L-11-134, Reply to Request for Additional Information for the Review of License Renewal Application, Batch 1 and License Renewal Application Amendment No. 6

Reply to Request for Additional Information for the Review of License Renewal Application, Batch 1 and License Renewal Application Amendment No. 6

ML11131A073
Person / Time
Site:	Davis Besse
Issue date:	05/05/2011
From:	Allen B FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-134, TAC ME4640
Download: ML11131A073 (51)

Text

FENOC "5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor,Ohio 43449 Barry S. Allen 419-321-7676 Vice President- Nuclear Fax: 419-321-7582 May 5, 2011 L-11-134 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Batch 1 (TAC No. ME4640) and License Renewal Application Amendment No. 6 By letter dated August 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1. By letter dated April 5, 2011 (ADAMS Accession No. ML110820490), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).

The Attachment provides the FENOC reply to 19 of the 41 NRC requests for additional information. For those 19, the NRC request is shown in bold text followed by the FENOC response. The remaining 22 requests (B.2.22-1, B.2.22-2, B.2.22-3, B.2.22-4, B.2.23-1, B.2.25-1, B.2.25-2, B.2.25-3, B.2.25-4, B.2.25-5, B.2.25-6, B.2.27-1, B.2.39-1, B.2.39-2, B.2.39-3, B.2.39-4, B.2.39-5, B.2.39-6, B.2.39-7, B.2.39-8, B.2.40-1 and XI.$8-1)were discussed with Mr. Brian Harris, NRC Project Manager, and the responses to these requests are deferred to a mutually-agreeable submittal date of April 20, 2011.

The Enclosure provides Amendment No. 6 to the DBNPS LRA.

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.

Davis-Besse Nuclear Power Station, Unit No. 1 L-11-134 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on May 5 ,2011.

Sincerely, Barry;S7.Zen

Attachment:

Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Batch 1, Sections 3.6 and B.2

Enclosure:

Amendment No. 6 to the DBNPS License Renewal Application cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Attachment L-11-134 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Batch 1, Sections 3.6 and B.2 Page 1 of 22 Section 3.6 Question RAI 3.6-1 In LRA Table 3.6-1, item 3.6.1-09, metal enclosed bus-enclosure assemblies, the applicant stated that loss of material due to general corrosion is not applicable to DBNPS because there is no metal enclosed bus within the scope of license renewal. During a plant walkdown, the staff reviewed the station blackout recovery path and noted that cable buses are used to connect bus tie transformers and the 4160 V essential switchgear buses. The applicant indicated to the staff that these cable buses were not subject to an AMP because they are not located in an adverse localized environment. The staff agreed with the applicant that these cable buses are not required to have an AMP because GALL Report (NUREG-1801, Revision 2)Section VI does not recommend aging management for cable in air indoor or outdoor environment. However, the cable buses are protected by enclosure assemblies. These assemblies are made from galvanized steel material.

Galvanized steel material in air outdoor or air indoor uncontrolled environment could be subject to loss of material due to general, pitting, and crevice corrosion.

Explain how aging of cable bus enclosure assemblies (including support structures) will be managed during the PEO.

RESPONSE RAI 3.6-1 Per the Davis-Besse 4160V cable bus specification, the 4160V essential switchgear cable bus enclosure material is aluminum. The material type of aluminum was confirmed by independent walkdown on May 1, 2011. As shown in License Renewal Application (LRA) Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities," row 50, "Electrical Cable Bus Ducts," aging effects for the cable bus enclosure assemblies, which includes associated support structures, will be managed by the Structures Monitoring Program.

Attachment L-11-134 Page 2 of 22 Question RAI 3.6-2 In LRA Section 3.6.2.2.2, the applicant stated that industry experience has shown that transmission conductors do not normally swing unless subjected to a substantial wind, and they stop swinging shortly after the wind subsides.

The applicant further stated that wind loading that can result in conductor sway is considered in the transmission system design. The applicant then concluded that loss of material due to mechanical wear is not an aging effect requiring management for the high voltage insulators and transmission conductors at DBNPS.

SRP Section 3.6.2.2 2 states that loss of material due to mechanical wear caused by wind blowing on transmission conductors could occur in high-voltage insulators. The applicant did not address plant-specific operating experience with high-voltage insulator and transmission conductor loss of material due to wear.

Review plant-specific operating experience and provide justification to confirm that wear has not occurred in high-voltage insulators and transmission conductors installed at DBNPS.

RESPONSE RAI 3.6-2 FirstEnergy Nuclear Operating Company (FENOC) conducted a review of the Davis-Besse plant-specific operating experience for License Renewal. The results of this review did not identify any instances of wear in high-voltage insulators and transmission conductors installed at Davis-Besse.

Question RAI 3.6-3 In LRA Section 3.6.2.2.3, the applicant stated that galvanized and aluminum bolted connections are exposed to the same service conditions as the plant switchyard and do not experience any aging effects, except for minor oxidation of the exterior surfaces, which does not impact their ability to perform their intended function.

Aluminum and galvanized connections are highly conductive but do not make a good contact surface since aluminum and galvanized steel exposed to air forms oxides on the inside surface which is nonconductive and could increase the resistance of connections. SRP (NUREG-1800, Revision 2) Section 3.6.2.2.3 states that increased resistance of connection due to oxidation in transmission conductors and connections, and switchyard bus and connections could occur.

The SRP recommends a plant-specific program for management of increase

Attachment L-11-134 Page 3 of 22 resistance due to oxidation for transmission conductor and switchyard bus connections.

Explain why increase resistance of connections (galvanized and aluminum bolted connections) is not an aging effect requiring management and why an AMP is not needed.

RESPONSE RAI 3.6-3 LRA Section B.2.1 1, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection," is revised to enhance the program to include high-voltage connections to confirm the absence of aging effects for the metallic electrical connections.

LRA Appendix A, "Updated Safety Analysis Report Supplement," Table A-1, "Davis-Besse License Renewal Commitments," is revised to include the B.2.11 program enhancement as a new license renewal future commitment.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Section B.2 Question RAI B.2.1-1 License renewal application (LRA) Section B.2.1 states that this is an existing program that is consistent with the Generic Aging Lessons Learned (GALL)

Report aging management program (AMP) XI.S4. Element 5, "detection of aging effects," in GALL AMP Xl.S4 recommends for the implementation of periodic in-service examinations for the containment structures by applying the requirements of subsections in ASME Section XI. The associated Subsection IWE-3510.1 of ASME Section Xl (1995) Code states, "The general Visual Examination shall be performed by, or under the direction of, a Registered Professional Engineer or other individual, knowledgeable in the requirements for design, in-service inspections, and testing of Class MC and metallic liners of Class CC components."

In Subsection 2.1.2 of Davis-Besse Nuclear Power Station (DBNPS) Surveillance Test Procedure DB-PF-03009, Revision 06, "Containment Vessel and Shielding Building Visual Inspection," states that "Personnel who performed the examination of the exterior surface of the Containment Vessel and the shielding Building need not be qualified in accordance with NOP-CC-5708". It is not clear to the staff what/which procedure(s) is/are used to qualify personnel who perform visual examinations of the Containment Vessel and Shielding Building.

Attachment L-11-134 Page 4 of 22 Provide qualifications of the personnel performing the visual examinations of the exterior surface of steel containment, and both sides of the shield building to be consistent with the recommendation in element 5, "detection of aging effects,"

of GALL AMP XI.S4.

RESPONSE RAI B.2.1-1 FENOC provides the following new license renewal future commitment regarding personnel qualifications for performing visual examinations of the exterior surface of steel Containment Vessel and the interior and exterior of the Shield Building, in LRA Appendix A, "Updated Safety Analysis Report Supplement," Table A-I, "Davis-Besse License Renewal Commitments:"

Davis-Besse Nuclear Power Station (DBNPS) Surveillance Test Procedure DB-PF-03009, Revision 06, "Containment Vessel and Shielding Building Visual Inspection," Subsection 2.1.2, shall be enhanced to state, "Personnel who perform general visual examinations of the exterior surface of the Containment Vessel and the interior and exterior surfaces of the Shield Building shall meet the requirements for a general visual examiner in accordance with Nuclear Operating Procedure NOP-CC-5708, "Written Practice for the Qualification and Certification of Nondestructive Examination Personnel." These individuals shall be knowledgeable of the types of conditions which may be expected to be identified during the examinations."

