ML061310139

Oyster Creek - Response to NRC Request for Additional Information, Dated April 20, 2006

ML061310139
Person / Time
Site:	Oyster Creek
Issue date:	05/09/2006
From:	Gallagher M AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
%dam200606, 2130-06-20327, TAC MC7624
Download: ML061310139 (42)

Text

_AmerGen,.

Michael P.Gallagher, PE Telephone 610.765.5958 An Exelon Company Vice President www.exeloncorp.com License Renewal Projects michaelp.gallagher@exeloncorp.com 10 CFR 50 AmerCen 10 CFR 51 200 Exelon Way 10 CFR 54 KSA/2-E Kennett Square, PA 19348 2130-06-20327 May 9, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

Response to NRC Request for Additional Information, dated April 20, 2006, Related to Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

Reference:

"Request for Additional Information for the Review of the Oyster Creek Nuclear Generating Station, License Renewal Application (TAC No. MC7624)," dated April 20, 2006 In the referenced letter, the NRC requested additional information related to Section 3.6.2 of the Oyster Creek Generating Station License Renewal Application (LRA). Enclosed are the responses to this request for additional information.

If you have any questions, please contact Fred Polaski, Manager License Renewal, at 610-765-5935.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on 0s-o- 6 Michael P. Gallagher Vice President, License Renewal AmerGen Energy Company, LLC

Enclosure:

Response to 04/20/06 Request for Additional Information 4114

U.S. Nuclear Regulatory Commission May 9, 2006 Page 2 of 2 cc: Regional Administrator, USNRC Region 1,w/o Enclosure USNRC Project Manager, NRR - License Renewal, Safety, w/Enclosure USNRC Project Manager, NRR - License Renewal, Environmental, w/o Enclosure USNRC Project Manager, NRR - OCGS, w/o Enclosure USNRC Senior Resident Inspector, OCGS, w/o Enclosure Bureau of Nuclear Engineering, NJDEP, w/Enclosure File No. 05040

Enclosures Response to 04/20/06 Request for Additional Information - Response to 4/20/06 Request for Additional Information, (8 pages) - Appendix A - RAI Response Impacts on License Renewal Application, (28 pages) - Summary of Commitments Associated With Response to April 20, Request for Additional Information, (3 pages) 9

Enclosure 1 Response to 4/20/06 Request for Additional Information Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

Page 1 of 8

RAI-3.6.2.2.5 Industry operating experience as discussed in Information Notice 93-95, identified the potential for loss of offsite power due to salt contamination of the switchyard insulators.

On March 17, 1993, Crystal River Unit 3 experienced a loss of the 230 kV switchyard (normal offsite power to safety-related busses) when a light rain caused arcing across salt-laden 230 kV insulators and opened breakers in switchyard. Since 1982, Pilgrim station has also experienced several loss of offsite power events when heavy ocean storms deposited salt on the 345 kV switchyard causing the insulator to arc to ground.

The applicant stated that an Incident on September 18, 2003 was considered a highly unusual weather condition that resulted in wind blown salty spray deposited on insulators causing flashing. The fact that industry operating experience has shown that the potential loss of offsite power due to salt contamination of switchyard insulators does exist for facilities that are near the sea coast where salt spray is prevalent, the staff requests the applicant to provide an aging management program (AMP) to manage the aging effects of insulator surface contamination due to salt deposits.

Reswonse:

For circuits within the scope of license renewal at voltages above 34.5 kV, Oyster Creek will implement visual inspections of high voltage insulators to manage the aging effects of salt build-up. The only circuits within the scope of license renewal that are in excess of 34.5 kV are on the high side of the transformers (Banks 9 and 10) that connect the Forked River Combustion Turbines to the 230 kV switchyard. High voltage insulators associated with these circuits will be included in this aging management program.

These inspections will be incorporated as a revision to the Periodic Monitoring of Combustion Turbine Power Plant - Electrical (B.1.37) aging management program. Inspections are to be performed using binoculars to a determined threshold for implementing corrective actions.

Corrective actions include subsequent cleaning (i.e., washing) of a contaminated insulator. The visual inspections will be performed on a twice per year frequency, beginning prior to the period of extended operation.

This response represents a change in Oyster Creek's approach to evaluating and managing the aging effects of salt build-up on high voltage insulators. Several Oyster Creek LRA sections and portions of the 10/12/2005 response to RAI 2.5.1.19 on the Station Blackout System are impacted by this change in approach. These changes are primarily shown on pages 3 through 12 of Appendix A to Enclosure 1. Also, changes to aging management review Tables 3.6.1 and 3.6.2.1.1 are shown within the Tables on pages 19 through 28 of Appendix A to Enclosure 1.

A commitment to perform these inspections will be included in LRA Appendix A, Table A.05 as part of license renewal commitment #43.

Page 2 of 8

RAI-3.6.2.2.6-1 Torque relaxation for bolted connections is a concern for transmission conductor connections. An electrical connection must be designed to remain tight and maintain good conductivity through a large temperature range. Meeting this design requirement is difficult if the material specified for the bolt and the conductor are different and have different rates of thermal expansion. For example, copper or aluminum bus/conductor materials expand faster than most bolting materials. If thermal stress is added to stresses inherent at assembly, the joint members or fasteners can yield. If plastic deformation occurs during thermal loading (i.e., heatup) when the connection cools, the joint will be loose. EPRI document TR-1 04213, "Bolted Joint Maintenance & Application Guide" recommends inspection of bolted joints for evidence of overheating, signs of burning or discoloration, and indication of loose bolts. The staff requests the applicant to provide a discussion why torque relaxation for bolted connection is not a concern for Oyster Creek Generating Station (OCGS).

Response

At Oyster Creek, the types of locking hardware used for the transmission conductor connections include Belleville washers and lock washers for lugged connections. There are also U-bolt clamp type cable connections that utilize a plate to hold the cable within the U of the bolt. These connections either used a lock washer with the nuts or another type of crown shaped locking nut in addition to the regular nut. As stated in the Oyster Creek LRA, preload of bolted connections is maintained by the appropriate design and use of lock and Belleville washers that provide vibration absorption and prevent loss of preload. This design is identified in EPRI TR-104213, Section 6.9 as a way to maintain preload. In a recent walkdown of license renewal in-scope transmission conductor connections, it was observed that the Belleville and lock washers were fully compressed and the crown shaped nuts for the u-bolt clamps, were flush against the regular nut. There is no Oyster Creek operating experience indicating any occurrence of loosening of transmission conductor connections. The connections at switchyard equipment, transformers (including the in-scope start-up and station blackout transformers), the start-up transformer regulators and disconnect switches are also periodically evaluated via thermography performed as preventive maintenance. There is no operating experience from this monitoring that indicates occurrences of loosening transmission conductor connections. Therefore, based on the design in accordance with EPRI TR-104213, periodic monitoring through existing preventative maintenance and no adverse Oyster Creek related operating experience, it is concluded that there are no additional evaluations or actions required to address the aging mechanism of torque relaxation for bolted connections for transmission conductors.

RAI-3.6.2.2.6-2 The staff requests the applicant to compare the Ontario Hydroelectric study to Oyster Creek.

Response

Section 3.6.2.2.6 of the OCGS LRA discusses the Ontario Hydroelectric study regarding high voltage transmission conductor strength. The following is offered as a comparison of this study Page 3 of 8

to the Oyster Creek in-scope electrical conductors.

Loss of transmission conductor strength due to corrosion is an applicable aging effect; however, ample design margin ensures that corrosion is not significant enough to impact Oyster Creek's transmission conductor intended function (i.e., conducting electricity). Oyster Creek transmission conductors are ACSR (aluminum conductor steel reinforced). These are conductors that are constructed of aluminum strands around a steel core. No organic materials are involved. The most prevalent mechanism contributing to loss of conductor strength of an ACSR transmission conductor is corrosion, which includes corrosion of the steel core and aluminum strand pitting.

For ACSR transmission conductors, degradation begins as a loss of zinc from the galvanized steel core wires.

