ML091140351
| ML091140351 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/20/2009 |
| From: | - No Known Affiliation |
| To: | Office of Information Services |
| References | |
| FOIA/PA-2009-0070 | |
| Download: ML091140351 (64) | |
Text
APPENDIX A COMMITMENTS FOR LICENSE RENEWAL OF OCGS During the review of the Oyster Creek Generating Station (OCGS) license renewal application (LRA) by the staff of the U.S. Nuclear Regulatory Commission (NRC) (the staff),
AmerGen Energy Company, LLC (the applicant) made commitments related to aging management programs (AMPs) to manage the aging effects of structures and components (SCs) both prior to and during the period of extended operation. The following table lists these commitments along with the implementation schedules and the sources for each commitment.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
- 1) ASME Existing program is credited. For the isolation A.1.1 Prior to the period of Section B.1.1 Section XI condensers this program also includes extended operation.
Inservice enhancement activities identified in Inspection, NUREG-1801, "Generic Aging Lessons Learned Subsections (GALL) Report," lines IV.C1-5 and IV.C1-6.
IWB, IWC, and These enhancement activities consist of:
IWD (1) Temperature and radioactivity monitoring of the shell-side (cooling) water, which will be implemented prior to the period of extended operation.
(2) Eddy current testing of the tubes, with inspection (VT or UT) of the tubesheet and channel head, which will be performed during the first ten years of the extended period of operation.
- 2) Water Existing program is credited.
A.1.2 Ongoing Section B.1.2 Chemistry
- 3) Reactor Head.
Existing program is credited.
A.1.3 Ongoing Section B.1.3 Closure Studs
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
- 5) BWR Feedwater Existing program is credited. The Oyster Creek A.1.5 Prior to the period of Section B.1.5 Nozzle Feedwater Nozzle Program will be enhanced to extended operation.
implement the recommendations of the BWR Letter 2130-Owners Group Licensing Topical Report General 06-20354 Electric (GE,) NE-523-A71-0594-A, Revision 1.
- 6) BWR Control Existing program is credited.
A.1.6 Ongoing Section B.1.6 Rod Drive Return Line Nozzle
- 7) BWR Stress Existing program is credited. The program will be A.1.7 Prior to the period of Section B.1.7 Corrosion enhanced to add the following requirement to the extended operation Cracking Line Specifications for all applicable license Letter 2130-renewal systems: "All new and replacement SS 06-20354 materials be low-carbon grades of SS with carbon content limited to 0.035 wt. % maximum and ferrite content limited to 7.5% minimum."
- 8) BWR Existing program is credited.
A.1.8 Ongoing Section B.1.8 Penetrations
- 9) BWR Vessel Existing program is credited. The program will be A.1.9 Prior to the period of Section B.1.9 Internals enhanced-to include:
extended operation (1)
Inspection of the steam dryer in accordance with BWRVIP-139.
(2)
Inspection of the top guide as recommended in NUREG-1801.
(3)
Rolling of the CRD stub tubes as a A-4
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) permanent repair, once the NRC approves the ASME code case (Code Case N-730). If Code Case N-730 is not approved, Oyster Creek will develop a permanent ASME code repair plan. This permanent ASME code repair could be performed in accordance with BWRVIP-58-A, which has been approved by the NRC, or an alternate ASME code repair plan that would be submitted for prior NRC approval. If it is determined that the repair plan needs prior NRC approval, Oyster Creek will submit the repair plan two years before entering the period of extended operation. After the implementation of an approved permanent roll repair, if there is a leak in a CRD stub tube, Oyster Creek will weld repair any leaking CRD stub tubes during the extended period of operation by implementing a permanent NRC approved ASME Code repair for leaking stub tubes that cannot be made leak tight using a roll expansion method, prior to restarting the plant.
(4)
Oyster Creek will revise its Reactor internals program to also manage the aging effect of loss of material due to the Letter 2130-06-20354 I.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR
.ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) aging mechanisms of pitting and crevice corrosion for Reactor Internals.
(5)
Oyster Creek will comply with all the applicable requirements that will be specified in the staff's final safety evaluations (SEs) of the BWRVIP-76 and BW RVIP-1 04 reports, and that it will complete all the license renewal action items in the final SE applicable to Oyster Creek, when they are issued.
(6)
The Reactor Internals program will be enhanced to include inspection for loss of material for the feedwater sparger, steam separator, RPV surveillance capsule holders and baffle plate.
