L-09-138, License Renewal Application, Amendment No. 36

License Renewal Application, Amendment No. 36

ML091380033
Person / Time
Site:	Beaver Valley
Issue date:	05/14/2009
From:	Sena P FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-09-138, TAC MD6593, TAC MD6594
Download: ML091380033 (22)

Text

FENOC Beaver Valley Power Station P.O. Box 4 FirstEnergyNuclear Operating Company ppgp, PA 15077 Peter P. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 May 14, 2009 L-09-138 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 License Renewal Application (TAC Nos. MD6593 and MD6594)Amendment No. 36 Reference 1 provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS). Reference 2 provided the U.S. Nuclear Regulatory Commission's (NRC) Safety Evaluation Report (SER) With Open Item Related to the License Renewal of Beaver Valley Power Station, Units 1 and 2. Reference 3 amended the LRA regarding the Inaccessible Medium-Voltage Cables and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. Reference 4 amended the LRA regarding the SER open item.

During a conference call between FENOC and the U.S. Nuclear Regulatory Commission (NRC) on May 5, 2009, the NRC staff requested that FENOC change the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program from a plant-specific program to a program consistent with NUREG-1801, and change the associated future license renewal commitments made in Reference 4.

The Enclosure provides Amendment No. 36 to the BVPS License Renewal Application.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-09-138 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on May __, 2009.

Sincerely Peter P. Sena III

References:

1. FENOC Letter L-07-113, "License Renewal Application," August 27, 2007.

2. NRC Letter, "Safety Evaluation Report with Open Item Related to the License Renewal of Beaver Valley Power Station, Units 1 and 2," January 9, 2009.

3. FENOC Letter L-08-262, "License Renewal Application Amendment No. 23 (TAC Nos. MD6593 and MD6594) and Revised License Renewal Boundary Drawings,"

September 8, 2008.

4. FENOC Letter L-09-057, "Reply to Request for Additional Information for the Review of the Beaver Valley Power Station. Units 1 and 2, License Renewal Application (TAC Nos. MD6593 and MD6594), and License Renewal Application Amendment No. 35," March 24, 2009.

Enclosures:

Amendment No. 36 to the BVPS License Renewal Application cc: Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc: w/o Attachment or Enclosures Mr. B. E. Holian, NRC DLR Director Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRC DORL Project Manager Mr. D. J. Allard, PA BRP/DEP Director Mr. L. E. Ryan, PA BRP/DEP

ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-09-138 Amendment No. 36 to the BVPS License Renewal Application Page 1 of 20 License Renewal Application Sections Affected Section 3.6.2.1 Table 3.6.1 Table 3.6.2.1 Section A.1.21 Table A.4-1 Table A.5-1 Table B.1-1 Table B.1-2 Table B.1-3 Section B.2.21 Appendix A Table of Contents Appendix B Table of Contents The Enclosure identifies the correction by Affected License Renewal Application (LRA)

Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text lined eut and added text underlined.

Enclosure L-09-1 38 Page 2 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section 3.6.2.1 Page 3.6-3 Aging Management Programs 5 th Bullet LRA Section 3.6.2.1, "Materials, Environment, Aging Effects Requiring Management and Aging Management Programs," subsection "Aging Management Programs," 5 th bullet, requires revision of the title of the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, which is being changed from a plant-specific program to a program consistent with NUREG-1801, "Generic Aging Lessons Learned (GALL),"Section XI.E3 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Section 3.6.2.1, subsection "Aging Management Programs," 5th bullet, is revised to read:

, Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Section B.2.21)

Enclosure L-09-138 Page 3 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.6.1 Page 3.6-10 Item No. 3.6.1-04 Discussion column LRA Table 3.6.1, "Summary of Aging Management Evaluations in Chapter VI of NUREG-1801 for Electrical and Instrumentation and Controls Components," Item No. 3.6.1-04, "Discussion" column, requires revision of the title of the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, which is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Table 3.6.1, Item No. 3.6.1-04, "Discussion" column, is revised to read:

Item Number Discussion -

3.6.1-04 Consistent with NUREG-1801.