There is a set percentage of composite conductor strength established at which a transmission conductor is replaced. The National Electrical Safety Code (NESC) requires that tension on installed conductors be limited to a maximum of 60% of the ultimate conductor strength. The NESC also sets the maximum tension a conductor must be designed to withstand under various load requirements, which includes consideration of ice, wind and temperature. Therefore, for a typical transmission conductor, there is ample design margin to offset the loss of strength due to corrosion and maintain the transmission conductor intended function through the extended period of operation.

The Ontario Hydroelectric tests document a 30% loss of composite conductor strength for an 80-year-old transmission conductor due to corrosion. The EPRI License Renewal Electrical Handbook calculated an ultimate strength margin of 37% for a 4/0 ACSR transmission conductor based on the Ontario Hydroelectric study and the National Electrical Safety Code (NESC). A 4/0 ACSR conductor has an ultimate strength to NESC heavy load tension ratio of 67% (i.e., the ratio of 8350 lbs. (ultimate strength) minus 2761 lbs. (heavy load design tension strength), to 8350 lbs. (ultimate strength)). Deducting the 30% loss of composite conductor strength determines the ultimate strength margin of 37%.

The same methodology successfully applies for the Oyster Creek transmission conductors.

Oyster Creek license renewal in-scope ACSR transmission conductors have a minimum size of 397.5 ACSR. Oyster Creek license renewal in-scope transmission conductors are specified and installed in accordance with NESC. It is conservative to assume the same 80-year 30% loss of composite conductor strength for Oyster Creek transmission conductors since the Ontario Hydroelectric tests were for a conservative heavy loading zone. A 397.5 ACSR conductor has a minimum ultimate strength of 9900 lbs. Applying NESC requirements for maximum design line loadings accounting for wind and ice (<60%) and initial unloaded tension limits (<35%) the 397.5 ACSR conductors have a minimum heavy load tension ratio of 65%, (ratio of 9900 minus 3465 lbs to 9900). When deducting the conservative assumed 30% loss of composite conductor strength, the bounding ultimate resulting strength margin is 35%. This minimum strength margin for Oyster Creek transmission conductors is sufficient such that wind loading and fatigue are not applicable aging mechanisms that will affect the intended function of transmission conductors at Oyster Creek.

RAI-3.6.2.3.1 -1 In LRA Section 3.6.2.3.1, the applicant stated that "These panels are not located in adverse localized areas of high temperature or humidity. These rooms are protected from weather variations and are not subject to significant temperature variations." The staff requests the applicant to explain how these rooms are protected from weather variations.

Page 4 of 8

Response

The in-scope fuse holders that are not part of a larger assembly at Oyster Creek are the scram solenoid valve fuse holders located in panels ER7A, ER7B, ER7C, ER7D, ER7E, ER7F, ER7G and ER7H. These panels are located inside the power block, in the Reactor Building, on elevation 23'6". The environment in the Reactor Building is controlled within design limits by the Reactor Building Heating and Ventilation System and is not subject to significant temperature variations. Weather does not create an adverse environment nor an aging stressor for the fuse holders.

RAI- 3.6.2.3.1-2 In LRA Section 3.6.2.3.1, the applicant indicated that "With regard to internal moisture (i.e., formation of condensation), a walkdown revealed no signs of moisture/humidity in the area, or any sign of moisture within the enclosure." The staff requests the applicant to provide details about the walkdown (number of fuse holders inspected and condition of the fuse holders, etc.).

Response

A walkdown was performed of the eight fuse panels (ER7A, ER7B, ER7C, ER7D, ER7E, ER7F, ER7G and ER7H) within the scope of license renewal. There were no signs of moisture/humidity in the areas where the fuse panels are located. The eight fuse panels in the scope of license renewal were walked down including visual inspection of the panels' internal and external condition and the contained fuse holders. There were no signs of moisture or corrosion on the exterior or interior of the enclosures. All of the fuse holders within each of the eight in-scope fuse panels were visually inspected (roughly 300 fuse holders). There were no observable signs of fuse holder fatigue or strain. Two chipped fuse blocks (Bakelite dielectric material) were identified, entered into the Oyster Creek corrective action process and evaluated as insignificant and non-impacting with respect to the fuse block function in that the Bakelite still provides adequate separation such that there is no immediate concern for dielectric breakdown.

RAI 3.6.2.3.1-3 In the LRA Section 3.6.2.3.1, the applicant stated that "SCRAM solenoid fuses are not subject to frequent manipulations. When these circuits need to be de-energized, power is removed at the safety-related power supplies. When manipulated an inspection is performed... ". The staff requests that the applicant discuss the disconnection means at the safety-related power supplies. Also, discuss how often the fuses are manipulated and the reason for this manipulation.

Response

The safety related power supplies for these circuits are the Reactor Protection System (RPS) power supplies. The RPS power is supplied through two independent buses (Protection System Panels No. 1 and 2, PSP-1 and PSP-2 ) Each panel supplies power to one logic channel and its respective pilot and backup scram valve solenoids, one half of the incore flux amplifiers, one half of the steam line radiation monitors, and one half of the flux amplifiers. A single breaker, on each panel, powers the scram solenoids and logic system. Clearances are applied at this Page 5 of 8

breaker for circuit de-energization. Routine RPS testing does not include de-energization of scram solenoid circuits. Isolation is accomplished via the valve air supply. The scram solenoid fuses are only removed when corrective maintenance is required (estimated at once in a 15 year time span). Manipulation of these fuses would only occur during required corrective maintenance or when replacing a blown fuse. Fuse control procedure CC-AA-206 provides instruction for fuse replacements to ensure:

- continuity

- tightness and condition (no cracks) of end caps

- no corrosion

- proper installation

- tightness of clips

- firm contact with fuse end caps.

RAI- 3.6.2.3.2 In LRA Section 3.6.2.3.2, the applicant stated that "Because of the non-EQ electrical penetrations are the same as the EQ electrical penetrations, and the EQ penetrations have been shown to have a qualified life of 60 years, Amergen concludes that non-EQ electrical penetrations are also qualified for a 60-year life." The staff requests that the applicant confirm that non-EQ electrical penetrations will be exposed to same environment as the EQ penetrations.

Response

EQ and non-EQ electrical penetrations are exposed to marginally different environments (i.e.,

temperature and radiation dose) based on the environmental conditions throughout Containment and Reactor Building elevations. Even though these environments are marginally different, the environmental qualification evaluation that was performed for EQ electrical penetrations is bounding in that it encompasses all of the environmental limits to which both EQ and non-EQ electrical penetrations are exposed.

Environmental Qualification (EQ) File OC 303 'General Electric - Electrical Penetrations Type F01 provides the justification for the environmental qualification of electrical penetrations for 60 years. EQ File OC 303 Sections SRS A-5 (Thermal Aging) and SRS A-6 (Radiation) evaluated the worst case environment for the electrical penetrations based on a review of AmerGen (GPU)

Standard ES-027, "Environmental Parameters - Oyster Creek NGS". The EQ and non-EQ electrical penetrations are for electrical circuits as they go from the reactor building to the drywell and thus exist in both reactor building and the drywell environments. A review of the EQ zones as identified in ES-027, controlled plant drawings and PIMS Component Record List (CRL) information identified that the highest EQ and non-EQ electrical penetrations are approximately at an elevation of 48'. EQ File OC 303 used ES-027 Drywell (primary containment) EQ Zone I environmental conditions, up to an elevation of 55') that envelopes all electrical penetrations with a maximum temperature of 1390 F and normal radiation (30.E06 Gamma) for 60 years. This temperature and radiation dose bound the environments for Drywell and Reactor Building locations for both EQ and non-EQ electrical penetrations. The evaluation concluded that the EQ Electrical Penetrations are qualified for 60 years and, therefore, the non-EQ penetrations are also qualified. Note that the non-EQ electrical penetrations are not required to function during design base accidents, thus providing additional margin.

Page 6 of 8

RAI- 3.6.2.3.3 In LRA Section 3.6.2.3.3, under the heading "Thermal Cycling, Ohmic Heating and Electrical Transients," the applicant stated that "At Oyster Creek, power supply cables are typically installed in a continuous run from the supply, e.g., switchgear, to the load, e.g., motor. The metallic parts of connections to the supply and load are therefore part of, or internal to, active components, e.g., the switchgear and motor, and therefore not subject to aging management." The AMP XI-E6, "Electrical Cable Connections not Subject to 10 CFR 50.49 Environmental Qualification Requirements" of NUREG-1 801, Rev.