(7)
The Reactor Internals Program will be enhanced to include and document the condition of the CRD and Feedwater Nozzle thermal sleeves to ensure future inspections look for thermal sleeve bypass flow.
(8)
AmerGen/Exelon is committed to following BWRVIP guidelines:
Oyster Creek will inform the (NRC) staff of any decision to not fully implement a BWRVIP guidelines approved by the A-6
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS 11 COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) staff within 45 days of the report
" Oyster Creek will notify the staff if changes are made to the RPV and its internals' programs that affect the implementation of the BWRVIP report.
Oyster Creek will submit any deviation from the existing flaw evaluation guidelines that are specified in the BWRVIP report.
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1 1
- 10) Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
Program is new. The program will include a component specific evaluation of the loss of fracture toughness in accordance with the criteria specified in NUREG-1801, XI.M13. At least one year prior to the period of extended operation, the following information will be submitted to the NRC: 1) the type and composition of CASS reactor internal components within the scope of license renewal; and 2) the results of evaluations performed to determine susceptibility to thermal aging and neutron irradiation embrittlement. For those components where loss of fracture toughness may affect the intended function of the component, a supplemental inspection will be performed. This inspection will ensure the integrity of the CASS components exposed to A.1.10 Prior to the period of extended operation Section B.1.10 Letter 2130-06-20358 A-7
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
_(LRA APP. A) the high temperature and neutron fluence present in the reactor environment.
- 11)
Flow-Existing program is credited.
A.1.11 Ongoing Section B.1.11 Accelerated Corrosion
- 12) Bolting Existing program is credited. Program site A.1.12 Prior to the period of Section B.1.12 Integrity implementing documents will be enhanced to extended operation include reference to EPRI TR-104213, Bolted Letter Joint Maintenance & Application Guide, 2130-06-20354 December 1995.
- 13) Open-Cycle Existing program is credited. The program will be A.1.13 Prior to the period of Section B.1.13 Cooling Water enhanced as follows. Volumetric inspections, for extended operation System piping that has been replaced, will be included at a minimum of 4 aboveground locations every 4 years. Inspection of heat exchangers will specify examination for loss of material due to general, pitting, crevice, galvanic and microbiologically influenced corrosion in the RBCCW, TBCCW and Containment Spray preventative maintenance tasks.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
- 14) Closed-Cycle Existing program is credited.
A.1.14 Ongoing Section B.1.14 Cooling Water System
- 15) Boraflex Existing program is credited.
A.1.15 Ongoing Section B.1.15 Monitoring
- 16) Inspection of Existing program is credited. The scope of the A.1.16 Prior to the period of Section B.1.16 Overhead program will be increased to include additional extended operation Heavy Load hoists that have been identified as a potential and Light Seismic I/I concern and are in scope for 10 Load (Related CFR54.4(a)(2). The program will also be to Refueling) enhanced to include inspections for rail wear, Handling and loss of material due to corrosion, of cranes Systems and hoists structural components, including the bridge, the trolley, bolting, lifting devices, and the rail system.
- 17) Compressed Existing program is credited.
A. 1.17 Ongoing Section B.1.17 Air Monitoring
- 18) BWR Reactor Existing program is credited. Based on Generic A.1.18 Ongoing Section B.1.18 Water Letter 89-10 containment isolation valve Cleanup upgrades/enhancements, an effective Hydrogen System Water Chemistry program, and the complete lack of cracking found during any of the RWCU piping weld inspections performed under Generic Letter 88-01, all inspection requirements for the portion A-9
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) of the RWCU System outboard of the second containment isolation valves have been eliminated.
- 19) Fire Protection Existing program is credited. The program will be A.1.19 Prior to the period of Section B.1.19 enhanced to include:
extended operation (1)
Specific fuel supply inspection criteria for Letter 2130-fire pumps during tests.
06-20354 (2)
Inspection of external surfaces of the halon and carbon dioxide fire suppression systems.
(3)
Additional inspection criteria for degradation of fire barrier walls, ceilings, and floors.
(4)
Clearance inspection of in-scope fire doors every two years.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
- 20) Fire Water Existing program is credited. The program will be A.1.20 Prior to the period of Section B.1.20 System enhanced to include:
extended operation (1)
Sprinkler head testing in accordance with NFPA 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems." Samples will be submitted to a testing laboratory prior to being in service 50 years. This testing will be repeated at intervals not exceeding 10 years.