B VPS will manage the aging effects with the Inaccessible Medium-Voltage Cables Not Subiect to 10 CFR 50.49 Environmental QualificationRequirements (B.2.21) Program.

No aging effect requiring m~anagement has beep identifed.

Howevern, these GOm~penents have been conscr-vativcy 4neludec in the BVPS plant spe'fiG !naGecSSibio Medium Voltage Cabe Suitable for-Submer-gencre anPd- ANot Su4bleet to IOCFR50.49 Environmental Q-a!igation Rquirements (B.2.24)Program.

This program includes testing and inspections of medium-voltage cables exposed to significant moisture and voltage.

In Table 3.6.2-1, reduced insulation resistance is considered equivalent to the aging effect listed for this item (breakdown of insulation).

Enclosure L-09-138 Page 4 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.6.2-1 Page 3.6-16 Row No. 4 Page 3.6-20 New Plant-specific Note (Note 602)

LRA Table 3.6.2-1, "Electrical and Instrumentation and Controls Components - Summary of Aging Management Evaluation," Row No. 4 and the "Plant-specific notes", require revision of the title of the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CER 50.49 Environmental Qualification Requirements Program, which is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Table 3.6.2.1, Row No. 4 is revised and "Plant-specific notes", Note 602 is removed:

Agn fetNUREG-Row Component Intended Aging Effect AgnMagentNR-TblI Material Environment Requiring Aging Management 1801 Table 1 Notes No. Type Function Management Program Volume 2 Item Item 4 Inaccessible CE Insulation Adverse Reduced Inaccessible VI.A-4 3.6.1-04 A medium-voltage material.- localized insulation Medium-Voltage (L-03)

(2kV to 35kV) various environment resistance Cables S'itable-fer -4 cables (e.g., organic caused by Submrgenc. and 602 installed polymers exposure to Nen Not Subject to 10 underground in moisture and CFR 50.49.

conduit or direct voltage Environmental buried) not stress Qualification subject to Requirements 10 CFR 50.49 (B.2.21)

EQ requirements f

Enclosure L-09-138 Page 5 of 20 Plant-specific notes 602. Based on a 2003 engineering evaluation, FENO oen firmedl that a#1 inaces;ibh mopdiur VAUPPn PAWAQh w4ithin thP scope of the Appendix B, 1na ce~S sibll Medium Voltage Cables Suitable for S*b Fnermen-ee and Not Sub1ect to 410FR 50.49 Envnirnmental Qu lft-oation Requiremnts Programq (B.2.21) are suitable mr-

.... nnnr~gtinn

/.. ............ ;n a' su!hngmnref f enviroenment. There fore, no aging effect requl ring management was identifed for-these Gables.

Enclosure L-09-138 Page 6 of 20 Affected Paragraph Affected LRA Section- LRA Page No. and Sentence Section A.1.21 Page A.1-9 Entire Section LRA Section A.1.21, "Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program," requires revision of the entire section, because the program is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure).

LRA Section A.1.21 is revised to read:

A. 1.21 Inaccessible Medium-Voltage Cables Sumita6*b-le far Submcrgcnce and Not Subject to 10 CFR 50.49 EnvironmentalQualificationRequirements Program The Inaccessible Medium-Voltage CablesStbf Submer'genGe and Not Subject to 10 CFR 50.49 Environmental QualificationRequirements Programis a new plant , pecifi, pr.ogram that BVPS will ,mplement pro to the pci.d of exten d operation. demonstrates that inaccessible,non-EQ medium-voltage cables, susceptible to aging effects caused by moisture and voltage stress, are managed such that there is reasonable assurancethat the cables will perform their intended function in accordancewith the current licensing basis during the period of extended operation.

The inaccessible mqedium voltage Gables not subj~ect to 10 CFR 50.49 enviroenmental qualifiatiequ ts and wihin f this pro-,gram are suitable for sub.mergePGe and thre Fore, Pgn aging-9. ef*f*t requiring management was idipentifi for these cables.