1 specified that connections associated with cables within the scope of license renewal are part of this program, regardless of their association with active or passive components. Also, refer to pages 107, 256 and 257 of NUREG - 1833, "Technical Bases for Revision to the License Renewal Guidance Documents," for additional information regarding AMP XI-E6. The staff requests that the applicant provide an AMP with the ten elements.

Response

Oyster Creek will develop and implement an aging management program that will manage the aging effects (i.e., loosening of metallic connections) of electrical connections, including those associated with active components. A representative sample of electrical connections will be tested. Sampling will be based on technical evaluation of the application (high, medium and low voltage), circuit loading, and location with respect to connection stressors. The program to be implemented will use thermography, on a 10-year frequency and will be implemented prior to the period of extended operation.

This response represents a change in Oyster Creek's approach to evaluating and managing the aging effects on electrical cable connections - metallic parts. Several Oyster Creek LRA sections are impacted by this change in approach. These changes are shown on pages 13 through 18 of Appendix A to Enclosure 1. Also, changes to aging management review Tables 3.6.1 and 3.6.2.1.1 are shown within the Tables on pages 19 through 28 of Appendix A to Enclosure 1.

A commitment to implement this new aging management program will be included in LRA Appendix A, Table A.05 as new commitment #64.

RAI- 3.6.2.3.4 In LRA Section 3.6.2.3.4, the applicant stated that "Ground connections are commonly made with welds or compression type connectors, which Include compression-, bolted-,

and wedge-type devices." Torque relaxation for bolted connections is a concern for ground connections. An electrical connection must be designed to remain tight and maintain good conductivity through a large temperature range. Meeting this design requirement Is difficult if the material specified for the bolt and the conductor are different and have different rates of thermal expansion. For example, copper or aluminum conductor materials expand faster than most bolting materials. If thermal stress is added to stresses inherent at assembly, the joint members or fasteners can yield. If plastic deformation occurs during thermal loading (i.e., heatup) when the connection cools, the joint will be loose. EPRI document TR-1 04213, "Bolted Joint Maintenance & Application Guide" recommends inspection of bolted joints for evidence of overheating, signs of burning or discoloration, and Indication of loose bolts. The staff requests that the Page 7 of 8

applicant provide a discussion why torque relaxation for bolted connection is not a concern for OCGS.

Response

Oyster Creek's ground connections do not experience thermal stresses from the environment or operating conditions. Environmental temperature changes experienced by ground conductors and connections are extremely gradual, reflective of gradual weather or environmentally induced temperature changes. Ground conductors and connections normally see no current. Under fault conditions, current flow would exist for a very brief period of time and as such would not result in ohmic heating nor related current induced thermal stresses. As such, these connections do not experience thermal stresses necessary to affect the bolted connections in ground connections.

As stated in LRA sections 3.6.2.1.8 and 3.6.2.3.4, the material used for ground conductors is copper. Copper is a good material choice due to its high resistance to corrosion.

Page 8 of 8

Enclosure 1 - ADpendix A RAI Response Impacts on License Renewal Application Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

Page 1 of 28

Enclosure 1 - Appendix A Description of Contents Page Numbers Changes Associated with RAI 3.6.2.2.5 Description of LRA Text Changes 3 -4 LRA Appendix A Table A.05 Revisions 5 Appendix A, Section A.1.37 Revisions 6 Appendix B, Section B.1.37 Revisions 7 - 12 Changes Associated with RAI 3.6.2.3.3 Description of LRA Text Changes 13 LRA Appendix A Table A.05 Addition 14 Appendix A, Section A.1.40 Addition 15 Appendix B, Section B.1.40 Revisions 16- 18 Changes Associated with RAls 3.6.2.2.5 and 3.6.2.3.3 LRA Table 3.6.1 Revisions 19 - 22 LRA Table 3.6.2.1.1 Revisions 23 - 28 Page 2 of 28

LRA Text Changes Associated With RAI 3.6.2.2.5 Note: Changes to previously submitted information and new information are designated by text bolding. Existing LRA text is identified by italics.

In Section 3.6.2.1.3 of the Oyster Creek LRA the sentence addressing "Aging Effects Requiring Management" is revised to read:

The following aging effects associated with the High Voltage Insulators require aging management:

- Salt build-up on the insulator surface.

The following is added as the first sentence of the Section addressing "Aging Management Programs:"

The following aging management program manages the aging effects for the High Voltage Insulators:

- Periodic Monitoring of the Combustion Turbine Power Plant - Electrical.

In Section 3.6.2.2.5 of the Oyster Creek LRA, several paragraphs are affected. The following is replacement text for the discussions following headers of

- Dearadation of Insulator Quality due to Presence of Any Salt Deposits and Surface Contamination: and Loss of Material due to Mechanical Wear

- Salt Deposits, and

- Conclusions.

No changes are required for text following headers for

- Contamination

- Wear.

Degradation of Insulator Qualit due to Presence of Any Salt Deposits and Surface Contamination: and Loss of Material due to Mechanical Wear Degradation of insulator quality due to presence of any salt deposits and surface contamination and loss of material due to mechanical wear caused by wind blowing on transmission conductors could occur in high voltage insulators. NUREG- 1801 recommends further evaluation of a plant-specific aging management program to ensure that this aging effect is adequately managed.

For the reasons described below, Oyster Creek will manage the aging effect of salt build-up on the surface of High Voltage Insulators via the Periodic Monitoring of the Combustion Turbine Power Plant - Electrical aging management program. (B.1.37)

For the reasons described below, Oyster Creek requires no aging management activities associated with non-saff surface contamination or wear on high voltage insulators for the extended period of operation.

Page 3 of 28

Salt Deposits Arcing leading to loss of offsite power has occurred at power plants located on sea coasts. Prevention of the problem is possible with lubricants on the insulators and may be appropriate for plants that experience the problem relatively regularly.

Weather - related occurrences of arcing due to salt deposition leading to loss of offsite power have been documented in SOER 02-1, Severe Weather, and NRC IN 93- 95, Storm - Related Loss of Offsite Power Events Due to Salt Buildup on Switchyard Insulators.

On September 18, 2003, arcing was observed on 230kV insulators in the Oyster Creek Switchyard. The arcing was not severe enough to cause ground faults. No protective relaying was actuated (CAP No. 02003-1925). The observations made in the switchyard are consistent with salt spray on the insulators. This resulted from the unusual weather conditions experienced during the passing of hurricane Isabel. The high winds and waves resulted in wind blown salty spray being deposited on the insulators. The electrical conductivity of the salty moisture on the insulators caused the observed flashing. The subsequent rains washed the salt from the insulators and eliminated the problem. Oyster Creek has not experienced a repeat occurrence of this event and has not experienced any arcing leading to loss of offsite power events attributable to salt contamination.

AmerGen will include in its Periodic Monitoring of the Combustion Turbine Power Plant - Electrical aging management program visual inspection of in-scope high voltage insulators above 34.5 kV for salt build-up.

Conclusion For these reasons, AmerGen will Include in its Periodic Monitoring of the Combustion Turbine Power Plant - Electrical aging management program visual Inspection of In-scope high voltage insulators above 34.5 kV for salt build-up. No aging management activities associated with non-salt surface contamination or wear on high voltage insulators are required for the extended period of operation of Oyster Creek.

Table 3.6.1, Summary of Aging Management Programs, line item 3.6.1-11 requires revision.

Table 3.6.2.1.1, Electrical Commodity Groups, Summary of Aging Management Evaluation, information for the component type of high voltage insulators requires revision. A complete printout of these tables is provided at the end of this Appendix incorporating revisions for high voltage insulators and electrical cable connections - metallic parts.

An update to LRA Appendix A (Table A.05 commitment number 43 and new Section A.1.37) and Appendix B (new Section B.1.37 for the Periodic Monitoring of the Combustion Turbine Power Plant - Electrical) were submitted as part of the 10/12/05 AmerGen response to RAI 2.5.1.19-1.