This enhancement will be implemented prior to the period of extended operation.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.5-1 Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Section A.1.2.3.1 states that the scope of the program should include the specific structures and components of the program that manages the aging. In addition, SRP-LR Section A.1.2.3.4 states that detection of aging effects should occur before there is a loss of the structure and component intended functions. The parameters to be monitored or inspected should be appropriate to ensure that the structure and component intended functions will be adequately maintained for license renewal under all current licensing basis design conditions. This includes aspects such as method or technique (e.g., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new or one-time inspections to ensure timely detection of aging effects.

Attachment L-11-134 Page 5 of 22 LRA AMP B.2.5 does not provide program specific information (e.g., monitoring technique, frequency of inspection, acceptance criteria) discussed and addressed in recent adverse industry operating experience with neutron absorber materials and staff guidance (i.e., NRC Information Notice 2009-26: Degradation Of Neutron-Absorbing Materials in the Spent Fuel Pool, and GALL AMP XI.M40, "Monitoring of Neutron-Absorbing Materials other than Boraflex")

The staff requests the following information:

1. Describe the material specifications (i.e., dimensions, percentage B4 C, etc.)

of the Boral material. Also, provide the age, manufacturer of the material and method of fabrication.

2. Describe the surveillance approach that will be used in the cited AMP, specifically the methods and techniques utilized (e.g., visual, weight, volumetric, surface inspection, neutron attenuation testing, frequency, sample size, data collection, timing and acceptance criteria).

3. Describe how the neutron absorption capacity of the material will be monitored. Include a description of the testing, parameters measured, calculations, and acceptance criteria.

4. Discuss whether the Boral material is vented. If not, discuss how it is assured that spent fuel pool water does not leak into the sealed aluminum weld.

RESPONSE RAI B.2.5-1

1. Davis-Besse spent fuel pool storage racks employ Boral as the neutron absorber material. The storage cells are composed of stainless steel walls with a single fixed neutron absorber panel, Boral, (held in place by 0.035 inch stainless steel sheathing) centered on each side in a 0.110 inch channel. Stainless steel boxes are arranged in an alternating pattern such that the connection of the box corners form storage cells between those of the stainless steel boxes. The Boral absorber has a thickness of 0.101 +/- 0.006 inches and a nominal B-10 areal density of 0.0324 grams per square centimeter (g/cm 2 ) (minimum of 0.0300 g/cm 2 ). The Boral absorber panels are 7.5 +/- 0.0625 inches in width and 148 + 0.25/-0.0 inches in length.

Davis-Besse Boral panels were manufactured by AAR Manufacturing in the summer of 1998.

Boral is an aluminum matrix containing boron carbide sandwiched between, and bonded to, aluminum cladding.

2. Davis-Besse does not have a Boral neutron absorber coupon tree installed in the spent fuel pool, and as such, no coupon surveillance program is possible.

Attachment L-11-134 Page 6 of 22 Absent a coupon surveillance program, FENOC plans to employ in-situ neutron attenuation testing. The primary parameter to be monitored is B-10 areal density.

The acceptance criteria will be the minimum B-1 0 areal density necessary to meet the assumptions in the spent fuel pool criticality analysis, which at Davis-Besse is currently a minimum of 0.0300 g/cm 2 . Acceptance criteria is subject to change based on then-current criticality analysis parameters.

Installation of the racks currently in the Davis-Besse spent fuel pools began in April 1999, and as such, the racks have been exposed to the spent fuel pool environment for 12 years or less. The initial application of the in-situ neutron attenuation testing will be conducted prior to the period of extended operation (i.e., prior to April 22, 2017). The frequency of testing during the PEO will be at least once every ten years, with the interval between testing campaigns shortened if the results of FENOC testing or industry operating experience for Boral neutron absorbers of a similar application and vintage as that of Davis-Besse should indicate that unacceptable degradation may occur prior to the next scheduled testing campaign.

A testing population of approximately 45 Boral neutron absorber panels is projected, based on recent testing campaigns. Testing population size may be adjusted at the time of the testing campaign based on then-current industry practices.

3. FENOC plans to employ in-situ neutron attenuation testing. The primary parameter to be monitored is B-1 0 areal density. The acceptance criteria will be the minimum B-10 areal density necessary to meet the assumptions in the spent fuel pool criticality analysis, which at Davis-Besse is currently a minimum of 0.0300 g/cm 2 . Acceptance criteria is subject to change based on then-current criticality analysis parameters.

4. The sheathing that holds the Boral neutron absorber panels in the racks in the Davis-Besse spent fuel pool are vented. At drawing position D-6 of Drawing C-063Q-00003, "Rack Construction - PWR Spent Fuel Storage Racks," there is a statement that indicates that the vent holes are not to be plugged by the welding that holds the stainless steel sheathing to the storage cell. The Boral panels themselves are cut to size and the edges are not sealed by the aluminum cladding.

LRA Section B.2.5, "Boral Monitoring Program," is revised based on the discussion in items 1-4, above.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment L-11-134 Page 7 of 22 Question RAI B.2.11-1 In element 3, "parameters monitored or inspected," of the basis document LRPD-05, Aging Management Evaluation Results related to LRA AMP B.2.11, the applicant states that the technical basis for the sample selected will be documented. In the GALL AMP XI.E6 Revision 2, it states that the applicant will document the technical basis for the sample selected.

It is not clear to the staff that these statements are consistent because the applicant has not developed the technical basis and/or the criteria for the sample selection.

Provide the technical basis for the sample selection of cable connections for one-time inspection.

RESPONSE RAI B.2.11-1 The "parameters monitored or inspected" and "detection of aging effects" program elements of LRA Section B.2.1 1, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection," are revised to state that 20 percent of the electrical cable connection population, with a maximum of 25 connections, constitutes a representative sample size. This sample size is based on that provided in NUREG-1801, "Generic Aging Lessons Learned (GALL) Report,"

Revision 2,Section XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.11-2 The staff reviewed USAR A.1.11 supplement description for the program (LRA AMP B.2.11) which states that the one-time inspection uses thermography (augmented by the optional use of contact resistance testing) to detect loose or degraded connections. The staff believes that a one-time inspection is to provide additional confirmation to support industry operating experience that shows electrical cable connections have not experienced a high degree of failures and that existing installation and maintenance practices are effective. The example description for this program is provided in NUREG-1800, Revision 2 (SRP-LR)

Table 3.0-1.

The purpose of the one-time inspection is to confirm that either aging of cable connections is not occurring and/or that the existing preventive maintenance program is effective such that a periodic inspection is not required.

Attachment L-11-134 Page 8 of 22 Provide an adequate program description consistent with the description provided in SRP-LR Revision 2 Table 3.0-1.

RESPONSE RAI B.2.11-2 LRA Sections A.1.11 and B.2.1 1, both titled, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection," are revised to provide an adequate program description based on the description provided in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2, Table 3.0-1, "FSAR Supplement for Aging Management of Applicable Systems."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.11-3 In the program basis document LRPD-05, under the parameters monitored or inspected program element, the applicant states that the inspections will include detection of loosened bolted connection due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

It further states, in part, that the following factors will be considered for sampling:

connections type (i.e., bolted splices, bolted terminations, lug terminations, bolted cable terminations). Splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks are described as the most common types of connections in the program description of GALL AMP XI.E6 Revision 2.

The NRC staff believes that loosening of cable connections may also occur in different types of connections and may not only be limited to bolted connections.

Provide a technical justification of why only bolted connections are considered in the inspection sample criteria.

RESPONSE RAI B.2.11-3 LRA Sections A. 1.11 and B.2.11 are revised to include various connection types.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.11-4 During a plant walkdown, the staff noted cable bus connections in a terminal housing connecting cable bus, bus tie transformers, and in the 4160 V essential switchgear buses. The applicant indicated to the staff that these cable buses

Attachment L-11-134 Page 9 of 22 were not subject to aging and are not included in an AMP because they are not located in an adverse localized environment.

The staff agreed with the applicant that insulation material for cable buses and connections are not subject to an AMP. However, metallic material of cable bus connections may experience increased resistance of connection due to loosening of bolted connections caused by repeated thermal cycling of connected loads.

Explain how aging of cable bus connections will be managed during the period of extended operation (PEO).

RESPONSE RAI B.2.11-4 LRA Sections A.1.11 and B.2.11 are revised to include various connection types. The metallic material of cable bus connections is managed by the Davis-Besse B.2.11 aging management program.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.20-1 Periodic draining and cleaning of diesel fuel tanks is performed so that internal surfaces can be visually and volumetrically inspected allowing for detection of corrosion and other degradation inside the tanks. Regulatory Guide 1.137 "Fuel Oil Systems for Standby Diesel Generators," Revision 1, Regulatory Position C.2.f, documented in GALL Report Revision 2, recommends draining and cleaning of diesel fuel tank internal surfaces at least once every 10 years during the period of extended operation.