The pup*ose

, f this agig agem t program wil be to confirm that the aging effects gaused by moi~sture and voltage sltresqs ar.e nOt O G14R44gso0that he ~e is.reasonable assuran~e that the cables will perForm ther intended function in accordance ... ith the- current hipensing bas's durn the period of extended operation. in scope medium voltage cables wil be tested to proevide an indication of the conditin Of the cond' A~rto 3sulation. in this aging management progqram, periodic actions are taken, at least once every two (2) years, to minimize cable exposure to significant moisture, such as inspecting for water collection in cable manholes, and draining.

water, as needed. In-scope, medium-voltage cables exposed to significant moisture and significant voltage are tested to provide an indication of the condition of the conductor insulation.

The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or other testing that is state-of-the-art at the time the test is performed.

Testing w#1-be is conducted at least once every ten (10) years, with initialtesting completed prior to the period of extended operation.Also, periodic visual inspections wilbe are performed on the accessible portions of cables (i.e., in manholes) for water induced damage. These inspections wl-be are performed at least-once every two (2) years, with the first inspection te-be completed priorto the period of extended operation.

Enclosure L-09-138 Page 7 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.4-1 Page A.4-5 Item No. 11 LRA Table A.4-1, "Unit 1 License Renewal Commitments," Item No. 11 regarding inaccessible medium-voltage cables, requires revision. The program is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure).

Therefore, the license renewal future commitment is replaced with a commitment to the new.program consistent with NUREG-1801. Item No. 11 in LRA Table A.4-1 is revised to read:

Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments 11 Implement the Inaccessible Medium- January 29, LRA; A. 1.21 Voltage Cables Suitable-fer 2016 B.2.21 Sub**.e.g.ne and Not Subject to 10 FENOC CFR 50.49 Environmental Letter QualificationRequirements Program L-08-262; as described in LRA Section B.2.21.

FENOC BVPS commits to implement one of Letter the following prior to entering the L-09-057; period of extended operation:

1. Adopt an acceptable FENOC Letter methodology that Letter demonstrates that the in- L-09-138 scope, continuously submerged, inaccessible, medium-voltage cables will continue to perform their intended function during the period of extended operation, or;

2. Implement measures to minimize cable exposure to s4gnificant moisture through dewaterinq manholes.

Incorporateoperating experience obtained from dewaterinq and adjust the dewatering frequency to

Enclosure L-09-138 Page 8 of 20 minimize cable exposure to significant moisture leng te submergen , or;

3. Replace the in-scope, continuously submerged medium-voltage cables with cables desiqned for submerged service.

Enclosure -

L-09-138 Page 9 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.5-1 Page A.5-5 Item No. 12 LRA Table A.5-1, "Unit 2 License Renewal Commitments," Item No. 12 regarding inaccessible medium-voltage cables, requires revision. The program is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). Therefore, the license renewal future commitment is replaced with a commitment to the new program consistent with NUREG-1801. Item No. 12 in LRA Table A.5-1 is revised to read:

Item ImplementationRead Related LRA A

Commitment Source Section No./

Number Schedule Comments 12 Implement the Inaccessible Medium- May 27, 2027 LRA; A.1.21 Voltage Cables Riptahle-fer B.2.21 Submergence and Not Subject to 10 FENOC CFR 50.49 Environmental Letter QualificationRequirements Program L-08-262; as described in LRA Section B.2.21.

FENOC BVPS commits to implement one of Letter the following prior to entering the L-09-057; period of extended operation:

1. Adopt an acceptable FENOC methodology that Letter demonstrates that the in- L-09-138 scope, continuously submerged, inaccessible, medium-voltage cables will continue to perform their intended function during the period of extended operation, or;

2. Implement measures to minimize cable.exposure to significant moisture through dewaterinq manholes.

Incorporateoperating experience obtained from dewatering and adiust the

_ _dewatering frequency to

Enclosure L-09-138 Page 10 of 20 minimize cable exposure to significant moisture -ln te

&sbmeFgene, or;