This information is revised to include the periodic monitoring (visual inspection) of in-scope high voltage insulators above 34.5 kV. The revised text is as follows.

Page 4 of 28

License Renewal Commitment List The item in the table below updates item 43 in the 10/12/2005 response to RAI 2.5.1.19-1. Revisions are bolded.

UFSAR ITEM NUMBER COMMITMENT SUPPLEMENT ENHANCEMENT SOURCE LOCATION OR (LRA APP. A) IMPLEMENTATION SCHEDULE A new plant specific program is credited. The program A.1.37 Prior to the period of Section will be used in conjunction with the existing Structures extended operation B.1.37 Monitoring Program and the new Inaccessible Medium Voltage Cables Not Subject to 10CFR50.59 Environmental Qualification Requirements program to manage aging effects for the electrical commodities that support FRCT operation. The Program consists of visual

43) Periodic inspections of accessible electrical cables and Monitoring of connections exposed in enclosures, pits, manholes and Combustion Turbine pipe trench; visual inspection for water collection in Pombustion Tu e manholes, pits, and trenches, located on the FRCT site, ower lan - for inaccessible medium voltage cables; visual inspection Electrical of accessible phase bus and connections and phase bus insulators/supports; and visual inspection of high voltage insulators above 34.5 kV for salt build-up.

The new program will be performed on a twice per year frequency for high voltage insulator inspections; on a 2-year interval for manhole, pit and trench inspections; on a 5-year frequency for phase bus inspections; and on a 10-year interval for cable and connection inspections.

Page 5 of 28

A.1.37 Periodic Monitoring of Combustion Turbine Power Plant - Electrical (Revisions are bolded)

The new Periodic Monitoring of Combustion Turbine Power Plant - Electrical Program will be used in conjunction with the existing Structures Monitoring Program and the new Inaccessible Medium Voltage Cables Not Subject to 10CFR5O.49 Environmental Qualification Requirements program to manage aging effects for the electrical commodities that support Forked River Combustion Turbine (FRCT) operation. The Program consists of visual inspection of accessible electrical cables and connections exposed in enclosures, pits, manholes, and pipe trench for embrittlement, discoloration, cracking or surface contamination; visual inspection of manholes, pits and cable trenches, located on the FRCT site, for inaccessible medium voltage cables, for water collection; visual inspections of accessible phase bus and connections and phase bus insulators for melting or other signs of heat effects on the tape covering bus connections, cracking of thermoplastic, or degradation of insulators; and visual inspection of high voltage insulators above 34.5 kV for salt build-up. Phase Bus Enclosures will be inspected by the existing Structures Monitoring Program for signs of corrosion. The inaccessible medium voltage cables circuits supporting the FRCT, and the associated manholes, pits and trenches located on the Oyster Creek site, will be tested or inspected by the new Inaccessible Medium Voltage Cables Not Subject to 10CFR5O.49 Environmental Qualification Requirements program for signs of insulation degradation and for prevention of wetted environments. The new combustion turbine power plant - electrical program will be implemented prior to the period of extended operation. Manhole, pit and trench inspections for manholes, pits and trenches located on the FRCT site will be performed at least once every 2 years for accumulation of water, and the frequency will be adjusted based on the results obtained. Cable and connection inspections will be implemented prior to the period of extended operation with a frequency of at least once every 10 years. Accessible phase bus and connection and phase bus insulator inspections will be performed at least once every 5 years. Visual inspections of high voltage insulators will be performed at least twice per year. Phase bus enclosure inspections will be performed at the frequency specified in the Structures Monitoring Program. Inaccessible medium voltage cable circuits and the associated manhole, pit and trench tests and inspections for the manholes, pits and trenches located on the OC site will be performed at the frequency specified in the Inaccessible Medium Voltage Cables Not Subject to 10CFR50.49 Environmental Qualification Requirements program.

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B.1.37 Periodic Monitoring of Combustion Turbine Power Plant - Electrical (Revisions are bolded)

Program Description The new AmerGen Periodic Monitoring of Combustion Turbine Power Plant - Electrical Program, the existing Structures Monitoring Program, and the new Inaccessible Medium Voltage Cables Not Subject to 10CFR50.49 Environmental Qualification Requirements program will be used to manage aging effects for the electrical commodities that support FRCT operation.

This AmerGen program will include elements of GALL programs XL.E1 for accessible electrical cables and connections; XI.E3 for manholes, pits and cable trenches; and XI.E4 for phase bus and connections and phase bus insulators, as well as visual inspections of in-scope high voltage insulators above 34.5 kV.

This AmerGen program will inspect accessible electrical cables and connections, prior to the period of extended operation, with an inspection frequency of at least once every 10 years.

This AmerGen program will inspect manholes, pits and cable trenches, containing inaccessible medium voltage cables, located on the FRCT site, for inaccessible medium voltage cables, for water collection so that draining or other corrective actions can be taken. Inspections for water collection will be performed at least once every 2 years and the frequency of inspection will be adjusted based on the results obtained. The first inspections will be completed prior to the period of extended operation.

This AmerGen program will inspect accessible phase bus and connections and phase bus insulators, prior to the period of extended operation, with an inspection frequency of at least once every 5 years.

This AmerGen program will also inspect in-scope high voltage insulators above 34.5 kV for salt build-up, with an inspection frequency of twice per year. The first inspections will be completed prior to the period of extended operation.

Inspection of phase bus enclosures will be performed under the existing Structures Monitoring Program, B.1.31. The first inspection will be performed prior to the period of extended operations, with an inspection frequency of at least 4 years.

The following represents AMP B.1.36 scope for the 13.8 kV cables that distribute the output of the FRCT to both the Oyster Creek SBO transformer and the 230 kV switchyard. Inaccessible medium voltage cable circuits supporting the FRCT and the associated manholes, pits and trenches located on the Oyster Creek site will be tested or inspected by the new Inaccessible Medium Voltage Cables Not Subject to 10CFR50.49 Environmental Qualification Requirements program, B.1.36. The first tests and inspections will be performed prior to the period of extended operations, with a cable test frequency of at least 10 years and a manhole, pit and trench inspection frequency of at least 2 years.

These aging management activities ensure the continued availability of the FRCTs as the alternate AC source in the event of a SBO at OCGS.

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Aging Management Program Elements (Other than headings, bolded text indicates changes)

(1) Scope of Activity: The scope of this aging management program (AMP) includes electrical commodities that are subject to aging management. The electrical commodities necessary for the FRCTs to provide alternate AC power to OCGS during a SBO and subject to aging management are:

• Insulated Cables and Connections (XI.E1)

• Inaccessible Medium Voltage Cables (XI.E3)

• Phase Bus and Connections (XI.E4)

• In-scope High Voltage Insulators above 34.5 kV

• Phase Bus Enclosure Assemblies (Structures Monitoring, XL.S6)

• Phase Bus Insulators (XI.E4)

This AMP provides reasonable assurance that aging effects for these commodities will be adequately managed, such that the FRCTs are available to perform their intended function for the extended period of Oyster Creek operation.

(2) Preventive Actions:

• There are no preventative actions associated with accessible electrical cables and connections.

• The inspection and drainage of manholes, pits and cable trenches under this AMP assist in preventing the premature aging of electrical cables.

• There are no preventative actions associated with phase bus and connections and phase bus insulators.

• The inspection and washing of in-scope high voltage insulators above 34.5 kV under this AMP assist in preventing faults on high voltage circuits.

(3) Parameters Monitored/inspected: This AMP includes the following activities:

• Accessible Electrical Cables and Connections:

Visual inspection of accessible electrical cables and connections exposed in enclosures, pits, manholes, and pipe trench will be performed by AmerGen.

These inspections will be performed for signs of accelerated age-related degradation such as embrittlement, discoloration, cracking or surface contamination. The scope of this inspection includes accessible power, control and instrumentation cables. The first inspection will be performed prior to the period of extended operation, with an inspection frequency of at least 10 years.

• Inaccessible Medium Voltage Cables Visual inspections of manholes, pits and pipe trench, located on the FRCT site, for inaccessible medium voltage cables, will be performed by AmerGen.