(2)
Water sampling for the presence of MIC at an interval not to exceed 5 years.
(3)
Periodic non-intrusive wall thickness measurements of selected portions of the fire water system at an interval not to exceed every 10 years.
(4)
Visual inspection of the redundant fire water storage tank heater during tank internal inspections.
- 21) Aboveground Program is new. The program will manage the A.1.21 Prior to the period of Section B.1.21 Outdoor corrosion of outdoor carbon steel and aluminum I
extended operation I
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS.
COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
Tanks tanks. The program credits the application of paint, sealant, and coatings as a corrosion preventive measure and performs periodic visual inspections to monitor degradation of the paint, Letter 2130-sealant, and coatings and any resulting metal 06-20354 degradation of carbon steel or of the unpainted aluminum tank. Bottom UTs are performed on tank bottoms supported by soil or concrete.
- 22) FuelOil Existing program is credited. The program will be A.1.22 Prior to the period of Section B.1.22 Chemistry enhanced to include:
extended operation (1)
Routine analysis for particulate contamination using modified ASTM D 2276-00 Method A on fuel oil samples from the Emergency Diesel Generator Fuel Storage Tank, the Fire Pond Diesel Fuel Tanks, and the Main Fuel Oil Tank.
(2)
Analysis for particulate contamination.
using modified ASTM D 2276-00 Method A on new fuel oil.
(3)
Analysis for water and sediment using ASTM D 2709-96 for Fire Pond Diesel Fuel Tank bottom samples.
(4)
Analysis for bacteria to verify the effectiveness of biocide addition in the Emergency Diesel Generator Fuel A-12
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT
'ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
Storage Tank, the Fire Pond Diesel Fuel Tanks, and the Main Fuel Oil Tank.
Letter 2130-(5)
Periodic draining, cleaning, and 06-20354 inspection of the Fire Pond Diesel Fuel Tanks and the Main Fuel Oil Tank.
Inspection activities will include the use of ultrasonic techniques for determining tank bottom thicknesses should there be any evidence of corrosion or pitting.
(6)
One time internal inspection of the Emergency Diesel Generator fuel oil day tanks prior to the period of extended operation to confirm the absence of aging effects.
- 23) Reactor Existing program is credited. The program will be A.1.23 Prior to the period of Section B.1.23 Vessel enhanced to implement BW RVIP-116 "BW R extended, operation Surveillance Vessel and Internals Project Integrated Letter 2130-Surveillance Program (ISP) Implementation for 06-20358 License Renewal," including the conditions specified by the NRC in its Safety Evaluation Dated February 24, 2006.
Letter 2130 20354 If the Oyster Creek standby capsule is removed from the reactor pressure vessel (RPV) without the intent to test it, the capsule will be stored in a A-13
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) manner that maintains it in a condition which would permit its future use, including during the period of extended operation, if necessary.
- 24) One-Time Program is new. The One-Time Inspection A.1.24 Prior to the period of Section B.1.24 Inspection program will provide reasonable assurance that extended operation an aging effect is not occurring, or that the aging Letter 2130-effect is occurring slowly enough to not affect the 06-20354 component or structure intended function during the period of extended operation, and therefore will not require additional aging management.
This program will be used for the following:
(1)
To confirm crack initiation and Perform prior to the growth due to stress corrosion period of extended cracking (SCC), intergranular operation.
stress corrosion cracking (IGSCC), or thermal and mechanical loading is not occurring in Class 1 piping less than four-inch nominal pipe size (NPS) exposed to reactor coolant.
Inspections will include UT examination of 10% of the total small bore Class I butt welds and destructive or non-destructive Perform prior to the A-14
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) examination of a single small bore period of extended Class I socket welded connection.
operation.
(2)
To confirm the effectiveness of the Water Chemistry program to manage the loss of material and crack initiation and growth aging effects. Included in the scope of this activity, a one-time UT inspection of the "B" Isolation Condenser shell below the waterline will be conducted looking for pitting corrosion.
(3)
To confirm the effectiveness of the Closed Cycle Cooling Water System program to manage the loss of material aging effect.
(4)
To confirm the effectiveness of the Fuel Oil Chemistry program and Lubricating Oil Monitoring Activities program to manage the loss of material aging effect.