3. Replace the in-scope, continuously submerged medium-voltage cables with cables desiqned for submerged service.

Enclosure L-09-138 Page 11 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-1 Page B.1-6 8 th Row LRA Table B.1-1, "BVPS Aging Management Programs," 8 th row on page B. 1-6, requires revision of the title of the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, which is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Table B.1-1, 8 th row on page B.1-6, is revised to read:

Aging Management Program Title LRA Section Status InaccessibleMedium-Voltage Cables &4tabie e B.2.21 New Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements

Enclosure L-09-138 Page 12 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-2 Page B.1-12 NUREG-1801 No. XI.E3; and Plant-Specific Programs LRA Table B.1-2, "BVPS Aging Management Program Correlation to NUREG-1801 Aging Management Programs," requires revision because the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is being changed from a plant-specific program to a program consistent with NUREG-1 801 (see the revision to LRA Section B.2.21 in this Enclosure).

LRA Table B.1-2 is revised to read:

NUREG- LRA 1801 NUREG-1801 Program BVPS Program Section Number XI.E3 Inaccessible Medium-Voltage Not credited for aging B.2.21 Cables Not Subject to management. See plant Spe.. -

10CFR50.49 Environmental Inaccessible Medium-Voltage Qualification Requirements Cables Suitable for S,,bme.gen..

and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program-.

Plant-Specific Programs NA Plant Specifi Program Inacessible Medium Voltage 84-24:2 Cables Suitabie for Submergence and Not Subjoct to 103FR 50.4" Environmental Quaflfication

Enclosure L-09-138 Page 13 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-3 Page B.1-15 2 nd Row LRA Table B. 1-3, "BVPS Aging Management Program Consistency with NUREG-1 801 Aging Management Programs," 2 ndrow on page B.1-15, requires revision because the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Table B.1-3, 2 nd row on page B. 1-15, is revised to read:

NUREG-1801 Comparison Programs Plant- Consistent Programs with Programs with Program Name with Enhancement(s) Exception(s) to NUREG- NUREG-1801 1801 Inaccessible Medium-Voltage --

Cables S'itabel fe -Yes Yes Sub"*e.gence an Not Subject to 10 CFR 50.49 Environmental Qualification Requirements

Enclosure L-09-138 Page 14 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section B.2.21 Pages B.2-58 Entire Section through B.2-61 LRA Section B.2.21, "Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," requires revision of the entire section, because, the program is being changed from a new plant-specific program to a new program consistent with NUREG-1801. LRA Section B.2.21 is revised to read:

B.2.21 Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Program Description The Inaccessible Medium-Voltage Cables Suitable fo. SubmergeGe and Not Subject to 10 CFR 50.49 Environmental QualificationRequirements Programis a new plan-tspeGfi program that B VPS will implement prior to the period of extended operation.

The purpose of this aging management program will be to demonstrate that inaccessible,non-EQ medium-voltage cables, susceptible to aging effects caused by moisture and voltage stress, will be managed such that there is reasonableassurancethat the cables will perform their intended function in accordance with the current licensing basis durinq the period of extended operation.

The i*a*cessible meditum veftage cable- not subjeGt th 10 GFR 50.49nenvronmental quapificatin require ents and ithin the scope ef this program ate suitable for-submertone and therfefore, no aging effect rnsuiring maa gment wac identiced for-thesae Gables.

The purpese of this agin maPoent pro9gram wil be to confirm that the aging effec-ts caui sed Mast'

,by ;Pded I aet voltage occurrpg so that thee is reasfnablen atress surae a scabe veolrm their intended function in a rdatio of the urrent hecongdo basiS 'ri't the periofd eof tended operation. inscope medium voltage cables Will be tested to provide an indication Of theson ditioteon of the conductor insulation. In this aging management program, periodicactions are taken, at leastonce every two (2) years, to minimize cable exposure to significant moisture, such as inspecting for water collection in cable manholes, and drainin water, as needed. In-scope, medium-volta-ge cables exposed to significant moisture and significant volta-ge are tested to provide an indication of the condition of the conductor insulation.

The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or other testing that is state-of-the-art at the time the test is performed.