LRA AMP B.2.20, "Fuel Oil Chemistry Program," states that the diesel fire pump day tank (DB-T47) and the station blackout diesel generator day tank (DB-T210) are cleaned and inspected every 12 years. The applicant states that LRA AMP B.2.20 is consistent with GALL AMP XI.M30, "Fuel Oil Chemistry," with exceptions.

The LRA is not consistent with the 10-year draining and cleaning frequency for diesel fuel tanks recommended by the GALL Report. Instead, the LRA states that draining and cleaning of the DB-T47 and DB-T210 tanks are performed on a 12-year interval.

Discuss how the 12-year interval for draining and cleaning of tanks DB-T47 and DB-T210 is consistent with the GALL AMP XI.M30, "Fuel Oil Chemistry."

Alternatively, provide a revision to your draining and cleaning frequency such that it is on a 10-year interval.

Attachment L-11-134 Page 10 of 22 RESPONSE RAI B.2.20-1 LRA Section B.2.20, "Fuel Oil Chemistry Program," is revised to provide the following program enhancement:

Require that internal surfaces of emergency diesel generator fuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generator day tank are periodically drained at least once every 10 years for cleaning and will be visually inspected to detect potential degradation. If degradation is identified in a diesel fuel tank by visual inspections, a volumetric inspection is performed.

Related changes are provided for the program description of LRA Section B.2.20, the program summary description in LRA Section A.1.20, "Fuel Oil Chemistry Program," a new license renewal future commitment in LRA Table A-i, and identification of the enhancement in LRA Table B-2, "Consistency of Davis-Besse Aging Management Programs with NUREG-1 801."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.20-2 The performance of volumetric inspections on degradation identified by visual inspections of the diesel fuel tank internal surfaces is an acceptable means to verify the presence of corrosion or other degradation inside the tanks.

Volumetric inspections are to be performed if evidence of degradation is observed during visual inspections of diesel fuel tank internal surfaces, or if visual inspection is not possible, as recommended in GALL Report Revision 2.

LRA AMP B.2.20 does not explicitly state and it is not clear to the staff whether volumetric inspections of degradation identified by visual inspections of tank internal surfaces will be performed.

If degradation is identified in a diesel fuel tank by visual inspections or if visual inspection is not possible, please discuss whether volumetric inspections will be performed to verify the degradation or inspect tank internal surfaces.

RESPONSE RAI B.2.20-2 LRA Section B.2.20, "Fuel Oil Chemistry Program," is revised to provide the following program enhancement:

Require that internal surfaces of emergency diesel generator fuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generator day tank are periodically

Attachment L-11-134 Page 11 of 22 drained at least once every 10 years for cleaning and will be visually inspected to detect potential degradation. If degradation is identified in a diesel fuel tank by visual inspections, a volumetric inspection is performed.

Related changes are provided for the program description of LRA Section B.2.20, the program summary description in LRA Section A.1.20, "Fuel Oil Chemistry Program," a new license renewal future commitment in LRA Table A-I, and identification of the enhancement in LRA Table B-2, "Consistency of Davis-Besse Aging Management Programs with NUREG-1801."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.20-3 The Final Safety Analysis Report (FSAR) Supplement description contained in the SRP-LR provides an acceptable program description for the GALL AMP XI.M30, "Fuel Oil Chemistry," which includes the specific ASTM Standards to be used for monitoring and control of fuel oil contamination to maintain fuel oil quality. LRA A.2.20 "Fuel Oil Chemistry Program" states:

The Fuel Oil Chemistry Program manages the presence of contaminants, such as water or microbiological organisms, that could lead to the onset and propagation of loss of material or cracking (of susceptible material) through proper monitoring and control of fuel oil contamination consistent with plant Technical Specifications and ASTM International (ASTM) standards for fuel oil.

Specifying the ASTM Standards to be used ensures that there is an adequate description of the critical elements of the Fuel Oil Chemistry Aging Management Program to provide assurance that the program will be properly executed during the period of extended operation. LRA FSAR Supplement A.2.20 does not include ASTM standards D975, D2276, D2709, D4057 and D4176 found in element 1, "scope of program," of LRA AMP B.2.20.

Justify the absence of the above mentioned ASTM standards in your FSAR Supplement provided in LRA Appendix A. Alternatively, provide a revision to your FSAR supplement to add the specific ASTM standards.

RESPONSE RAI B.2.20-3 LRA Sections A.2.20 and B.2.20 are revised to include ASTM standards D975, D2276, D2709, D4057 and D4176.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment L-11-134 Page 12 of 22 Question RAI B.2.21-1 GALL AMP XI,E3, "Inaccessible Medium Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements," addresses inaccessible medium voltage cables. The purpose of this program is to provide reasonable assurance that the intended functions of inaccessible medium-voltage cables (2 kV to 35 kV), that are not subject to environmental qualification requirements of 10 CFR 50.49 and are exposed to adverse localized environments caused by moisture while energized, will be maintained consistent with the current licensing basis. The scope of the program applies to inaccessible (in conduits, cable trenches, cable troughs, duct banks, underground vaults or direct buried installations) medium-voltage cables within the scope of license renewal that are subject to significant moisture simultaneously with significant voltage (energized 25% of the time).

The application of AMP XI.E3 to medium-voltage cables was based on the operating experience available at the time Revision 1 of the GALL Report was developed. However, industry operating experience subsequent to GALL Report Revision 1 indicates that the presence of water or moisture can be a contributing factor in inaccessible power cable failures at lower service voltages (400 V to 2 kV). Applicable operating experience was identified in licensee responses to Generic Letter (GL) 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," which included failures of power cable operating at service voltages of less than 2 kV where water was considered a contributing factor. The staff also noted that the significant voltage screening criterion (subject to system voltage for more than energized 25% of the time) was not applicable for all the inaccessible power cable failures noted.

Industry operating experience provided by NRC licensees in response to GL 2007-01 has shown: (a) that there is an increasing trend of cable failures with length in service, and (b) that the presence of water/moisture or submerged conditions appears to be the predominant factor contributing to cable failure.

The staff has determined, based on the review of the cable failure data, that an annual inspection of manholes and a cable test frequency of at least every six years (with evaluation of inspection results to determine the need for an increased inspection frequency) is a conservative approach to ensuring the operability of power cables and, therefore, should be considered. The use of test and inspection frequencies in the determination of the need for adjustment of test and inspection frequencies should also be considered.

In addition, industry operating experience subsequent to GALL Report Revision I has shown that some NRC licensees may experience cable manhole water intrusion events, such as flooding or heavy rain, that subjects cables within the scope of program for GALL AMP XI.E3 to significant moisture. The staff has determined that event driven inspections of cable manholes, in addition to a

Attachment L-11-134 Page 13 of 22 1-year periodic inspection frequency, is a conservative approach and, therefore, should be considered.

The staff requests the following information:

1. Provide a summary of your evaluation of recently identified industry operating experience and any plant-specific operating experience concerning inaccessible low voltage power cable failures within the scope of license renewal (not subject to 10 CFR 50.49 environmental qualification requirements), and how this operating experience applies to the need for additional aging management activities for such cables.

2. Explain how DBNPS will manage the effects of aging on inaccessible low voltage power cables within the scope of license renewal with consideration of recently identified industry operating experience and any plant-specific operating experience. The discussion should include assessment of your aging management program description, program elements (i.e., "scope of program," preventive actions," parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and acceptance criteria"), USAR summary description and applicable license renewal commitment to demonstrate reasonable assurance that the intended functions of inaccessible low voltage power cables subject to adverse localized environments will be maintained consistent with the current licensing basis through the PEO.

3. Provide an evaluation showing how the Non-EQ Inaccessible Medium-Voltage Cable Program test and inspection frequencies, including event driven inspections, incorporate recent industry and plant-specific operating experience for both inaccessible low and medium-voltage cable.

Explain how the Inaccessible Medium-Voltage Cable Program will ensure that future industry and plant-specific operating experience will be incorporated into the program such that inspection and test frequencies may be increased based on test and inspection results.

RESPONSE RAI B.2.21-1 Based on industry cable operating experience and plant-specific manhole water operating experience, FENOC has determined that the addition of cables operated at or above 400 volts is prudent, and that testing of the cables within the scope of this program every 6 years is reasonable and allows for trending of test data. Inspection for water in the in-scope manholes at least every year, and after events that could cause water to accumulate to the level of the installed cables or conduit, is warranted. The

'scope' and 'testing and inspection frequency' changes will provide reasonable assurance that the cables covered by this program will continue to perform their required functions during the period of extended operation.