Page 8 of 28

These inspections will be performed for evidence of excessive water collection. Inspections for water collection will be performed at least once every 2 years and the frequency of testing will be adjusted based on the results obtained. The first inspections will be completed prior to the period of extended operation.

• Phase Bus and Connections and Phase Bus Insulators/Supports Visual inspections of accessible phase bus and connections and phase bus insulators/supports will be performed by AmerGen. These inspections will be performed for signs of melting or other heat effects on the tape covering bus connections, cracking of thermoplastic or degradation of insulators/supports.

The first inspection will be performed prior to the period of extended operations, with an inspection frequency of at least 5 years.

• High Voltage Insulators Visual inspection of the in-scope high voltage insulators above 34.5 kV will be performed by AmerGen. These inspections will be performed for signs of salt build-up. The first inspection will be performed prior to the period of extended operations, with an inspection frequency of at least twice per year.

• Phase Bus Enclosure Assemblies Visual inspection of the phase bus enclosure assemblies will be performed by AmerGen, under the Structures Monitoring Program, B.1.31. These inspections will be performed for signs of general corrosion or loss of weather tightness. The first inspection will be performed prior to the period of extended operations, with an inspection frequency of at least 4 years.

• Inaccessible Medium Voltage Cable Circuits Testing of inaccessible medium voltage cable circuits supporting the FRCT and inspection of the associated manholes located on the Oyster Creek site will be performed by AmerGen, under the Inaccessible Medium Voltage Cables Not Subject to 10CFR50.49 Environmental Qualification Requirements program, B.1.36. These inspections will be performed for signs of cable insulation degradation and prevention of wetted environments.

The first cable tests will be performed prior to the period of extended operations, with a test frequency of at least 10 years. The first manhole, pit and trench inspections will be performed prior to the period of extended operations, with an inspection frequency of at least 2 years.

(4) Detection of Aging Effects: The AmerGen inspection of electrical commodities described above will ensure that aging effects on cables and phase bus are detected prior to loss of intended function.

Page 9 of 28

• Accessible Electrical Cables and Connections:

Conductor insulation aging degradation from heat or moisture in the presence of oxygen causes cable and connection jacket surface anomalies. Accessible electrical cables and connections in at the FRCT are visually inspected for cable and connection jacket anomalies, such as embrittlement, discoloration, cracking or surface contamination. Accessible electrical cables and connections will be performed prior to the period of extended operation and inspected at least once every 10 years.

• Inaccessible Medium Voltage Cables The actions under this program addressing inaccessible medium voltage cables are preventative only.

• Accessible Phase Bus and Connections and Phase Bus Insulators/Supports Bolted connections will be checked for loose connection by performing visual inspections for aging degradation of insulating materials and for foreign debris and excessive dust build-up, and evidence of moisture intrusion. Bus insulations will be visually inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation. Bus supports will be inspected for structural integrity and signs of cracks. The program will be completed prior to the period of extended operation and every 5 years thereafter.

• High Voltage Insulators In-scope high voltage insulators above 34.5 kV will be checked for salt build-up by performing visual inspections. If contamination is Identified, the inspections will distinguish between slight, medium and heavy levels of contamination based on the lack of a shiny surface appearance (slight); build-up of contamination at the base of the insulators or indication of dripping (medium); or audible noise or visible corona (heavy). Inspections will begin prior to the period of extended operation and occur twice a year thereafter.

(5) Monitoring and Trending:

• Monitoring of electrical commodities involves visual inspection activities by qualified individuals, at specified intervals, to determine the condition of the cables and connections.

• Monitoring of electrical commodities involves visual inspection activities by qualified individuals, at specified intervals, to determine if there is standing water in manholes, pits and trenches.

• Monitoring of electrical commodities involves visual inspection activities by qualified individuals at specified intervals to determine the condition of phase bus.

• Monitoring of electrical commodities Involves visual Inspection activities by qualified individuals at specified intervals to determine if there is salt build-up on the insulators.

Page 10 of 28

Results of inspections performed by both FirstEnergy, under their routine activities, and AmerGen, under this new program are reviewed by OCGS engineering as part of confirmation and monitoring the reliability of the FRCTs.

(6) Acceptance Criteria: Acceptance criteria for the electrical commodity inspections are as follows:

• Accessible Electrical Cables and Connections:

The accessible cables and connections are to be free from unacceptable, visual indications of surface anomalies, which suggest that conductor insulation or connection degradation exists.

• Inaccessible Medium Voltage Cables Manholes, pits, and cable trenches are to be free from standing water.

• Accessible Phase Bus and Connections and Phase Bus Insulators/Supports Phase bus is to be free from unacceptable visual indications of surface anomalies, suggesting conductor insulation degradation exists.

• High Voltage Insulators High voltage insulators are to be free from salt build-up. If contamination is identified, the Inspections will distinguish between slight, medium and heavy levels of contamination based on the lack of a shiny surface appearance (slight); build-up of contamination at the base of the insulators or indication of dripping (medium); or audible noise or visible corona (heavy). Subsequent corrective actions will be aligned with the level of contamination.

(7) Corrective Action: If an inspection identifies a degraded condition, a Corrective Action Program Issue Report will be initiated in accordance with 10 CFR Part 50, Appendix B plant administrative procedures. The degraded condition will be evaluated and corrective actions are taken as necessary. The 10 CFR Part 50 Appendix B corrective action program ensures that conditions adverse to quality are properly corrected. If the deficiency is found to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude recurrence.

(8) Confirmation Process: Site quality assurance procedures, review and approval processes and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.

(9) Administrative Controls: See Item 8 above.

(10) Operating Experience: While this is a new program, FRCT has not experienced a cable or bus related failure during its period of operation.

The 2004 inspection involved major rework and repair of the exhaust plenum after and forward walls, including complete rebuild and re-wiring of the load compartment and junction boxes, and extensive alignment activities. These major efforts ensured that the FRCT cables and connections were in optimal condition when returned to Page 11 of 28

service. Lessons learned from routine inspections are incorporated into future outage scope.

On September 18, 2003, arcing was observed on 230kV insulators in the Oyster Creek Switchyard. This event was entered and evaluated in the Oyster Creek corrective action process (CAP No. 02003-1925). The arcing was not severe enough to cause ground faults. No protective relaying was actuated. There was no associated loss of offsite power to Oyster Creek. The observations made in the switchyard are consistent with salt spray on the insulators. This occurrence was the result of unusual weather conditions experienced during the passing of hurricane Isabel. The high winds and waves resulted in wind blown salty spray being deposited on the insulators. The electrical conductivity of the salty moisture on the insulators caused the observed flashing. Oyster Creek has not experienced any arcing leading to loss of offsite power events attributable to salt contamination.

Enhancements:

None.

==

Conclusion:==

The Periodic Monitoring of Combustion Turbine Power Plant - Electrical Program will effectively manage the aging of insulated cables and connections; inaccessible medium voltage cables; and phase bus and connections and phase bus insulators; high voltage insulators; and phase bus enclosures such that there is reasonable assurance that the intended functions of the FRCTs will be maintained consistent with the current licensing basis during the period of extended operation.

Page 12 of 28

LRA Text Changes Associated With RAI 3.6.2.3.3 Note: Changes to previously submitted information and new information are designated by text bolding. Existing LRA text is identified by italics.

The second to last paragraph in the "Electrical Systems and Components" section of LRA Section 2.1.6.1, Identification of Structures and Components Subject to AMR, requires revision.

This paragraph currently identifies that electrical components that are part of a larger active component are screened out. This paragraph should be revised to read:

The electrical components that require an aging management review are the separate electrical components that are not a part of a larger active component. For example, the wiring and terminal blocks located internal to a breaker cubicle were considered to be parts of the breaker. Accordingly, the breaker is screened, but not the individual internal parts. The only exception to this screening criteria is the consideration of electrical cable connections, metallic parts, for inclusion in the population of connections to be sampled and subsequently tested per the GALL aging management program XL.E6 (corresponding to Oyster Creek aging management program B.1.40).