(5)
To confirm loss of material in stainless steel piping, piping components, and piping elements is insignificant in an intermittent condensation (internal) environment.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
(6)
(7)
(8)
To confirm loss of material in steel piping, piping components, and piping elements is insignificant in an indoor air (internal) environment.
To confirm loss of material is insignificant for nonsafety related (NSR) piping, piping components, and piping elements of vents and drains, floor and equipment drains, and other systems and components that could contain a fluid, and, are in scope for 10 CFR54.4(a)(2) for spatial interaction. The scope of the program consists of only those systems not covered by other aging management activities.
Two stainless steel pipe sections in a stagnant or low flow area in the Reactor Water Cleanup System, and two stainless steel pipe sections in a stagnant or low flow area in the Isolation Condenser System will be included in the one-time inspection samples for stress Incorporate into program prior to period of extended operation A-16
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) corrosion cracking.
- 25) Selective Program is new. The Selective Leaching of A.1.25 Prior to the period of Section B.1.25 Leaching of Materials Program will consist of inspections of a extended operation.
Materials representative selection of components of the different susceptible materials to determine if loss of material due to selective leaching is occurring. Visual inspections will be consistent with ASME Section XI VT-1 visual inspection requirements and supplemented by hardness tests and other examinations of the selected set of components. If selective leaching is found, the condition will be evaluated to determine the need to expand inspections.
- 26) Buried Piping Existing program is credited. The program will be A.1.26 Prior to the period of Section B.1.26 Inspection enhanced to include:
extended operation.
(1)
Inspection o'f buried piping within ten Letter 2130-years of entering the period of extended 06-20354 operation, unless an opportunistic inspection occurs within this ten year period. The inspections will include at least one carbon steel, one aluminum and one cast iron pipe or component. In addition, for each of these materials, the locations selected for inspection will include at least one location where the A-17
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LIRA APP. A) pipe or component has not been previously replaced or recoated, if any such locations remain.
(2)
Fire protection components in the scope of the program.
(3)
Piping located inside the vault in the scope of the program. The vault is considered a manhole that is located between the reactor building and the exhaust tunnel.
- 27) ASME Existing program is credited. The program will be A.1.27 Prior to the period of Section B.1.27 Section Xl, enhanced to include:
extended operation.
Subsection IWE (1)
Ultrasonic Testing (UT) thickness Prior to the period of Letter 2130-measurements of the drywell shell in the extended operation 06-20354 sand bed region will be performed on a (completed during frequency 6f every 10 years, except that 2006 refueling Letter 2130-the initial inspection will occur prior to the outage); then every 06-20358 period of extended operation and the other refueling subsequent inspection will occur two outage refueling outages after the initial inspection, to provide early confirmation Letter 2130 that corrosion has been arrested. The UT 20464 measurements will be taken from the inside of the drywell at the same locations Letter 2130-where UT measurements were performed 06-20358 A-18
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) in 1996. The inspection results will be compared to previous results. Statistically significant deviations from the 1992, 1994, and 1996 UT results will result in corrective actions that include the following:
Perform additional UT measurements to confirm the readings.
Notify NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of confirmation of the identified condition.
Conduct visual inspection of the external surface in the sand bed region in areas where any unexpected corrosion may be detected.
Perform engineering evaluation to assess the extent of condition and to determine if additional inspections are required to assure drywell integrity.
Perform operability determination and justification for operation until next inspection.
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APPENDIX A: COMMITMENTS FOR. LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
These actions will be completed prior to restart from the associated outage.
Note: The frequency for the inspections described in item 1 (above) has been changed to every other, refueling outage, in accordance with item.21 of the IWE Inspection Program.
(2)
A strippable coating will be applied to the reactor cavity liner to prevent water intrusion into the gap between the drywell shield wall and the drywell shell during periods when the reactor cavity is flooded.
(3)
The reactor cavity seal leakage trough drains and the drywell sand bed region drains will be monitored for leakage.
The sand bed region drains will be monitored daily during refueling outages. If leakage is detected, procedures will be in place to determine the source of leakage and investigate and address the impact of leakage on the drywell Refueling outages prior to and during the period of extended operation Periodically Daily during refueling outages.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) shell, including verification of the condition of the drywell shell coating and moisture barrier (seal) in the sand bed region and performance of UT examinations of the shell in the upper regions.
UTs will also be performed on any areas in the sand bed region where visual inspection indicates the coating is damaged and corrosion has occurred. UT results will be evaluated per the existing program. Any degraded coating or moisture barrier will be repaired. These actions will be completed prior to exiting the associated outage.
