for reviewing and updating risk-informed programs that have been generated per EPRI TR-1 12657. Once these guidelines are available, Indian Point Unit 3 will review them and implement applicable criteria. In addition, significant changes may require program adjustments as directed by NRC Bulletin or Generic Letter requirements, or by industry and plant specific feedback.

5. PROPOSED ISI PROGRAM PLAN CHANGE A comparison between the RI-ISI program and ASME Section Xl Code 1989 Edition, No Addenda program requirements for in-scope piping is provided in Tables 5-1 and 5-2. Table 5-1 provides a summary comparison by risk region. Table 5-2 provides the same comparison information, but in a more detailed manner by risk category, similar to the format used in Table 3.6-1.

Indian Point unit 3 is currently in the first period of its third Inservice Inspection interval. As such, 100% of the required RI-ISI program inspections will be completed in the third interval.

Examinations shall be performed during the interval such that the period examination percentage requirements of ASME Section Xl, paragraph IWB-2412 are met.

6. REFERENCES/DOCUMENTATION 6.1 Reference 6.1.1 EPRI TR-1 12657, "Revised Risk-Informed Inservice Inspection Evaluation Procedure", Rev. B-A 6.1.2 ASME Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method B,Section XI, Division 1" Page 9 of 19

6.1.3 Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant-Specific Changes to the Licensing Basis" 6.1.4 Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection of Piping" 6.2 Supporting Onsite Documentation 6.2.1 Memo PEP-GLS-2001-075, G. Smith to P. O'Regan, "IP3 Service History and Susceptibility Review for Risk Informed Inservice Inspection," July 9, 2001.

6.2.2 Report No. 17184-03, "RI-ISI Degradation Analysis for Indian Point Units 2 and 3.

6.2.3 Report No. 17184-01, "Consequence Evaluation of Class 1 Piping in Support of ASME Code Case N-578, Indian Point 3 Nuclear Power Plant" 6.2.4 Report No. 17184-05, "Segment Risk Ranking and Element Selection Results of Class 1 Piping In Support of ASME Code Case N-578, Indian Point 3 Nuclear Power Plant" 6.2.5 Report No. 17184-07, "RI-ISI Risk Impact Analysis for Indian Point Unit 3" 6.2.6 Memo to file, "Resolution of final IP3 RI-ISI comments",

6.2.7 Memo to file, R&R-17184-01-111 "Impact of updated IP3 IPE results on RI-ISI documentation" Page 10 of 19

Table 3.1-1 System Selection and Segment / Element Definition System Description ASME Code Class Number of Segments Number of Elements RC - Reactor Coolant System Class 1 53 260 CH - Chemical and Volume Control System Class 1 15 69 SI - Safety Injection System Class 1 60 282 AC - Auxiliary Cooling System (Residual Heat Removal) Class 1 3 20 Totals 131 631 Page 11 of 19

Table 3.3-1 Failure Potential Assessment Summary Thermal Fatigue Stress Corrosion Cracking Localized Corrosion Flow Sensitive TASCS TT iGSCC TGSCC ECSCC PWSCC MIC PIT CC E-C FAC RC X X CH X SI X X AC X Note

1. Systems are described in Table 3.1-1.

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Table 3.4-1 Number of Segments by Risk Category With and Without Impact of FAC(1 )

High Risk Region Medium Risk Region Low Risk Region System(2) Category I Category 2 Category 3 Category 4 Category 5 Category 6 Category 7 With Without With Without With Without With Without_[ With JWithout With Without With Without RC 12 12 35 35 1 1 1 1 4 4 CH 1 1 7 7 1 1 6 6 SI 21 21 11 11 12 12 16 16 AC 1 1 1 1 1 1 Total 35 35 54 54 14 14 24 24 4 4 Notes

1. The Flow Assisted Corrosion (FAC) Program is not applicable for Class 1 piping at the Indian Point Unit 3 Station. As such, the FAC Program has no impact on the figures shown in the table. The table format and reference to the FAC Program has been retained solely for uniformity purpose with other RI-ISI application template submittals.