In section 3.6.2.1.7 of the Oyster Creek LRA sentences following two subheadings require revision. The sentence addressing "Aging Effects Requiring Management' is replaced as follows:

The following aging effects associated with the high voltage Insulators require aging management:

- Loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

The first sentence of the section addressing "Aging Management Programs" should read:

The following aging management program manages the aging effects for electrical cable connections - metallic parts:

- Electrical Cable Connections - Metallic Parts - Not Subject toto CFR 50.49 Environmental Qualification Requirements.

Section 3.6.2.3.3 shall have all text deleted and shall be retitled: "Not Used". Further Evaluation of this electrical commodity is not required per NUREG-1 801, Table VI Electrical Components, item number Vl.A-1 (LP-12).

Table 3.6.1, Summary of Aging Management Programs, line item 3.6.1-13 requires revision.

Table 3.6.2.1.1, Electrical Commodity Groups, Summary of Aging Management Evaluation, information for the component type of cable connections (metallic parts) requires revision. A complete printout of these tables is provided at the end of this appendix incorporating revisions for changes for high voltage insulators and electrical cable connections - metallic parts.

Updates showing the impacts of this change on LRA Appendix A (Table A.05 and new section A.1.40) and LRA Appendix B (new section B.1.40) are provided below. No bolding of text details is used since the entries are new in their entirety.

Page 13 of 28

A.5 License Renewal Commitment List The item in the table below is a new commitment submitted as part of the response to RAI 3.6.2.3.3 All column entries associated with this new commitment are new additions.

UFSAR ITEM NUMBER COMMITMENT SUPPLEMENT ENHANCEMENT SOURCE LOCATION OR (LRA APP. A) IMPLEMENTATION SCHEDULE The Electrical Cable Connections - Metallic Parts - Not A.1.40 Prior to the period of Section Subject to 10 CFR 50.49 Environmental Qualification extended operation B.1.40 Requirements aging management program is a new program that will be used to manage the aging effects of

64) Electrical Cable metallic parts of non-EQ electrical cable connections

6) Eectrica C during the period of extended operation. A Metallic Parts - Not representative sample of non-EQ electrical cable Subject to 1s0 CFR connections will be selected for testing considering 50.49 Environmental application (high, medium and low voltage), circuit Qualification loading and location, with respect to connection Requirements stressors. The type of test to be performed, i.e.,

thermography, is a proven test for detecting loose connections. A representative sample of non-EQ cable connections will be tested at least once every 10 years.

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

Page 14 of 28

A.1.40 Electrical Cable Connections - Metallic Parts - Not Subiect to 10 CFR 50.49 Environmental Qualification Requirements The Electrical Cable Connections - Metallic Parts - Not Subject to 10 CFR 50.49 Environmental Qualification Requirements aging management program is a new program that will be used to manage the aging effects of metallic parts of non-EQ electrical cable connections during the period of extended operation. A representative sample of non-EQ electrical cable connections will be selected for testing considering application (high, medium and low voltage), circuit loading and location, with respect to connection stressors. The type of test to be performed, i.e., thermography, is a proven test for detecting loose connections.

A representative sample of non-EQ cable connections will be tested at least once every 10 years. This new program will be implemented prior to the period of extended operation.

Page 15 of 28

B.1.40 Electrical Cable Connections - Metallic Parts - Not Subiect to 10 CFR 50.49 Environmental Qualification Requirements Program Description This new aging management program will be used to manage the aging effects of metallic parts of non-EQ electrical cable connections within the scope of license renewal.

It will address cable connections that are used to connect cable conductors to other cables or electrical devices. The most common types of connections used in nuclear power plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks. Most connections involve insulating material and metallic parts. This aging management program will account for the aging stressors of thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation of the metallic parts.

Electrical cable connections, metallic parts, not subject to 10 CFR 50.49 environmental qualification requirements, that are subject to aging stressors will be managed by testing to provide an indication of the integrity of the cable connections. The type of test to be performed, i.e., thermography, is a proven test for detecting loose connections. A representative sample of electrical cable connections will be tested.

This program, as described, can be thought of as a sampling program. The following factors are considered for sampling: application (high, medium and low voltage), circuit loading, and location (high temperature, high humidity, vibration, etc.) with respect to connection stressors. If an unacceptable condition or situation is identified in the selected sample, a determination is made as to whether the same condition or situation is applicable to other connections not tested.

A sample of non-EQ electrical cable connections metallic parts will be tested prior to the period of extended operation, with an inspection frequency of at least once every 10 years.

Aging Management Program Elements (1) Scope of Program:

The metallic parts of electrical cable connections, not subject to 10 CFR 50.49, associated with cables in scope of license renewal are part of this program, regardless of their association with active or passive components (2) Preventative Actions No actions are taken as part of this program to prevent or mitigate aging degradation.

(3) Parameters Monitored/Inspected This program will focus on the metallic parts of electrical cable connections. The monitoring includes loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. A representative sample of electrical cable connections is tested. The following factors are to be considered for sampling: application (high, medium Page 16 of 28

and low voltage), circuit loading, and location (high temperature, high humidity, vibration, etc.) with respect to connection stressor. The technical basis for the sample selected is to be documented.

(4) Detection of Aging Effects Electrical cable connections - metallic parts - not subject to 10 CFR 50.49 environmental qualification requirements within the scope of license renewal will be tested at least once every 10 years. Testing will utilize thermography. This is an adequate period to preclude failures of the electrical connections since experience has shown that aging degradation is a slow process. A 10-year testing interval will provide two data points during a 20-year period, which can be used to characterize the degradation rate. The first tests for license renewal are to be completed before the period of extended operation.

(5) Monitoring and Trending Trending actions are not included as part of this program.

(6) Acceptance Criteria The acceptance criteria for each test are defined by the specific type of test performed and the specific type of cable connections tested.

(7) Corrective Actions Unacceptable test results for electrical cable connections will be subject to an engineering evaluation under the corrective action process. Such an evaluation will consider the age and operating condition and environment of the connection.

When an unacceptable condition or situation is identified, a determination will be made as to whether the same condition or situation is applicable to the other connections.

Oyster Creek's corrective action process is governed by 10 CFR 50, Appendix B and is implemented by corporate administrative procedures. The corrective action process generically applies to Oyster Creek activities, even when not specifically invoked by a procedure line item.

(8) Confirmation Process Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.

(9) Administrative Controls Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.

(10) Operating Experience Page 17 of 28

This is a new aging management program. Review of existing Oyster Creek operating experience did not identify significant occurrences of failures associated with this aging management program. Since there is no adverse Oyster Creek operating experience information, this new aging management program will be implemented in alignment with GALL XL.E6 recommendations, including assessment of stressors, implementation of a sampling approach and a frequency of every 10-years, with the first inspection prior to the period of extended operation.

NUREG-1801 Consistency The aging management program for Electrical Cable Connections - Metallic Parts - Not Subject to 10 CFR 50.49 Environmental Qualification Requirements is a new program.

The program will be implemented prior to the period of extended operation. Program activities are consistent with the ten elements of aging program XL.E6, Electrical Cable Connections - Metallic Parts - Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, specified in NUREG-1801.

Exceptions to NUREG-1801 None.

Enhancements None.

Conclusion The aging management program for Electrical Cable Connections - Metallic Parts - Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provides reasonable assurance that aging effects will be adequately managed so that the intended functions of electrical cable connections are maintained consistent with the current licensing basis during the period of extended operation.