The sand bed region drains will be monitored quarterly during the plant operating cycle. If leakage is identified, the source of water will be investigated, corrective actions taken or planned as appropriate.
In addition, if leakage is detected, the following items will be performed during the next refueling outage:
Quarterly during non-outage periods.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
_(LRA APP. A)
Inspection of the drywell shell coating and moisture barrier (seal) in the affected bays in the sand bed region UTs of the upper drywell region consistent with the existing program UTs will be performed on any areas in the sand bed region where visual inspection indicates the coating is damaged and corrosion has occurred UT results will be evaluated per the existing program.
Any degraded coating or moisture barrier will be repaired.
(4)
Prior to the period of extended operation, AmerGen will perform additional visual inspections of the epoxy coating that was applied to the exterior surface of the Drywell shell in the sand bed region, such that the coated surfaces in all 10 Drywell bays will have been inspected at least once. In addition, the Inservice Inspection (ISI) Program will be enhanced to require inspection of 100% of the epoxy coating Prior to the period of extended operation (completed during 2006 refueling outage); then every other refueling outage thereafter A-22
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENTOR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
_(LRA APP. A) every 10 years during the period of extended operation. These inspections will be performed in accordance with ASME Section XI, Subsection IWE.
Performance of the inspections will be staggered such that at least three bays will be examined every other refueling outage.
Note: The scope and frequency for the inspections described in item number4 (above) has been changed to all 10 bays every other refueling outage, in accordance with item 21 of the IWE Inspection Program.
(5)
A visual examination of the drywell shell in the drywell floor inspection access Prior to the period of trenches will be performed to assure that extended operation the drywell shell remains intact. If (completed during degradation is identified, the drywell shell 2006 refueling condition will be evaluated and corrective outage) actions taken as necessary. In addition, one-time ultrasonic testing (UT) measurements will be taken to confirm the adequacy of the shell thickness in these areas. Beyond these examinations, A-23
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE I (LRA APP. A) these surfaces will either be inspected as part of the scope of the ASME Section XI, Subsection IWE inspection program or they will be restored to the original design configuration using concrete or other suitable material to prevent moisture collection in these areas.
Note: Item 5 (above) is supplemented by Item numbers 16 and 20 of the IWE Inspection Program.
(6)
The coating inside the torus will be visually inspected in accordance with ASME Section XI, Subsection IWE, per the Protective Coatings Program. The scope of each of these inspections will include the wetted area of all 20 torus bays. Should the current torus coating system be replaced, the inspection frequency and scope will, as a minimum, meet the requirements of ASME Section XI, Subsection IWE.
(7)
AmerGen will conduct UT thickness measurements in the upper regions of the drywell shell every other refueling outage Every other refueling outage prior to (completed during 2006 refueling outage) and during the period of extended operation.
Every other refueling outage prior to (completed during Letter 2130 20426 A-24
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) at the same locations as are currently measured.
(8)
The IWE Program will be credited for managing corrosion in the Torus Vent Line and Vent Header exposed to an Indoor Air (External) environment.
(9)
During the next UT inspections to be performed on the drywell sand bed region (reference AmerGen 4/4/06 letter to NRC), an attempt will be made to locate and evaluate some of the locally thinned areas identified in the 1992 inspection from the exterior of the drywell. This testing will be performed using the latest UT methodology with existing shell paint in place. The UT thickness measurements for these locally thinned areas may be taken from either inside the drywell or outside the drywell (sand bed region) to limit radiation dose to as low as reasonably achievable (ALARA).
2006. refueling outage) and during the period of extended operation Prior to the period of extended operation (completed during 2006 refueling outage); then every other refueling outage thereafter A-25'
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
Note: Item 9 (above) is supplemented by Items 14 and 21 of the IWE Inspection Program.
(10)
AmerGen will conduct UT thickness measurements on the 0.770 inch thick plate at the junction between the 0.770 inch thick and 1.154 inch thick plates, in the lower portion of the spherical region of the drywell shell. These measurements will be taken at four locations using the 6"x6" grid. The specific locations to be selected will consider previous operational experience (i.e., will be biased toward areas that have experienced corrosion or have been exposed to water leakage). These measurements will be performed prior to the period of extended operation and repeated at the second refueling outage after the initial inspection, at the same location. If corrosion in this transition area is greater than areas monitored in the upper drywell, UT inspections in the transition area will be performed on the same frequency as those in the upper drywell (every other refueling outage).