2. Systems are described in Table 3.1-1.

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Table 3.5-1 Number of Elements Selected for Inspection by Risk Category Excluding Impact of FAC(1)

High Risk Region Medium Risk Region Low Risk Region System(2) Category 1 Category 2 Category 3 Category 4 Category 5 Category 6 Category 7 Total Selected Total Selected Total Selected Total] Seleted Total Selected Total Selected Total Selected RC 21 6 202 21 23 3 3 0 11 0 CH 3 1 49 5 3 1 14 0 SI 57 15 31 4 44 5 150 0 AC 5 2 2 1 13 0 Total 86 24 284 31 70 9 180 0 11 0 Notes

1. The Flow Assisted Corrosion (FAC) Program is not applicable for Class 1 piping at the Indian Point Unit 3 Station. As such, the FAC Program has no impact on the figures shown in the table. The reference to the FAC Program has been retained solely for uniformity purpose with other RI-ISI application template submittals.

2. Systems are described in Table 3.1-1.

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Table 3.6-1 Risk Impact Analysis Results Syste Ca Consequence Failure Potential Inspections CDF Impact(3) LERF Impact(3)

StRank DMs Rank Section XI(2) RI-ISI Delta w/POD W/o POD w/POD wlo POD RC 2 High TASCS, TT Medium 1 2 +1 Improvement Improvement RC 2 High TASCS Medium 2 3 +1 Improvement Improvement RC 2 High TT Medium 2 1 -1 Increase Increase RC 4 High None Low 41 21 -20 Increase Increase RC 5 Medium TASCS Medium 0 3 +3 Improvement Improvement RC 6 Medium None Low 0 0 0 no change no change RC 7 Low None Low 0 0 0 no change no change RC Total 46 30 -16 CH 2 High TASCS Medium 0 1 +1 Improvement Improvement CH 4 High None Low 0 5 +5 Improvement Improvement CH 5 Medium TASCS Medium 0 1 +1 Improvement Improvement CH 6 Medium None Low 0 0 0 no change no change CH Total 0 7 +7 SI 2 High TASCS Medium 0 1 +1 Improvement Improvement SI 2 High TASCS, IGSCC Medium 0 3 +3 Improvement Improvement SI 2 High IGSCC Medium 1 11 +10 Improvement Improvement SI 4 High None Low 1 4 +3 Improvement Improvement SI 5 Medium IGSCC Medium 6 5 -1 Increase Increase SI 6 Medium None Low 9 0 -9 negligible negligible Sl Total 17 24 +7 Page 15 of 19

Table 3.6-1 Risk Impact Analysis Results Inspections CDF Impact(3) LERF Impact(3 )

System(1) Category Consequence Failure Potential Ran DIVs Rank Section Xl) RI-ISl Delta w/ POD W/o POD w/ POD w/o POD AC 2 High TASCS Medium 0 2 +2 Improvement Improvement AC 4 High None Low 1 1 0 no change no change AC 6 Medium None Low 5 0 -5 Negligible Negligible AC Total 6 3 -3 Grand Total 69 64 -5 Notes

1. Systems are described in Table 3.1-1.

2. Only those ASME Section XI Code inspection locations that received a volumetric examination in addition to a surface examination are included in this count. Inspection locations previously subjected to a surface examination only are not considered in accordance with Section 3.7.1 of EPRI TR-1 12657.

3. Per Section 3.7.1 of EPRI TR-1 12657, the contribution of low risk categories 6 and 7 need not be considered in assessing the change in risk. Hence, the word "negligible" is given in these cases in lieu of values for CDF and LERF Impact. In those cases where no inspections were being performed previously via Section XI, and none are planned for RI-ISI purposes, "no change" is listed instead of "negligible".