Page 18 of 28

Table 3.6.1 Summary of Aging Management Programs for the Electrical Components Evaluated in Chapter VI of NUREG-1801 Further Discussion Item Aging Effectl Aging Management Evaluation Number Component Mechanism Programs Recommended 3.6.1-1 Electrical Degradation due to Environmental Yes, TLAA This TLAA is further evaluated in equipment various aging qualification of Section 4.4 and Subsection 3.6.2.2.1.

subject to mechanisms electric components 10 CFR 50.49 environmental qualification (EQ) requirements 3.6.1-2 Electrical cables, Embrittlement, cracking, Aging management No Consistent with NUREG-1 801. The connections and melting, discoloration, program for electrical Electrical Cables and Connections Not fuse holders swelling, or loss of cables and Subject to 10 CFR 50.49 Environmental (insulation) not dielectric strength leading connections not Qualification Requirements program, subject to to reduced insulation subject to B.1.34, will be used to inspect cable and 10 CFR 50.49 resistance (IR); electrical 10 CFR 50.49 connection insulation to identify and EQ requirements failure due to thermal/ EQ requirements assess aging effects that may be thermoxidative occurring due to the existence of degradation of organics; adverse localized environments radiolysis and photolysis (ultraviolet [U\V sensitive materials only) of organics; radiation-induced oxidation; and moisture intrusion Page 19 of 28

Table 3.6.1 Summary of Aging Management Programs for the Electrical Components Evaluated in Chapter VI of NUREG-1 801 Further Discussion Item Aging Effectl Aging Management Evaluation Number Component Mechanism Programs Recommended 3.6.1-3 Electrical cables Embrittlement, cracking, Aging management No Consistent with NUREG-1801. The and connections melting, program for electrical Electrical Cables and Connections Not used in discoloration, swelling, or cables and Subject to 10 CFR 50.49 Environmental instrumentation loss of dielectric strength connections used in Qualification Requirements Used In circuits not leading to reduced IR; instrumentation Instrumentation Circuits program, subject to electrical failure due to circuits not subject to B.1.35, will be used to inspect cable and 10 CFR 50.49 thermalthermoxidative 10 CFR 50.49 connection insulation in instrumentation EQ requirements degradation of organics; EQ requirements circuits to identify and assess aging that are sensitive radiation-induced effects that may be occurring due to the to reduction in oxidation; and moisture existence of adverse localized conductor intrusion environments insulation resistance (IR) 3.6.1-4 Inaccessible Formation of water trees, Aging management No Consistent with NUREG-1 801. The medium-voltage localized damage leading program for Inaccessible Medium Voltage Cables (2 kV to 15 kV) to electrical failure inaccessible medium- Not Subject To 10 CFR 50.49 cables (e.g., (breakdown of insulation); voltage cables not Environmental Qualification installed in water trees due to subject to Requirements program, B.1.36, will be conduit or direct moisture intrusion 10 CFR 50.49 used to inspect inaccessible medium buried) not EQ requirements voltage cable and connection insulation subject to to identify and assess aging effects that 10 CFR 50.49 may be occurring due to the existence EQ requirements of adverse localized environments 3.6.1-5 PWR Only 3.6.1-6 Fuse holders Fatigue due to ohmic Aging management No NUREG-1801 aging effect is not (metallic clamp) heating, thermal cycling, program for fuse applicable to Oyster Creek. See electrical transients, holders Subsection 3.6.2.3.1 for further frequent manipulation, evaluation vibration, chemical contamination, corrosion, and oxidation Page 20 of 28

Table 3.6.1 Summary of Aging Management Programs for the Electrical Components Evaluated in Chapter VI of NUREG-1 801 Further Discussion Item Aging Effectl Aging Management Evaluation Number Component Mechanism Programs Recommended 3.6.1-7 Phase bus - Loosening of bolted Aging management No Not Applicable. Oyster Creek has no Bus/connections connections due to program for bus duct phase bus in the scope of license thermal cycling and ohmic renewal heating 3.6.1-8 Phase bus - Embrittlement, cracking, No Not Applicable. Oyster Creek has no Insulation/insulato melting, discoloration, Aging management phase bus in the scope of license rs swelling, or loss of program for bus duct renewal dielectric strength leading to reduced insulation resistance (IR); electrical failure due to thermal/

thermoxidative degradation of organics/thermoplastics, radiation-induced oxidation; moisture/debris intrusion, and ohmic heating 3.6.1-9 Phase bus - Loss of material due to Structures Monitoring No Not Applicable. Oyster Creek has no Enclosure general corrosion Program phase bus in the scope of license assemblies renewal 3.6.1-10 Phase bus - Hardening and loss of Structures Monitoring No Not Applicable. Oyster Creek has no Enclosure strength/ elastomers Program phase bus in the scope of license

_ assemblies degradation renewal Page 21 of 28

Table 3.6.1 Summary of Aging Management Programs for the Electrical Components Evaluated in Chapter VI of NUREG-1801 Further Discussion Item Aging Effectl Aging Management Evaluation Number Component Mechanism Programs Recommended 3.6.1-11 High voltage Degradation of insulation Plant specific Yes, plant Consistent with NUREG-1801 insulators quality due to presence of specific any salt deposits and surface contamination; Loss of material caused by mechanical wear due to wind blowing on transmission conductors 3.6.1-12 Transmission Loss of material due to Plant specific Yes, plant NUREG-1801 aging effect is not conductors and wind induced abrasion specific applicable to Oyster Creek transmission connections, and fatigue; conductors and connections. See Switchyard bus Loss of conductor subsection 3.6.2.2.6 for further and connections strength due to corrosion; evaluation.

Increased resistance of connection due to Oyster Creek has no switchyard bus oxidation or loss of pre- and connections in the scope of license load renewal.

3.6.1-13 Cable Loosening of bolted Aging management No Consistent with NUREG-1801 Connections connections due to program for electrical (Metallic parts) thermal cycling, ohmic cable connections not heating, electrical subject to 10 CFR transients, vibration, 50.49 environmental chemical contamination, qualification corrosion, and oxidation requirements 3.6.1-14 Fuse Holders None None N/A Consistent with NUREG-1 801 (Not Part of a Larger Assembly)

Insulation material Page 22 of 28

Table 3.6.2.1.1 Electrical Commodity Groups Summary of Aging Management Evaluation Table 3.6.2.1.1 Electrical CommodityGroups Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Management Programs Vol. 2 Item Cable Electrical Various metals Containment Loosening of bolted Electrical Cable VI.A-1 (LP-12) 3.6.1-13 A Connections Continuity used for Atmosphere connections due to Connections -

(Metallic Parts) electrical (External) thermal cycling, Metallic connections ohmic heating, Parts - Not Subject electrical, to 10 CFR 50.49 transients, Environmental vibration, chemical Oualification contamination, Requirements corrosion and (B.1.40) oxidation Indoor Air Loosening of bolted Electrical Cable VI.A-1 (LP-12) 3.6.1-13 A (External) connections due to Connections -

thermal cycling, Metallic Parts - Not ohmic heating, Subject to 10 CFR electrical transients, 50.49 vibration, chemical Environmental contamination, Qualification corrosion and Requirements oxidation (B.1.40)

Outdoor Air Loosening of bolted Electrical Cable VL.A-1 (LP-12) 3.6.1-13 A (External) connections due to Connections -

thermal cycling, Metallic Parts - Not ohmic heating, Subject to 10 CFR electrical transients, 50.49 vibration, chemical Environmental contamination, Qualification corrosion and Requirements oxidation (B.11.40)

Electrical Electrical Various Adverse Various degradation/ Environmental VI3.B-1 (L-05) 3.6.1-1 A Equipment continuity polymeric and Localized various mechanisms Qualification (EQ)

Subject To 10 metallic Environment Program (B.3.2)

CFR 50.49 EQ materials (Electrical Requirements Only)

Page 23 of 28

Table 3.6.2.1.1 Electrical Commodity Groups (Continued)

Component Intended Material Environment Aging Effect Aging NUREG-1801 Table 1 Notes Type Function Requiring Management Item Management Programs Vol. 2 Item Electrical Electrical Various organic polymers Adverse Embrittlement, Electrical Cables J, 1 penetrations Continuity (e.g., EPR, EXPE, PVC, Localized cracking, melting, and Connections (pigtails) ETFE) Environment discoloration, Not Subject to (Extemal) swelling, or loss of 10CFR50.49 dielectric strength Environmental leading to reduced Qualification insulation resistance Requirements (IR); electrical (B.1.34) failure! degradation of organics (Thermal/

thermoxidative),

radiolysis and photolysis (UV sensitive materials only) of organics; radiation-induced oxidation, and moisture intrusion Pressure Epoxy Potting Containment None None J,1 Boundary Atomosphere (Extemal)

Fuse Holders Electrical Copper alloy (Metallic Clamps) Indoor Air None None VI.A-8 (LP-01) 3.6.1-6 1,2 Continuity (External)