Testing will be conducted at least once every ten (10) years, with initial testing completed prior to the period of extended operation. Also, periodic visual inspections will be performed on the

Enclosure L-09-138 Page 15 of 20 accessible portions of cables (i.e., in manholes) for water induced damage. These inspections will be performed at least once every two (2) years, with the first inspection to be completed prior to the period of extended operation.

NUREG-1801 Consistency The Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program that is consistent with NUREG-1801,Section XI.E3, Inaccessible Medium-Voltage Cables Not Sub/ect to 10 CFR 50.49 Environmental QualificationRequirements.

Exceptions to NUREG-1801 None Enhancements None Aging Management Program Elements The results of an evaluation of each of the 10 aging management program elements described in NUREG 1800 [Ref renGe 1.3 4, Appendix A, NUREG-1801,Section XI.E3, are provided as follows:

• Scope of Program The program is applicable to inaccessible,non- EQ medium-voltage cablessuitablefe m Gee that support a license renewal intended function and are exposed to significant moisture simultaneously with significant voltage.

The program defines "significant moisture" as periodic exposure to moisture that lasts more than a few days (e.g., cable in standing water). Periodic exposure to moisture, which lasts less than a few days (i.e., normal rain and drain) is not significant.

The program defines "significant voltage" as being subject to system voltage for more than twenty-five percent (25%) of the time, The moisture and voltage exposures described as significant in these definitions, which are based on operating experience and engineeringjudgment, are not significant for medium-voltage cables that are su#able desiqned for these conditions (i.e., submarine cables). -The frV.DSrin scope nmediumg voltage Gables have boen determined to be srhitablo for subm*rgencc; thcrcforge, no aging effe~t Feq"~ng magmnt was identified qfothese Gables.

Enclosure L-09-138 Page 16 of 20 Preventive Actions This program includes periodic actions to minimize cable exposure to significant moisture. The program identifies the applicable manholes and will require inspection of these manholes at least once every two (2) years to inspect for water collection in cable manholes, and drainingof water as needed. . a . ,on.dit.on monitorig pr.g.am w"hich wilW onfirm bG,, inspet.g a..d testing that aging effccts arc not Occumng,- thoro fore, no actions are taken as pad of this proGgram to prevent or mitigate aging degradation.

- Parameters Monitored/Inspected The cables will be tested to provide indicationsOf !Go -*ized damnage and breakdo"n of insulation leadingto e 'ia' fa... due to meistu.. iptr.sio., water- troes. an indication of the condition of the conductorinsulation. The program allows that the specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deteriorationof the insulation system due to wetting, such as power factor,partialdischarge, as described in EPRI guidance documents, or other testing that is state-of-the- art at the time the test is performed.

Through manhole inspections, accessible portions of cables will be inspected for visual indications of water induced damage.

- Detection of Aging Effects Testing of the cables will be performed at least once every ten (10) years, with the first test to be completed prior to the period of extended operation. This is an adequateperiod to preclude failures of the conductor insulation since experience has shown that aging degradation is a slow process. A ten (10) year testing interval will provide two data points during a twenty (20) year period, which can be used to characterizethe degradationrate. This testing will provide an indication of the condgitin Of the cond~uctor-4nsuiation. The specifi type of test to be perfor~ed will be frtMirId prirFt* the ft'I test,and is t be a rt/t t fpofr-rfpr detecting deteFrioratin ot the insulation y*tefm rdue to wett"ng', SUch as power-fatorr,partial diacharge, as describel in EP-Ri guidance documents., or other-testing that is state of the art at the time the test i pe~fem~ec Through manhole inspections, accessible portions of the cables will be visually inspected at least once every two (2) years, with the first inspection to be completed prior to the period of extended operation. This inspection will identify visual indications of water induced damage.

Water identified in the applicable manholes will be drained at the time of inspection to facilitate visual inspection of the cables.

The program identifies the applicable manholes and will require inspection of these manholes at least once every two (2) years. The inspection frequency will be based on actual plant experience with water accumulation in the manhole, with the first inspection to be completed priorto the period of extended operation.