Prior to the period of extended operation and two refueling outages later.
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APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
(11)
AmerGen will conduct UT thickness measurements in the drywell shell "knuckle" area, on the 0.640 inch thick plate above the weld to the 2.625 inch thick plate. These measurements will be taken at four locations using the 6"x6" grid. The specific locations to be selected will consider previous operational experience (i.e., will be biased toward areas that have experienced corrosion or have been exposed to water leakage).
These measurements will be performed prior to the period of extended operation and repeated at the second refueling outage after the initial inspection, at the same location. If corrosion in this transition area is greater than areas monitored in the upper drywell, UT inspections in the transition area will be performed on the same frequency as those in the upper drywell (every other refueling outage).
Prior to the period of extended operation and two refueling outages later; Prior to the period of extended operation (completed during 2006 refueling (12)
When the sand bed region drywell shell coating inspection is performed (Commitment 27, Items 4 and 21), the sea) at the junction between the sand bed A-27
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) region concrete and the embedded drywell shell will be inspected per the Protective Coatings Program.
Note: The frequency for the inspections described in Item 12 (above) has been changed to every other refueling outage, in accordance with Item 21 of the IWE Inspection Program (13)
The reactor cavity concrete trough drain will be verified to be clear from blockage once per refueling cycle. Any identified issues will be addressed via the corrective action process.
(14)
UT thickness measurements will be taken from outside the drywell in the sand bed region during the 2008 refueling outage on the locally thinned areas examined during the October 2006 refueling outage.
The locally thinned areas are distributed both vertically and around the perimeter of the drywell in all ten bays such that potential corrosion of the drywell shell would be detected.
outage); then every other refueling outage thereafter.
Once per refueling cycle.
During the 2008 refueling outage and every other refueling outage thereafter A-28
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR.
SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
Note: The frequency for the inspections described in Item 14 (above) has been change to every other refueling outage, in accordance with Item 21 of the IWE Inspection Program.
(15)
Starting in 2010, drywell shell UT thickness measurements will be taken from outside the drywell in the sand bed region in two bays per outage, such that inspections will be performed in all 10 bays within a 10-year period. The two bays with the most locally thinned areas (bay #1 and bay # 13) will be inspected in 2010. If the UT examinations yield unacceptable results, then the locally thinned areas in all 10 bays will be inspected in the refueling outage that the unacceptable results are Identified.
Note: The scope and frequency for the inspections described in Item 15 (above) have been changed to all 10 bays every other refueling outage, in accordance with Item 21 of the IWE Inspection Program.
All 10 bays will be inspected during the 2008 refueling outage and every other refueling outage thereafter.
A-29
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR
" ENHANCEMENT OR
ý SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
(16)
Perform visual inspections of the drywell shell inside the trenches in bay # 5 and bay # 17 and take UT measurements inside these trenches In 2008 at the same locations examined in 2006.
Repeat (both the UT and visual) inspections at refueling outages during the period of extended operation until the trenches are restored to the original design configuration using concrete or other suitable material to prevent moisture collection in these areas.
Note: Item 16 (above) is supplemented by Item 20 of the IWE Inspection Program (17)
Perform visual inspection of the moisture barrier between the drywell shell and the concrete floor curb, installed inside the drywell during the October 2006 refueling outage, in accordance with ASME Section XI, Subsection IWE during the period of extended operation.
(18)
AmerGen will perform a 3-D finite element structural analysis of the primary During the 2008 refueling outage and subsequent refueling outages until trenches are restored to original configuration.
In accordance with ASME Section XI, Subsection IWE.
Prior to the period of extended operation A-30
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE.
NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) containment drywell shell using modern methods and current drywell shell thickness data to better quantify the margin that exists above the Code required minimum for buckling. The analysis will include sensitivity studies to determine the degree to which uncertainties in the size of thinned areas affect Code margins. If the analysis determines that the drywell shell does not meet required thickness values, the NRC will be notified in accordance with 10 CFR 50 requirements.
(19)
AmerGen will perform an engineering Prior to the period of study to investigate cost-effective extended operation replacement or repair options to eliminate or reduce reactor cavity liner leakage.