Attachment L-11-134 Page 14 of 22

1. With respect to recent industry operating experience concerning inaccessible low-voltage power cable, the NRC Summary Report for Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," was consulted in response to this RAI.

Figure 23 of the Summary Report indicates the causes and causal factors for low-voltage cable failures. For these failures, the NRC staff noted that water, physical damage, general age-related degradation, and human error were contributors. The predominant factor was general age-related degradation.

FENOC Letter, Serial 3333, dated May 8, 2007, "Response To Generic Letter 2007-01 (TAC No. MD4320)," ADAMS Accession Number ML071290578, provides a history of inaccessible or underground power cable failures at Davis-Besse for all cables within the scope of 10 CFR 50.65 (the Maintenance Rule).

The FENOC response to Generic Letter 2007-01 included a listing of inaccessible or underground power cables where testing identified cable degradation. No failures of 480V cables were identified. The 480V cables were replaced prior to failure of the cable or component.

The recent industry and plant specific operating experience with respect to lower service voltage cables summarized above indicates that monitoring of inaccessible underground lower service voltage power cables (400 VAC to 2kV) is prudent during the period of extended operation.

LRA Sections A.1.21 and B.2.21 are revised to include inaccessible lower service voltage power cables.

2. The Davis-Besse program provided in LRA Section B.2.21, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 EQ Requirements Program," currently addresses medium-voltage cable (from 2 kV to 35 kV), to follow the recommendations of Section XI.E3 of NUREG-1801, Revision 1. As provided in the item 1 response to this RAI, monitoring of inaccessible underground lower service voltage power cables (400 VAC to 2kV) is prudent during the period of extended operation.

LRA Sections A.1.21 and B.2.21 ,including the applicable program elements, are revised to also address electrical power cables at lower service voltages (400 VAC to 2 kV) in inaccessible underground locations to address recent industry and plant specific operating experience. The subject program is re-named as the "Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program," and the affected sections of the LRA are revised to include the new title.

3. Based on industry cable operating experience and plant-specific manhole water operating experience, testing of the cables that are within the scope of this program every 6 years is reasonable and allows for trending of test data. Inspection for water in the in-scope manholes at least every year, and after events that could cause

Attachment L-11-134 Page 15 of 22 water to accumulate to the level of the installed cables or conduit, is warranted.

The 'scope' and 'testing and inspection frequency' changes will provide reasonable assurance that the cables covered by this program will continue to perform their required functions during the period of extended operation. Therefore, LRA Section B.2.21 is revised to include new enhancements to the test and inspection frequencies, including event-driven inspections of the Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program, as follows:

• Perform cable testing on a frequency of at least every 6 years.

• Cable test frequency will be updated as required based on test results.

• Electrical manholes will be inspected at least once per year.

• The frequency of manhole inspections for accumulated water will be established and adjusted based on plant-specific inspection results.

• Manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

LRA Table A-1 is revised to include these program enhancements as new license renewal future commitments.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.21-2 GALL AMP XI.E3 states that periodic actions are taken to prevent inaccessible cables from being exposed to significant moisture, such as identifying and inspecting in-scope accessible cable conduit ends and cable manholes for water collection, and draining the water, as needed.

Manhole MH3045, based on work orders, corrective actions, system health reports, and staff inspection reports, has continued to experience water intrusion and cable submergence. Corrective actions have included increased inspection frequencies and, more recently, the installation of a temporary sump pump to limit the exposure of in-scope inaccessible cable to significant moisture.

Provide a commitment to implement the corrective actions (such as permanent sump pump, cable replacement, increased inspection frequencies, and testing) for manhole MH3045 to prevent in-scope inaccessible cable from being exposed to significant moisture (cable wetting or submergence) so that these cables will continue to perform their intended functions during the PEO.

Attachment L-11-134 Page 16 of 22 RESPONSE RAI B.2.21-2 A permanent sump pump, DB-P190, has been installed in manhole MH3045 to prevent the cables from being exposed to significant moisture. In addition, as provided in the response to RAI B.2.21-1:

" the frequency of manhole inspections for accumulated water will be established and adjusted based on plant-specific inspection results, and

" manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

Question RAI B.2.21-3 GALL AMP XI.E3 states that for this AMP, periodic actions are taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes, and draining water as needed.

GALL AMP XI.E3, element 2, states in part that the inspection should include direct observation that cables are not wetted or submerged. The staff is concerned that power plant work orders developed to inspect manholes including manholes in-scope for license renewal do not specifically require documentation if in-scope inaccessible cables are found submerged. Although procedures require inspecting for water level and pumping out any water found, the maintenance work orders do not have an action to identify in-scope cables found submerged. Without this step it is not clear how cables exposed to significant moisture would be identified and how additional corrective actions would be taken. Reference work orders PM 4297, PM 4294, PM 8025, and PM 4296.

Explain how in-scope inaccessible power cables that are exposed to significant moisture will be identified and how corrective actions will be taken through referenced plant work orders.

RESPONSE RAI B.2.21-3 Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities (PM 4297, PM 4294, PM 8025, and PM 4296) exist for inspection of water accumulation in the manholes associated with the in scope inaccessible non-EQ power cables. As an enhancement to the program, these preventive maintenance activities will include a requirement to generate a condition report in cases where the inspection identifies submerged cables.

Attachment L-11-134 Page 17 of 22 LRA Section B.2.21 is revised to include the program enhancement, and License Renewal commitment Table A.1 is revised to include the new license renewal future commitment.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.21-4 GALL AMP XI.E3 states that for this AMP, periodic actions are taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes, and draining water as needed. The staff reviewed manhole drawings provided by the applicant and noted that some of the manholes in the scope of license renewal do not have sump pumps but drain to manholes that are not in scope that do have sump pumps.

It is not clear to the staff that the sump pumps located in manholes not in scope of AMP B.2.21 but connected through common drainage systems (a common sump for the duct bank system) would be inspected/functionally tested. Because these sump pumps are used to prevent in-scope inaccessible power cables from being exposed to significant moisture, the staff is concerned that sump pumps not located in in-scope manholes may not be inspected/functionally tested under LRA AMP B.2.21.

Explain how sump pumps not included in the in-scope manholes but used to prevent in-scope inaccessible power cables from being exposed to significant moisture are inspected and functionally tested with the associated in-scope manholes under LRA AMP B.2.21.

RESPONSE RAI B.2.21-4 With the recent addition of a permanent sump pump installed in manhole MH3045, the in-scope manholes either have a sump pump installed or drain to an in-scope manhole that has a sump pump installed.

Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities (PM 4297, PM 4294, PM 8025, and PM 4296) exist for inspection of water accumulation in the manholes associated with the in scope inaccessible non-EQ power cables. These preventive maintenance activities include functional testing of the sump pumps associated with the in-scope manholes.

Attachment L-11-134 Page 18 of 22 Question RAI B.2.21-5 System Health Reports (including 2010-04), and other site documents reference a medium-voltage wetted cable replacement program as part of the health improvement plan. The System Health Reports identify medium-voltage underground cables located in a potentially wet environment that are scheduled for replacement. The System Health Reports state that the priority for cable replacement is based on identified corrective actions and considers the following factors: (1) risk significance, (2) length of time a cable is energized, (3) cable age, (4) insulation type, and (5) connected equipment GALL AMP XI.E3, element 7, "corrective actions," states that when an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible, in-scope power cables. Element 7 further states that corrective actions may include, but are not limited to, installation of permanent drainage systems, installation of sump pumps and alarms, more frequent cable testing or manhole inspections, or replacement of the affected cable.

The identification of wetted medium-voltage cable replacement with respect to inaccessible power cables in scope of license renewal (GALL AMP XI.E3) is not specifically referenced or described in the System Health Reports.

Provide a discussion of the medium-voltage wetted cable replacement program as applicable to license renewal. Discuss criteria for replacement including prioritization or deferred replacement with monitoring (testing). Provide information detailing the in-scope inaccessible power cables included in the replacement program, the number of in-scope inaccessible power cables replaced, and the planned schedule for in-scope inaccessible power cable replacement or monitoring (testing).

RESPONSE RAI B.2.21-5 The medium-voltage wetted cable replacement program includes 24 cables (identified below) that are within the scope of License Renewal. The medium-voltage wetted cable replacement program originated through the FENOC Corrective Action Program pursuant to requirements of 10 CFR 50, Appendix B, Criterion XV and Criterion XVI.

Cable replacement is based upon (1) risk significance, (2) length of time a cable is energized, (3) cable age, (4) insulation type, and (5) connected equipment.