Enclosure L-09-138 Page 17 of 20

- Monitoring and Trending Trending actions are not included as part of this program because the ability to trend results is dependent on the specific type of test chosen. However, all test and inspection results will be maintained as part of plant records. Therefore, these results are available for review and/or trending during subsequent tests and inspections as needed.

- Acceptance Criteria Testing acceptance criteria will be defined by the specific type of test performed and the specific cable tested.

Visual inspection acceptance criteria will provide that the accessible portions of the cables are to be free from visual indications of surface anomalies.

- Corrective Actions The program will require that unacceptable cable test/inspection results are to be documented in the BVPS Corrective Action Program. Any subsequent engineering evaluations and extent-of-condition determinations are conducted according to the Corrective Action Program.

This element is discussed further in Section B.1.3.

- Confirmation Process This element is discussed further in Section B.1.3.

- Administrative Controls This element is discussed further in Section B.1.3.

- Operating Experience The Inaccessible Medium-Voltage Cables Suitable for Submerngence and Not Subject to 10 CFR 50.49 Environmental QualificationRequirements Programis a new plan peGifi Beaver Valley Power Station aging management program for which there is no plant-specific operating experience for program effectiveness.

Industry operating experience that forms the basis for the program, as described in the operating experience element of the NUREG- 1801,Section XI. E3 program description, B VPS plant-specific operating experience is consistent with the operating experience element of the NUREG-1801,Section XI.E3 program description. Industry and plant-specific operating experience will be considered in the development and implementation of this program. As additional operating experience is obtained, lessons learned will be appropriately incorporated into the program.

Enclosure L-09-138 Page 18 of 20 BVPS currently has a manhole inspection procedure, which provides for the identification of water induced damage to cables and cable supports contained in manholes. The BVPS manhole inspection procedure was performed in 2008. The results of the procedure are documented in the Corrective Action Program. The findings included missing seals, cracked walls, corroded supports, and water intrusion. No cable damage was found. The associated work order indentifies varying amounts of water in in-scope manholes, with some in-scope manholes having water levels above the cable level.

A20-08 engnerig aluation has con firmed that in scope mqedium voltage cables arc suitabe for operation. in sub-gmerged environmgents. The inspection frequency of at le6a-st onc~e ever-y to (2ý) yea rs w" pro vide rcasonabie assurance that the cables wil pe~form thei intnde h4fR untion Gu....nt Acnsing basi~s during the period or ete.ndedoperation-.

0n accoG3rdance 14thi -thP-In the response to NRC Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients," FENOC reported that BVPS has not experienced failure of inaccessible or underground power cables within the scope of 10 CFR 50.65.

The lack of cable failures and the lack of cable degradation support the cable testing frequency of at least once every ten (10) years.

Conclusion The implementation of the Inaccessible Medium-Voltage Cables Su÷witable for Subm.ergence an Not Subject to 10 CFR 50.49 Environmental QualificationRequirements Program will provide reasonableassurancethat the aging effects will be managed so that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Enclosure L-09-138 Page 19 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Appendix A Page A-ii Table of Contents, Item A.1.21 LRA Appendix A, "Updated Final Safety Analysis Supplement," Table of Contents item A. 1.21, requires revision of the title of the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, which is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Appendix A, Table of Contents item A.1.21, is revised to read:

A. 1.21 Inaccessible Medium-Voltage Cables Sutable-fer Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ................... A. 1-9

Enclosure L-09-138 Page 20 of 20 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Appendix B Page B-iv Table of Contents, Item B.2.21 LRA Appendix B, "Aging Management Programs and Activities," Table of Contents item B.2.21, requires revision of the title of the Inaccessible Medium-Voltage Cables Suitable for Submergence and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, which is being changed from a plant-specific program to a program consistent with NUREG-1801 (see the revision to LRA Section B.2.21 in this Enclosure). LRA Appendix B, Table of Contents item B.2.21, is revised to read:

B.2.21 Inaccessible Medium-Voltage Cables Suitable-fe Submergence and Not Subject to 10 CFR 50.49 Environmental QualificationRequirements ........................... B.2-58