(20)
AmerGen is committed to perform visual and UT inspections of the drywell shell in the inspection trenches in drywell bays 5 and 17 during the Oyster Creek 2008 refueling outage (see item 16 of AmerGen's IWE Program (commitment 27), made in its letter 2130-06-20426).
AmerGen will extend this commitment A-31
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR
.SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
_____(LRA APP. A) and also perform these inspections during the 2010 refueling outage. In addition, AmerGen will monitor the two trenches for the presence of water during refueling outages. Visual and UT inspections of the shell within the trenches will continue to be performed until no water is identified in the trenches for two consecutive refueling outages, at which time the trenches will be restored to their original design configuration (e.g.,
refilled with concrete) to minimize the risk of future corrosion.
(21)
Perform the full scope of drywell sand bed region inspections prior to the period of extended operation and then every other refueling outage thereafter. The full scope is defined as:
UT measurements from inside the drywell (Item 1)
Visual inspections of the drywell external shell epoxy coating in all 10 bays ( Item 4)
During the 2008 refueling outage and every other refueling outage thereafter. If the analysis being performed under Item 18 above establishes increased margin, or if ongoing inspections continue to demonstrate that A-32
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT.
UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) drywell corrosion has Inspection of the seal at the junction been sufficiently between the sand bed region concrete arrested, the period and the embedded drywell shell ( Item between inspections
- 12) may able increased to minimize UT measurements at the external areas personnel radiation inspected in 2006 (Items 9 and 14) exposure.
- 28) ASME Existing program is credited. The scope of the A.1.28 Prior to the period of Section B.1.28 Section XI, program will be enhanced to include additional extended operation.
Subsection MC supports, and require inspection of the IWF underwater supports for loss of material due to corrosion and loss of mechanical function and loss of preload on bolting by inspecting for missing, detached, or loosened bolts.
- 29) 10 CFR Existing program is credited.
A.1.29 Ongoing Section B.1.29 Part 50, Appendix J
- 30) Masonry Wall Existing program is credited. The Masonry Wall A.1.30 Ongoing Section B.1.30 Program Program is part of the Structures Monitoring Program.
A-33
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) 31 ) Structures Monitoring Program Existing program is credited. The program includes elements of the Masonry Wall Program and the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants Program. The Structures Monitoring Program will be enhanced to include:
(1) Buildings, structural components and commodities that are not in scope of maintenance rule but have been determined to be in the scope of license renewal. These include miscellaneous platforms, flood and secondary containment doors, penetration seals, sump liners, structural seals, and anchors and embedment.
(2) Component supports, other than those in scope of ASME XI, Subsection IWF.
(3) Inspection of Oyster Creek external surfaces of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bolting. The scope of this enhancement includes the Reactor Building Closed Cooling Water System carbon steel piping and piping elements located inside the Drywe)l since operating experience has A.1.31 Prior to the period of extended operation.
Section B.1.31 Letter 2130-06-20354 A-34
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) shown an exposure to an environment conducive to corrosion during outages.
Also, to confirm that there is no significant age related degradation occurring on the external carbon steel surfaces of the feedwater and main steam system located inside containment, one-time visual inspections of feedwater and main steam system piping inside the containment for loss of material due to corrosion will be performed. Inspection and acceptance criteria of the external surfaces will be the same as those specified for structural steel components and structural bolting.
(4) The visual inspection of insulated surfaces will require the removal of insulation.
Removal of insulation will be on a sampling basis that bounds insulation material type, susceptibility of insulated piping or component material to potential degradations that could result from being in contact with insulation, and system operating temperature.
(5) Inspection of electrical panels and racks, junction boxes, instrument racks and panels, cable trays, offsite power structural components and their foundations, and A-35
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) anchorage.
(6) Periodic sampling, testing, and analysis of ground water to confirm that the environment remains nonaggressive for buried reinforced concrete.
(7) Periodic inspection of components submerged in salt water (Intake Structure and Canal, Dilution structure) and in the water of the fire pond dam, including trash racks at the Intake Structure and Canal.
(8) Inspection of penetration seals, structural seals, and other elastomers for change in material properties.
(9) Inspection of vibration isolators, associated with component supports other than those covered by ASME XI, Subsection IWF, for reduction or loss of isolation function.
(10) The current inspection criteria will be revised to add loss of material, due to corrosion for steel components, and change in material properties, due to leaching of calcium hydroxide and aggressive chemical attack for reinforced concrete. Wooden piles and sheeting will be inspected for loss of material and change in material properties.