Attachment L-11-134 Page 19 of 22 The following cables within the scope of License Renewal have been replaced:

Cable Numbers Equipment APX0105A-F startup transformer X01 BPX0106A-F startup transformer X01 BPXBD01A-C bus tie transformer XBD APAC201A backup service water pump 1PAC1 13A component cooling water pump 1 2PAD1 13A component cooling water pump 2 3PACD01A component cooling water pump 3 1PAC111A high pressure injection pump 1 APAC105A makeup pump 1 BPAD105A makeup pump 2 1PAC1 07A service water pump 1 2PAD107A service water pump 2 3PACD06A service water pump 3 The following cables within the scope of License Renewal are scheduled for replacement:

Cable Numbers Equipment Schedule

• APXAC01A-C bus tie transformer XAC 17RFO 2PAD1_12A decay heat pump 2 18RFO BPAD210H motor driven feed pump 18RFO 2PAD101A&B emergency diesel generator 2 18RFO APX0205A-F startup transformer X02 19RFO 1PAC 112A decay heat pump 1 19RFO BPX0206A-F startup transformer X02 20RFO 2PAD1 11A high pressure injection pump 2 20RFO 1PAC101A&B emergency diesel generator 1 21 RFO

• 17RFO refers to Cycle 17 refueling outage The underground cables associated with the station blackout diesel generator (BPGD301 C and BPGD301 C1) are being monitored by diagnostic testing every two years rather than replacing cables, as originally planned.

Question RAI B.2.26-1 The staff noted that water contamination in lubricating oil can cause an environment that is conducive to loss of material or reduction of heat transfer.

In addition, areas of stagnant oil flow are susceptible to water accumulation and

Attachment L-11-134 Page 20 of 22 have the potential to go undetected with the current standard industry testing techniques.

GALL AMP XI.M39 "Lubricating Oil Analysis," states that water and particle concentration should not exceed limits based on equipment manufacturer's recommendations or industry standards. Additionally, it states that phase-separated water in any amount is not acceptable. The staff noted during its audit that LRA Section B.2.26 and the applicant's program basis document does not indicate that any testing is performed to detect the presence of phase-separated water, nor do they provide any corrective actions that will be taken if phase-separated water is detected.

Describe the tests that will be performed to detect for the presence of phase-separated water in lubricating oil systems within the scope of license renewal. If testing for phase-separated water will not be performed, clarify and provide technical justification for the preventative actions taken in order to prevent phase-separated water accumulation from occurring. Conversely, if preventative actions are not to be taken to prevent phase-separated water accumulation, provide technical justification for why no action is needed.

RESPONSE RAI B.2.26-1 The Davis-Besse Lubricating Oil Analysis program requires periodic sampling of lubricating oil and testing for particle count and the presence of water to detect evidence of abnormal wear rates, contamination by moisture, or excessive corrosion. While the term "phase-separated water' is not used in the Lubricating Oil Analysis Program or plant procedures, the amount of water contained in samples is determined through laboratory testing. The laboratory results for water content are compared to limits, and corrective action is taken when water content exceeds limits. Free water (i.e., phase-separated water) in a sample would exceed water content limits because water content limits for oil are detected and recorded in small units, such as parts-per-million or weight-percent.

The One-Time Inspection supplements the Lubricating Oil Analysis Program and is used to confirm the effectiveness of the Lubricating Oil Analysis Program. The elements of the one-time inspections for lube oil systems will include:

• Determination of a representative sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience;

" Identification of the inspection locations in the system or component based on the aging effect, or based on the areas susceptible to concentration of contaminants that promote certain aging effects;

Attachment L-11-134 Page 21 of 22

" Determination of the examination technique, including acceptance criteria that would be effective in managing the aging effects for which the component is examined; and

" Evaluation of the need for follow-up examinations to monitor the progression of any age-related degradation.

The One-Time Inspection is used to confirm the absence of aging effects where water and other contaminants might have accumulated in lubricating oil systems within the scope of license renewal. The FENOC Corrective Action Program would be used to address unexpected age-related degradation and evaluate the need for additional monitoring or equipment modifications. The use of the One-Time Inspection to detect accumulation of water in lube oil systems is justified based on Davis-Besse lubricating oil operating experience and on the NUREG-1801 operating experience statement that no instances of component failures attributed to lubricating oil contamination have been identified.

Question RAI B.2.38-1 The staff has identified potential inconsistencies between NEI 97-06, Revision 2, and the standard steam generator technical specifications which the applicant has adopted (through its adoption of TSTF-449). These inconsistencies were discussed in a public meeting on September 16, 2009, between the Nuclear Energy Institute Steam Generator Task Force and the U.S. Nuclear Regulatory Commission (refer to meeting summary dated October 6, 2009 (Agencywide Documents Access and Management Systems Accession Number ML092820119)).

The potential inconsistencies between NEI 97-06, Revision 2, and the standard steam generator technical specifications raises questions on whether all the applicant's technical specification requirements will be satisfied.

Please confirm that your steam generator AMP has addressed the potential inconsistencies between NEI 97-06 and your technical specifications.

RESPONSE RAI B.2.38-1 The Davis-Besse Steam Generator Management Program is based on Technical Specification requirements, and is implemented in accordance with NEI 97-06, "Steam Generator Program Guidelines," Revision 2. Davis-Besse has adopted steam generator tube integrity Technical Specifications consistent with those in TSTF-449, "Steam Generator Tube Integrity," as approved by safety evaluation report in NRC Letter dated July 31, 2007, "Davis-Besse Nuclear Power Station, Unit No. 1 - Issuance of Amendment Re: Steam Generator Tube Integrity Technical Specifications Amendment

Attachment L-11-134 Page 22 of 22 Using the Consolidated Line Item Improvement Process (TAC NOS. MD2145 AND MD0077)" (ADAMS Accession Number ML072040417).

Consistent with the NEI 97-06 guidelines, the Davis-Besse requirements for steam generator tube integrity and the Steam Generator Tube Integrity Program are provided in the plant Technical Specifications.

NEI 97-06, Revision 3, eliminated any identified conflicts with standard steam generator Technical Specifications and its incorporated reference documents further indicate that, if a conflict arises, plant Technical Specifications shall govern. Revision 3 was issued effective January 2011, with a required implementation date of September 30, 2011.

Enclosure Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)

Letter L-11-134 Amendment No. 6 to the DBNPS License Renewal Application Page 1 of 27 License Renewal Application Sections Affected Table 3.6-1 Table B-2 Table 3.6.2-1 Section B.2.5 Section A. 1.11 Section B.2.11 Section A. 1.20 Section B.2.20 Section A.1.21 Section B.2.21 Table A-1 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected 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 kned-ou and added text underlined.

Enclosure A L-11-134 Page 2 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.6.1 Page 3.6-10 Row 3.6.1-04, "Discussion" and "Aging Management Programs" Text in Discussion column revised based on the response to RAI B.2.21-1. The Aging Management Program title is revised to read "Inaccessible Medium Voitage Power Cables Not Subject to 10 CFR 50.49 EQ Requirements."

LRA Table 3.6.1, "Summary of Aging Management Programs for Electrical and I&C Components Evaluated in Chapter VII of NUREG-1 801," is revised to include the Program title and scope change, and now reads:

RAI B.2.21-1 Table 3.6.1 Summary of Aging Management Programs for Electrical and I&C Components Evaluated in Chapter VI of NUREG-1801 Item IAging Aging Management Further Iter Number Component/Commodity

]Effect/Mechanism Effect/Mechanams Programs Evaluation Recommended Discussion 3.6.1-04 Conductor insulation for Localized damage Inaccessible Medium- No Consistent with NUREG-1801.

inaccessible medium voltage (2- and breakdown of Voltage Power Cables kW to 35-kV) cables (e.g., insulation leading to Not Subject to 10 CFR The Inaccessible Power Cables installed in conduit or direct electrical failure due 50.49 EQ Requirements Not Subiect to 10 CFR 50.49 EQ buried) not subject to to moisture intrusion, Requirements Program is 10 CFR 50.49 EQ requirements water trees enhanced such that the scope also includes inaccessible under-ground400VAC to 2kV oower cables, in response to industry and plant-specific operating experience.