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Table 5-1 Inspection Location Selection Comparison Between ASME Section XI Code, 1989 Edition and EPRI TR-112657 by Risk Region High Risk Region Medium Risk Region Low Risk Region Syste() Categor) ASME SectionXI EPRI TR-112657 Weld ASME SectionXI EPRI TR-1126C7 W ASuE S rectionyXI EPRI TR-112657 ICount Vol/Sur Sur Only RI-ISl I Other(3) Count Vol/Sur SurOnly RI-ISI f Other(3) Count Vol/Sur ISurOnly RI-ISI IOther(3)

RC B-F 2 2 0 1 20 20 0 8 B-J 19 3 2 5 205 21 29 16 14 0 0 0 CH B-J 3 0 0 1 52 0 13 6 14 0 6 0 SI B-J 57 1 3 15 75 7 8 9 150 9 48 0 AC B-J 5 0 0 2 2 1 0 1 13 5 0 0 B-F 2 2 0 1 20 20 0 8 Total B-J 84 84 4 4 55 23 23 3 334 2014 29 50 32 191 14 554 0 Notes

1. Systems are described in Table 3.1-1.

2. The ASME Code Category is based on the 1989 Edition, No Addenda of the ASME Section XI Code.

3. The column labeled "Other" is generally used to identify augmented inspection program locations that are credited beyond those locations selected per the RI-ISI process, as addressed in Section 3.6.5 of EPRI TR-112657. This option was not applicable for the Indian Point Unit 3RI-ISl application. The "Other" column has been retained in this table solely for uniformity purposes with other RI-ISI application template submittals.

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Table 5-2 Inspection Location Selection Comparison Between ASME Section XI Code, 1989 Edition and EPRI TR-112657 by Risk Category I I I I I Risk Consequence Failure Potential Code Weld ASME Section Xl EPRI TR-112657 System(1)

Category Rank Rank Category Count DMs Rank Vol/Sur ISur OniI RI-ISI RC 2 High High TASCS, TT Medium B-J 5 1 0 2 B-F 1 1 0 0 RC 2 High High TASCS Medium B-J 13 1 2 3 B-F 1 1 0 1 RC 2 High High TT Medium B-J 1 1 0 0 B-F 20 20 0 8 RC 4 Medium High None Low B-J 182 21 29 13 RC 5 Medium Medium TASCS Medium B-J 23 0 0 3 RC 6 Low Medium None Low B-J 3 0 0 0 RC 7 Low Low None Low B-J 11 0 0 0 CH 2 High High TASCS Medium B-J 3 0 0 1 CH 4 Medium High None Low B-IJ 49 0 13 5 CH 5 Medium Medium TASCS Medium B-J 3 0 0 1 CH 6 Low Low TT Medium 8-J 14 0 6 0 SI 2 High High TASCS Medium B-J 10 0 0 1 SI 2 High High TASCS. IGSCC Medium B-J 27 0 1 3 SI 2 High High IGSCC MEDIUM B-J 20 1 2 11 SI 4 Medium High None Low B-J 31 1 2 4 SI 5 Medium Medium IGSCC Medium B-J 44 6 6 5 SI 6 Low Medium None Low B-J 150 9 48 0 Page 18 of 19

Table 5-2 Inspection Location Selection Comparison Between ASME Section XI Code, 1989 Edition and EPRI TR-112657 by Risk Category Risk Consequence Failure Potential Code Weld ASME Section Xl EPRI TR-112657 Category Rank Rank DMs Rank Category Count Vol/Sur Sur Only RI-ISI Other(2 )

AC 2 High High TASCS Medium B-J 5 0 0 2 AC 4 Medium High None Low B-J 2 1 0 1 AC 6 Low Medium None Low B-J 13 5 0 0 Notes

1. Systems are described in Table 3.1-1.

2. The column labeled "Other" is generally used to identify augmented inspection program locations that are credited beyond those locations selected per the RI-ISI process, as addressed in Section 3.6.5 of EPRI TR-1 12657. This option was not applicable for the Indian Point Unit 3RI-ISl application. The "Other" column has been retained in this table solely for uniformity purposes with other RI-ISI application template submittals.

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