Insulation - Insulation material - bakelite, Adverse None None VI.A-6 (LP-03) 3.6.1-2 I, 2 Electrical phenolic melamine or ceramic, Localized molded polycarbonate and Environment other (External)

Insulation material - bakelite, Indoor Air None None VI.A-7 (LP-02) 3.6.1-14 A phenolic melamine or ceramic, (External) molded polycarbonate and other Page 24 of 28

T.l 3.6.2.1.1 Table _3_.2____.1 .1 Electrical Ecria Commoditv Codt Grouna ,

.ruo _ (Continued)

__, _ue. .

Component Intended Material Environment Aging Effect Aging NUREG-1801 Table 1 Notes Type Function Requiring Management Item Management Programs Vol. 2 Item High Voltage Insulation - Porcelain Malleable iron, Outdoor Air Degradation of Periodic VI.A-9 (LP-07) 3.6.1-11 E, 3 Insulators Electrical aluminum, galvanized steel, (External) Insulator Quality I Monitoring of cement Presence of any Combustion Salt Deposits Turbine Power Plant - Electrical

(_B.1.37)

None None VI.A-10 (LP- 3.6.1-11 1,4 11)

Insulated Electrical Various organic polymers Adverse Embrittlement, Electrical Cables Vl.A-2 (L-01) 3.6.1-2 A cables and Continuity (e.g., EPR, XLPE, PVC, Localized cracking, melting, and Connections connections ETFE) Environment discoloration, Not Subject to (External) swelling, or loss of 10CFR50.49 dielectric strength Environmental leading to reduced Qualification insulation resistance Requirements (IR); electrical (B.1.34) failure/ degradation of organics (Thermal/

thermoxidative),

radiolysis and photolysis (UV sensitive materials only) of organics; radiation-induced oxidation, and I ________ _ __ _ _I_ _ Imoisture intrusion _ _ _ _ _ I Page 25 of 28

Table 3.6.2.1.1 Electrical Commoditv Grouns lContinuedl Component Intended Material Environment Aging Effect Aging NUREG-1801 Table 1 Notes Type Function Requiring Management Item Management Programs Vol. 2 Item Insulated cables Electrical Various organic Adverse Embrittlement, cracking, Electrical VL.A-3 (L-02) 3.6.1-3 A and connections Continuity polymers (e.g., EPR, Localized melting, discoloration, Cables and in instrumentation XLPE, PVC, ETFE) Environment swelling, or loss of Connections Not circuits (External) dielectric strength leading Subject to to reduced insulation 10CFR50.49 resistance (IR); electrical Environmental failure/ degradation of Qualification organics (Thermal/ Requirements thermoxidative), Used in radiolysis and photolysis Instrumentation (UV sensitive materials Circuits (B.1.35) only) of organics; radiation-induced oxidation, and moisture intrusion Insulated Electrical Various organic Adverse Localized damage and Inaccessible VL.A-4 (L-03) 3.6.1-4 A inaccessible Continuity polymers (e.g., EPR, Localized breakdown of insulation Medium Voltage medium-voltage XLPE, PVC, ETFE) Environment leading to electrical Cables Not cables (Extemal) failure/ moisture Subject to intrusion, water trees 10CFR50.49 Environmental Qualification Requirements, (B.1.36)

Transmission Electrical Aluminum, steel Outdoor Air None None VI.A-16 (LP-08) 3.6.1-12 I, 5 conductors and Continuity (External) connections Uninsulated Electrical Copper Containment None None J, 7 Ground Continuity Atmosphere Conductors (Extemal)

Indoor Air None None J, 7 (External)

Outdoor Air None None J, 7 (External)

Page 26 of 28

Table 3.6.2.1.1 Electrical Co modity Groups (Continued)

Component Intended Material Environment Aging Effect Aging NUREG- Table Notes Type Function Requiring Management 1801 1 Item l Management Programs Vol. 2 Item Wooden Utility Structural Treated Wood Outdoor Air Change in Material Wooden J Poles Support (External) Properties Utility Poles (B.2.6)

Loss of Material Wooden J Utility Poles (B.2.6)

Soil (External) Change in Material Wooden J Properties Utility Poles (B.2.6)

Loss of Material Wooden J Utility Poles (B.2.6)

Page 27 of 28

Notes Definition of Note A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited.

F Material not in NUREG-1 801 for this component.

G Environment not in NUREG-1 801 for this component and material.

H Aging effect not in NUREG-1 801 for this component, material and environment combination.

I Aging effect in NUREG-1801 for this component, material and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-1 801.

Plant Specific Notes:

1. Insulation internal to Oyster Creek electrical penetrations and epoxy potting sealing material have a service life in excess of 60 years. Pigtails are included in the scope of the Electrical Cables and Connections Not Subject to 10CFR50.49 Environmental Qualification Requirements Aging Management Program. See Subsection 3.6.2.3.2 for additional information.

2. Oyster Creek fuse holders (not part of a larger assembly) do not experience the aging effects identified in NUREG-1801 due to their location and environment. See Subsection 3.6.2.3.1 for additional information.

3. Oyster Creek high voltage insulators in the scope of license renewal above 34.5kV will be periodically Inspected under the Periodic Monitoring of Combustion Turbine Power Plant - Electrical (B.1.37) aging management program.

4. Oyster Creek high voltage insulators do not experience the mechanical wear identified in NUREG-1801. See subsection 3.6.2.2.5 for additional information.

5. Oyster Creek transmission conductors and connections do not experience the aging effects identified in NUREG-1 801. See subsection 3.6.2.2.6 for additional information.

6. Not used.

7. Oyster Creek uninsulated ground conductors do not experience aging effects requiring management. See subsection 3.6.2.3.4 for additional information.

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Enclosure 2 Summary of Commitments Associated With Response to April 20, 2006 Request for Additional Information Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

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Enclosure 2 Summary of Commitments The following table identifies commitments made in this document. These items are described in more detail in Enclosurel of this submittal. Any other actions discussed in this submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.

Changes to Oyster Creek license renewa[ commitment 43 as submitted in the 10/12/05 AmerGen response to NRC RAI 2.5.1.19-1 are highlighted by bolding. Commitment 64 is a commitment to implement a new program and is shown in bold print.

Commitment Committed Date One-Time Programmatic ]

or Outage Action (Yes/No) (Yes/No)

43) Periodic Monitoring of Combustion Turbine Power Plant - Prior to period of No Yes Electrical extended operation A new plant specific program is credited. The program will be used in conjunction with the existing Structures Monitoring Program and the new Inaccessible Medium Voltage Cables Not Subject to 10CFR50.59 Environmental Qualification Requirements program to manage aging effects for the electrical commodities that support FRCT operation. The Program consists of visual inspections of accessible electrical cables and connections exposed in enclosures, pits, manholes and pipe trench; visual inspection for water collection in manholes, pits, and trenches, located on the FRCT site, for inaccessible medium voltage cables; visual inspection of accessible phase bus and connections and phase bus insulators/supports; and visual inspection of high voltage insulators above 34.5 kV for salt build-up. The new program will be performed on a twice per year frequency for high voltage Insulator inspections; on a 2-year interval for manhole, pit and trench inspections; on a 5-year frequency for phase bus inspections; and on a 10-year interval for cable and connection inspections.

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Commitment Committed Date One-Time Programmatic or Outage Action (Yes/No) (Yes/No)

64) Electrical Cable Connections - Metallic Parts - Not Prior to period of No Yes Subject to 10 CFR 50.49 Environmental Qualification extended operation Requirements The Electrical Cable Connections - Metallic Parts - Not Subject to 10 CFR 50.49 Environmental Qualification Requirements aging management program Is a new program that will be used to manage the aging effects of metallic parts of non-EQ electrical cable connections during the period of extended operation. A representative sample of non-EQ electrical cable connections will be selected for testing considering application (high, medium and low voltage), circuit loading and location, with respect to connection stressors. The type of test to be performed, i.e.,

thermography, Is a proven test for detecting loose connections. A representative sample of non-EQ cable connections will be tested at least once every 10 years. This new program will be implemented prior to the period of extended operation.

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