Enclosure A L-11-134 Page 3 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.6.2-1 Page 3.3-465 Row No. 4 Row No. 4 is revised based on the response to RAI B.2.21-1, to address the program scope and name change. A plant-specific note is added. LRA Table 3.6.2-1, "Aging Management Review Results - Electrical Component Commodity Groups," is revised to read:

Table 3.6.2-1 Aging Management Review Results - Electrical Component Commodity Groups Component Intended Material Environment Aging Effect Requiring I Aging Management NUREG-1801, Table 1 Notes Type Function(s) Malagene M anage m en int Manam Volume Item Program 2 Item Localized Non- Adverse damage and Inaccessible Environment- localized breakdown of Mesibl0 Eniomn-Various environment insulation ally Qualified Conduct VarPower Cables A Medium- electricity Organic caused by leading to Not Subject to VI.A-4 3.6.1-04 0605 Voltage Power Polymers exposure to 10 CFR 50.49 moisture and /electrical moisturefailure EQ Requirements Cables voltage intrusion, water trees A new plant-specific note is added to the Plant-Specific Notes Table on LRA page 3.6-23. LRA Section 3.6, "Plant-Specific Notes" Table is revised to read:

Plant-Specific Notes:

0605 Inaccessible underground lower service voltage cables (400VAC to 2kV) are included in response to industry and plant-specific operating experience.

Enclosure A L-11-134 Page 4 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.11 Page A-12 Entire section LRA Section A.1.11, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection," is revised based on the response to RAI B.2.11-2, B.2.11-3 and B.2.11-4, and is replaced in its entirety, to read:

A.1.11 ELECTRICAL CABLE CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENTS INSPECTION The ElectricalCable Connections Not Sub/ect to 10 CFR 50.49 Environmental QualificationRequirements Inspection provides reasonableassurancethat the intended functions of the metallic parts of electrical cable connections within the scope of the program that are susceptible to age-relateddegradationresulting in increased resistance of connection due to thermal cycling, ohmic heating, electricaltransients,vibration, chemical contamination,corrosion, or oxidation are maintained consistent with the currentlicensing basis through the period of extended operation.

Cable connections are used to connect cable conductors to other cable conductors or electricaldevices. Connections associatedwith cables within the scope of license renewal including high voltage connections are part of this program. The most common types of connections used in nuclearpower plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminalblocks.

Most connections involve insulating materialand metallic parts. This program focuses on the metallic parts of the electrical cable connections. This program provides a one-time inspection, on a sampling basis, to ensure that either aging of metallic cable connections is not occurring and/or that the existing preventive maintenance program is effective such that a periodic inspection program is not required. The one-time inspection confirms the absence of age-related degradationof cable connections resulting in increasedresistance of connection due to thermal cycling, ohmic heating, electricaltransients,vibration, chemical contamination,corrosion, or oxidation.

Implementation of this inspection provides added assurancethat the electrical connections in the plant have electricalcontinuity and are not overheating due to increasedresistance (from a loosened or degraded connection). The inspection is performed via the use of thermography, with the optional use of contact resistance testing as a supplement.

Enclosure A L-11-134 Page 5 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.20 Page A-16 Entire section In response to RAI B.2.20-1, B.2.20-2 and B.2.20-3, the program description in LRA Section A.1.20, "Fuel Oil Chemistry Program," is replaced in its entirety to read:

A.1.20 FUEL OIL CHEMISTRY PROGRAM The Fuel Oil Chemistry Programmonitors and maintains fuel oil quality in order to mitigate damage due to loss of material,as well as due to cracking of susceptible materials, for the storage tanks and associatedpiping and components containing fuel oil that are within the scope of license renewal. The program includes verifying the quality of new fuel oil, periodic sampling of stored diesel fuel oil, and periodic cleaning and inspection of the emergency diesel generatorfuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generatorday tank. The fuel oil tanks are periodicallydrained(at least once every 10 years) for cleaning and are visually inspected to detect potential degradation. If degradationis identified in a diesel fuel tank by visual inspections, a volumetric inspection is performed.

The Fuel Oil Chemistry Programmanages the presence of contaminants,such as water or microbiologicalorganisms, that could lead to the onset and propagation of loss of materialor cracking (of susceptible material)through proper monitorinqand control of fuel oil contamination consistent with plant Technical Specifications and ASTM standardsD975, D22 76, D2709, D4057 and D4176. The Fuel Oil Chemistry Programis a mitigation program.

The effectiveness of the Fuel Oil Chemistry Program is verified by the One-Time Inspection, which includes ultrasonic thickness measurement of a sample of fuel oil tank bottom.

Enclosure A L-11-134 Page 6 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.21 Page A-16 Entire section In response to RAI B.2.21-1, the program title in the LRA is revised to read,,

"Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program." The program description in LRA Section A.1.21, "Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program," is replaced in its entirety to read:

A.1.21 INACCESSIBLE MEDIUM-VOLTA.. POW*ERCABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENTS PROGRAM The Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental QualificationRequirements Proqrammanaqes reduced insulation resistance of inaccessible or underqroundpower cables (greaterthan or equal to 400 volt) that are exposed to siqnificant moisture, such that there is reasonableassurancethat the cables will perform their intended function in accordance with the current licensinq basis throuqh the period of extended operation. Siqnificant moisture is defined as periodicexposure to moisture that lasts more than a few days (e.g., cable wettinq or submerqence in water).

At least once every 6 years these cables are tested to provide an indication of the condition of the conductor insulation. The frequency of testing is adiusted based on test results and operatinqexperience. The pro-gram also requires periodicinspection of electrical manholes associated with in-scope cables for water accumulation and requiresthe removal of water from the electrical manholes as necessary. Inspections are performed at least annually and are also performed in response to event-driven occurrences (such as heavy rain or floodinq.)

Enclosure A L-11-134 Page 7 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-57 Commitment 5 Commitment 5 is revised to add an enhancement to the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection based on the response to RAI 3.6-3. LRA Table A-I, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments IRelated LRA Item Iter Number Commitment Implementation Schedule Source Section CmetNo./

Comments 5 Implement the Electrical Cable Connections Not Subject to Priorto LRA A.1.11 10 CFR 50.49 Environmental Qualification Requirements April 22, 2017 FENOC B.2.11 Inspection as described in LRA Section B.2.11. Letter Response to Enhance the ElectricalCable Connections Not Subiect to L-11-134 NRC RAI 3.6-3 10 CFR 50.49 Environmental Qualification Requirements from NRC Inspection to: Letter dated

• Include hiqh voltage connections to confirm the absence of April 5, 2011 aging effects for metallic electricalconnections.

Enclosure A L-11-134 Page 8 of 27 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Table A-1 Page A-61 Commitment 11 Commitment 11 is changed due to a program title change and the addition of program enhancements based on the response to RAI B.2.21-1 and B.2.21-3. LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 11 Implement the Inaccessible Medium Veftage Power Cables Not Priorto LRA A.1.11 Subject to 10 CFR 50.49 Environmental Qualification Requirements April 22, 2017 FENOC B.2.11 Program as described in LRA Section B.2.21. Letter Response to Enhance the Inaccessible Power Cables Not Subiect to L-11-134 NRC RAI 10 CFR 50.49 Environmental QualificationRequirements B.2.21-land Pro-gram to: B. 2.21-3 from NRC Letter dated

• Include inaccessible undergroundlower service voltage cables (400 VAC to 2kV). April 5, 2011

" Not use 'significantvoltage' (defined as being subiected to system voltage for more than twenty-five percentof the time) as a criterion for inclusion into the program.

• Include inspection of electricalmanholes which contain power cables within the scope of the program.

Enclosure A L-11-134 Page 9 of 27 Table A-1 Davis-Besse License Renewal Commitments e IRelated LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 11, cont.

• Inspect electrical manholes at least once per year. The frequency of inspections for accumulated water will be establishedand adiustedbased on plant-specific inspection results. Also, manhole inspections will be performed in response to event-driven occurrences (e.g.., heavy rain or flooding).

Include a requirementin preventive maintenance activities PM 4297, PM 4294, PM 8025, and PM 4296 to generate a condition report in cases where in scope inaccessible non-EQ power cable manhole inspection identifies submerged cables.

Although the Inaccessible Power Cables Not Subiect to 10 CFR 50.49 Environmental QualificationRequirements Program is a new program, preventive maintenance activities exist for inspection of water accumulation in the manholes associatedwith the in scope inaccessible non-EQ power cables.

Perform cable testing on a frequency of at least every 6 years.

Testing will be evaluated for more frequent performance based on test results and operatingexperience.

Enclosure A L-11-134 Page 10 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added to the table based on the response to RAI B.2.1-1.

LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Number m

j Commitment TiImplementation Schedule Source Related LRA Section No./

Cmet Comments 27 DBNPS Surveillance Test Procedure DB-PF-03009,Revision 06, Priorto FENOC Response to "ContainmentVessel and Shielding Building Visual Inspection," April 22, 2017 Letter NRC RAI Subsection 2.1.2, shall be enhanced to state, "Personnelwho L-1 1-134 B.2. 1-1 from perform general visual examinationsof the exteriorsurface of the NRC Letter Containment Vessel and the interiorand exterior surfaces of the dated Shield Building shall meet the requirementsfor a generalvisual April 5, 2011 examiner in accordance with Nuclear OperatingProcedureNOP-CC-5708, "Written Practicefor the Qualification and Certificationof Nondestructive Examination Personnel." These individuals shall be knowledgeable of the types of conditions which may be expected to be identified during the examinations."

Enclosure A L-11-134 Page 11 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added to the table based on the response to RAI B.2.20-1 and B.2.20-2 LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 28 Enhance the Fuel Oil Chemistry Programto: Priorto LRA A. 1.20 April 22. 2017 FENOC B.2.20

• Require that internal surfaces of emergency diesel generator fuel oil storage tanks and day tanks, diesel oil storage tank, Letter Response to diesel fire pump day tank, and station blackout diesel generator L-1 1-134 NRC RAI day tank are periodically drained(at least once every 10 years) B.2.20-1 and for cleaning and are visually inspected to detect potential B. 2.20-2 from degradation. If degradationis identified in a diesel fuel tank by NRC Letter visual inspections, a volumetric inspection is performed, dated April 5, 2011

Enclosure A L-11-134 Page 12 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-2 Page B-19 "Enhancement Required" column The "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection" row is revised to identify an enhancement added in response to RAI 3.6-3, and now reads:

Table B-2 Consistency of Davis-Besse Aging Management Programs with NUREG-1801 Consistent Consistent wt New I with NUth Plant- Enhancement Existing NUREG- 1801 with Specific Required 1801 181wt Exceptions Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental New Yes Yes Qualification Requirements Inspection Section B.2.11

Enclosure A L-11-134 Page 13 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-2 Page B-20 "Enhancement Required" column The "Fuel Oil Chemistry Program" row is revised to identify an enhancement added in response to RAI B.2.20-1, and now reads:

Table B-2 Consistency of Davis-Besse Aging Management Programs with NUREG-1801 Consistent Consistent wt New /

Existing with NUEG Plant- Enhancement NUREG- 1801 with Specific Required 1801 181wt Exceptions Fuel Oil Chemistry Program Existing Yes Yes Section B.2.20

Enclosure A L-11-134 Page 14 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.5 Pages B-33 thru Aging Management Program B-36 Elements LRA Section B.2.5, "Boral Monitoring Program," Aging Management Program Elements are revised based on the response to RAI B.2.5-1, and now reads:

Aging Management Program Elements The results of an evaluation of each program element are provided below.

Scope The scope of the Rew Boral Monitoring Program consists of in-situ neutron attenuation testing of the Boral neutron absorbing material in the spent fuel storage racks at Davis-Besse.

The Boral Monitoring Program is credited fo.r detocting los of material aging-effeet monitors the ability of the Boral noutron absorbers to absorb neutrons in the spent fuel racks.

• Parameters Monitored or Inspected The Boral Monitoring Program monitors changes that c-an load-to loss of matoiaGor chango Of physical form the neutron absorption propertiesof the Boral neutron absorbers in the spent fuel racks. The program monitors changes in physical p*operties of the Boral hby in-situ neutron attenuation testing.

The program provides for additional, optional measurement parameters and actions, including radiography, destructive wet chemical analysis or destructive inspection of the Boral panels. These additional actions provide options for confirming or further investigating results of in-situ testing.

" Detection of Aging Effects The Boral Monitoring Program monitors the condition of the absorber material with in-situ neutron attenuationtesting. Visual inspoctions a*d measurements, as approepriate, are used to determine and assess the extent of-dgaaini the Boralý before there is a loss o-f intended f-upct~e. The initial testing will occur prior to the period of extended operation. A testing population of approximately 45 Borarneutron absorberpanels is projected, based on recent industry testing campaigns.

Enclosure A L-11-134 Page 15 of 27 Testing population size may be adiusted at the time of the testing campaiqn based on then current industry practices. Test frequency will be at least once per 10 years, and may be more frequent if results of Davis-Besse testing, or industry operating experience indicate that unacceptable degradationmay occur prior to the next scheduled test.

Monitoring and Trending In-situ testing of Boral will provide information on the radiological effects, thermal effects, and chemical effects of the spent fuel pool environment on the neutron attenuation capability of the Boral panels. Visual inspGections determine the extent of loss; of material. These inspections Will be reported in a manner which allows trending ef resu-ts. The measurements from in-situ neutron attenuation tests are compared to previous test results to determine whether degradationis occurring, and whether such degradation may affect the Boral'sfunction prior to the next scheduled test.

• Acceptance Criteria Thea -moSt ig;nificant measurements taken amr for evaluation of thickness (to monitor for swelliRg). There is no evidence that noutron attenuation testing (to confirm the concentFration. o-f Boron10 in the- Ba)Will serge any usoefu4 purpose. Based On the MOnOitorin metods used, acceptance criteria fol measurements will be established prior to the period o~f extended-oertin Changes' i e.coss f the acceptance criteria will require investigation and Sn eingmvauatin t dPtify whether further testing ormcmrvc*F tive.

actions may be RneessaFr.

Other measuremnent par~ametpErs will also be exmndfor earlyincaos of the potential onset of Baral  ; ho+ , g,., R f -*

further attention. These include.

• Visual r photographic evidence o-f unuua ge9e*triF changes SThe eoxstance om f areas of reduced boron density Neutron attenuationacceptance criteria will be determined based on confirming the B-10 areal density assumed in the spent fuel pool criticality analysis. Acceptance criteriais subject to change based on changes to the criticality analysisparameters.

Operating Experience

[Only the third paragraph in this subsection is changed, as follows]

FENOC re.rac_,kd the spent fuel poo,-l in the Cycle 13 refueling u,,tage (February 2002 to March 2004) with began installing Boral as a the neutron absorber in the spent fuel Pool beginning in 1999. As a result, the Boral neutron absorbers exposure to the spent fuel pool environment

Enclosure A L-11-134 Page 16 of 27 would be less than 40 years at the end of the period of extended operation.

The overall performance of the Boral at Davis-Besse currently (less than 1-0 12 years) would be similar to the results evaluated by EPRI from industry coupon surveillance programs such that the Boral's neutron attenuation capability remains acceptable. An EPRI report on neutron absorber materials contains a compilation of data and operating experience for all neutron absorber materials used or proposed for spent fuel storage and transportation applications over the last 40 years.

Enclosure A L-11-134 Page 17 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.11 Page B-54 "Program Description" subsection The Program Description subsection of LRA Section B.2.1 1, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection," is revised based on the response to RAI B.2.11-2, B.2.11-3 and B.2.11-4, and is replaced in its entirety, to read:

Program Description The ElectricalCable Connections Not Subiect to 10 CFR 50.49 EQ Requirements Inspection will provide reasonableassurancethat the intended functions of the metallic parts of electrical cable connections within the scope of the program that are susceptible to age-related degradationresulting in increased resistanceof connection due to thermal cycling, ohmic heating, electricaltransients, vibration, chemical contamination,corrosion, or oxidation are maintained consistent with the currentlicensing basis through the period of extended operation.

Cable connections are used to connect cable conductors to other cable conductors or electrical devices. Connections associatedwith cables within the scope of license renewal including high voltage connections are part of this program. The most common types of connections used in nuclearpower plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks.

Most connections involve insulating materialand metallic parts. This program will focus on the metallic parts of the electrical cable connections. This program will provide a one-time inspection, on a sampling basis, to ensure that either aging of metallic cable connections is not occurring and/or that the existing preventive maintenance program is effective such that a periodic inspection program is not required. The one-time inspection will confirm the absence of age-relateddegradationof cable connections resulting in increasedresistance of connection due to thermal cycling, ohmic heating, electrical transients,vibration, chemical contamination, corrosion, or oxidation.

Implementation of this inspection will provide added assurance that the electrical connections in the plant have electricalcontinuity and are not overheating due to increasedresistance (from a loosened or degraded connection). The inspection will be performed via the use of thermography, with the optionaluse of contact resistance testina as a supplement.

Enclosure A L-11-134 Page 18 of 27 The ElectricalCable Connections Not Subiect to 10 CFR 50.49 EQ Requirements Inspection is a new aging management activity (a one-time inspection) that will be conducted priorto the period of extended operation.

Enclosure A L-11-134 Page 19 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.11 Page B-55 "Enhancements" subsection In response to RAI 3.6-3, the Enhancements sub-section of Section B.2.11 of the LRA is replaced in its entirety to read:

Enhancements The followinq enhancement will be implemented in the identified program element prior to the period of extended operation.

• Scope The program will include high voltage connections to confirm the absence of aging effects for the metallic electrical connections.

Enclosure A L-11-134 Page 20 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.11 Pages B-55 & "Parameters Monitored or B-56 Inspected", "Detection of Aging Effects", and "Monitoring and Trending" subsections The "Parameters Monitored or Inspected", "Detection of Aging Effects", and "Monitoring and Trending" subsections of Section B.2.11 of the LRA are revised based on the responses to RAI B.2.11-1, B.2.11-3 and B.2.11-4, and now read:

Aging Management Program Elements

" Parameters Monitored or Inspected This one-time inspection will focus on the metallic parts of electrical cable connections. The inspection will include detection of loosened bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. A representative sample of electrical cable connections will be inspected.

Twenty percent of the electricalcable connection population, with a maximum of 25 connections, constitutes a representativesample size.

The following factors will be considered for sampling: connection type (e.g., bolted splices, bolted terminations, lug terminations, bolted cable terminations, connectors, and terminalblocks), circuit application (medium, or low voltage), circuit loading (high load), and physical location (e.g., high temperature, high humidity, vibration) with respect to connection stressors. The technic-l b-sis for the sample selected will be deGuiiented-. If an unacceptable condition or situation is identified in the sample, a determination is made as to whether the same condition or situation is applicable to other connections not tested. The inspection will confirm that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, chemical contamination, corrosion, vibration, or oxidation is not an aging effect that requires a periodic aging management program.

" Detection of Aging Effects A representative sample of the metallic electrical cable connections not subject to 10 CFR 50.49 environmental qualification requirements and within the scope of license renewal will receive a one-time inspection via thermography (augmented with optional contact resistance testing) prior to

Enclosure A L-11-134 Page 21 of 27 the period of extended operation. Twenty percent of the electrical cable connection population, with a maximum of 25 connections, constitutes a representativesample size. Thermography is a proven test method for detecting loose connections and degraded connections (i.e., chemical contamination, corrosion, oxidation) leading to increased resistance, and will be used to test a sample of electrical connections at a variety of plant locations. Thermography can detect aging effects due to thermal cycling, ohmic heating, vibration, and electrical transients. Thermography is an effective tool for inspecting connections that are covered by close fitting electrical tape, insulating boots or covers, heat-shrink material, and sleeving. The optional use of contact resistance testing of a sample of motor termination connections and other connections will also be utilized, as applicable. The one-time inspection provides additional confirmation that the electrical connections in the plant have not experienced general or repeated failures and that existing installation and maintenance practices are effective.

Monitoring and Trending No actions are taken as part of the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection to monitor or trend inspection results. This is a one-time inspection activity used to determine if, and to what extent, further actions, including monitoring and trending, may be required.

Sample size will be determined- by engineering evaluation, as de-scribed fer the Detect*on of Aging Eff*ece*lm

-ent abov.eo. Results of the inspection activities that require further evaluation or resolution (e.g., if degradation is detected), if any, will be evaluated using the Corrective Action Program, including expansion of the sample size and inspection locations to determine the extent of the degradation.

Enclosure A L-11-134 Page 22 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.20 Page B-87 "Program Description" subsection 1 st Paragraph In response to RAI B.2.20-1, B.2.20-2 and B.2.20-3, the Program Description subsection of LRA Section B.2.20, "Fuel Oil Chemistry Program," the 1 st paragraph, is replaced in its entirety to read:

Program Description The Fuel Oil Chemistry Program monitors and maintains fuel oil quality in order to mitigate damage due to loss of material, as well as due to cracking of susceptible materials, for the storage tanks and associated piping and components containinq fuel oil that are within the scope of license renewal The program includes verifying the quality of new fuel oil, periodic sampling of stored diesel fuel oil, and periodic cleaninq and inspection of the emergency diesel generatorfuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generator day tank. The Fuel Oil Chemistry Program manages the presence of contaminants, such as water or microbiologicalorganisms, that could lead to the onset and propagationof loss of material or crackinq (of susceptible material) through proper monitorinq and control of fuel oil contamination consistent with plant Technical Specifications and ASTM standards D975, D2276, D2709, D4057 and D4176. Exposure to these contaminants are minimized by a) verifying the quality of new fuel oil before it enters the storage tanks, b) periodic sampling of tank contents to ensure the fuel oil is free of water and particulates, and c) periodic cleaning and inspection of tanks containing fuel oil. Fuel oil tanks will be periodically drained (at least once every 10 years) for cleaning and will be visually inspected to detect potential degradation. If degradationis identified in a diesel fuel tank by visual inspections, a volumetric inspection will be performed. The Fuel Oil Chemistry Programis a mitigation program.

Enclosure A L-11-134 Page 23 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.20 Page B-88 "Enhancements" subsection In response to RAI B.2.20-1 and B.2.20-2, the Enhancements subsection of LRA Section B.2.20, "Fuel Oil Chemistry Program," is replaced in its entirety to read:

Enhancements The followinq enhancement will be implemented in the identified pro-gram element prior to the period of extended operation.

• Detection of Aging Effects Require that internal surfaces of emergency diesel generator fuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generator day tank are periodically drained (at least once every 10 years) for cleaning and are visually inspected to detect potential degradation. If degradationis identified in a diesel fuel tank by visual inspections, a volumetric inspection is performed.

Enclosure A L-11-134 Page 24 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.21 Page B-91 "Program Description" subsection In response to RAI B.2.21-1, the program title in the LRA is revised to read,,

"Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program." The program title is understood to change throughout the LRA, and the affected sections with a title change only are not presented in this letter.

The description in LRA Section B.2.21, "Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program," is replaced in its entirety to read:

Program Description The Inaccessible Power Cables Not Subiect to 10 CFR 50.49 Environmental Qualification Requirements Pro-qram will manage reduced insulation resistance of inaccessible power or underground cables (greater than or equal to 400 volt) that are exposed to significant moisture, such that there is reasonableassurance that the cables will perform their intended function in accordance with the current licensing basis through the period of extended operation.

Siqnificant moisture is defined as periodic exposure to moisture that lasts more than a few days (e.g., cable wetting or submergence in water).

In-scope, inaccessible power cables exposed to significant moisture will be 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, as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed. The frequency of testing will be established and adiusted based on test results and operating experience. Testing will be conducted at least once every 6 years, with initial testing to be completed prior to the period of extended operation.

In addition, manholes associated with inaccessible non-EQ power cables will be inspected for water accumulation and the water removed, as necessary. The frequency of inspections for accumulated water will be established and adjusted based on plant-specific inspection results, recognizing that the objective of the

Enclosure A L-11-134 Page 25 of 27 inspections, as a preventive action, is to keep the cables infrequently submerged, thereby minimizinq their exposure to siqnificant moisture. These inspections for water collection will be conducted at least annually and will also be performed in response to event-driven occurrences (such as heavy rain or flooding). The initial inspection will be completed prior to the period of extended operation.

The Inaccessible Power Cables Not Subiect to 10 CFR 50.49 Environmental Qualification Requirements Program is a new aging management program that will be implemented prior to the periodof extended operation.

Enclosure A L-11-134 Page 26 of 27 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.21 Page B-92 "Enhancements" subsection In response to RAI B.2.21-1 and B.2.21-3, the Enhancements subsection of LRA Section B.2.21, "Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program," is replaced in its entirety to read:

Enhancements The followinq enhancements will be implemented in the identified procgram element prior to the period of extended operation.

• Scope Include inaccessible underground lower service voltage cables (400VAC to 2kV).

Not use 'significant voltage' (defined as beinq subiected to system voltage for more than twenty-five percent of the time) as a criterion for inclusion into the program.

" PreventiveActions Include inspection of electrical manholes which contain power cables within the scope of the program.

Inspect electrical manholes at least once per year. The frequency of inspections for accumulated water will be established and adiusted based on plant-specific inspection results. Also, manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

Include a requirement in preventive maintenance activities PM 4297, PM 4294, PM 8025, and PM 4296 to generate a condition report in cases where in-scope inaccessible non-EQ power cable manhole inspection identifies submerged cables. Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities exist for inspection of water accumulation in the manholes associated with the in-scope inaccessiblenon-EQ power cables.

Enclosure A L-11-134 Page 27 of 27 Detection of Aging Effects Perform cable testing on a frequency of at least every 6 years. Testing will be evaluated for more frequent performance based on test results and operating experience.