(11)
Periodic inspection of the Fire Pond Dam A-36
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) for loss of material and loss of form.
(12)
Inspection of Station Blackout System structures, structural components, and phase bus enclosure assemblies.
(13) Inspection of Forked River Combustion Turbine power plant external surfaces of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bolting. Inspection and acceptance criteria of the external surfaces will be the same as those specified for structural steel components and structural bolting.
(14) The program will be enhanced to include inspection of Meteorological Tower Structures. Inspection and acceptance criteria will be the same as those specified for other structures in the scope of the program.
(15) The program will be enhanced to include inspection of exterior surfaces of piping and piping components associated with the Radio Communications system, located at the meteorological tower site, for loss of material due to corrosion. Inspection and acceptance criteria will be the same as those specified for other external surfaces C _______________________________________________________
L I
A-37
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) of mechanical components.
(16) The program will be enhanced to require visual inspection of external surfaces of mechanical steel components that are not covered by other programs for leakage from or onto external surfaces, worn, flaking, or oxide-coated surfaces, corrosion stains on thermal insulation, and protective coating degradation (cracking and flaking).
(17) The program will be enhanced to require performing a baseline inspection of submerged water control structures prior to entering the period of extended operation.
A second inspection will be performed six years after this baseline inspection and a third inspection eight years after the second inspection. After each inspection, an evaluation will be performed to determine if identified degradation warrant more frequent inspections or corrective actions.
- 32) RG 1.127, Existing program is credited. The program is part A.1.32 Prior to the period of Section B.1.32 Inspection of of the Structures Monitoring Program. The extended operation.
Water-Control RG 1.127, Inspection of Water-Control Structures Structures Associated with Nuclear Power Plants Associated Program will be enhanced to include:
with Nuclear A-38
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
___(LRA APP. A)
Power Plants (1) Monitoring of submerged structural components and trash racks.
(2)
Periodic inspection of components submerged in salt water (Intake Structure and Canal, Dilution structure) and in the water of the fire pond dam.
(3)
Periodic inspection of the Fire Pond Dam for loss of material and loss of form.
(4) Inspection of steel components for loss of material, due to corrosion.
(5) Inspection of wooden piles and sheeting for loss of material and change in material properties.
Letter 2130-(6) Parameters monitored will be enhanced to 06-20354 include change in material properties, due to leaching of calcium hydroxide, and aggressive chemical attack.
Submerged water control structures will be inspected under the Structural Monitoring Program as follows: A baseline inspection of submerged water control structures will be performed prior to entering the period of extended operation. A second inspection will be performed six years after this baseline inspection and a third inspection eight years after the second inspection. After each inspection, an A-39
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT
.IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) evaluation will be performed to determine if identified degradation warrants more frequent inspection or corrective actions.
- 33) Protective Coating Monitoring and Maintenance Program Existing program is credited. The Oyster Creek Protective Coating Monitoring and Maintenance Program provides for aging management of Service Level I coatings inside the primary containment and Service Level II coatings for the external drywell shell in the area of the sand bed region. The program will be enhanced to include:
(1) The inspection of Service Level I and Service Level II protective coatings that are credited for mitigating corrosion on interior surfaces of the Torus shell and vent system, and, on exterior surfaces of the Drywell shell in the area of the sandbed region, will be consistent with ASME Section XI, Subsection IWE requirements.
(2) Additional visual inspections of the epoxy coating that was applied to the exterior surface of the drywell shell in the sand bed region, such that the coated surfaces in all 10 drywell bays will have been inspected at least once prior to entering the period of extended operation.
A.1.33 Prior to the period of extended operation.
Section B.1.33 Letter 2130-06-20354
.1.
I ______________________
I I
A-40
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
(3) The inspection of 100% of the sandbed region epoxy coating every 10 years during the period of extended operation.
Inspections will be staggered such that at least three bays will be examined every other refueling outage.
(4) The inspection of all 20 torus bays at a frequency of every other refueling outage for the current coating system. Should the current coating system be replaced, the inspection frequency and scope will be re-evaluated. Inspection scope will, as a minimum, meet the requirements of ASME Section XI, Subsection IWE.
Note: The scope and frequency for the inspections described in Item 4 (above) has been changed to all 10 bays every other refueling outage, in accordance with Item 21 of the IWE Inspection Program.
- 34) Electrical Program is new. The program will be used to A.1.34 Prior to the period of Section B.1.34 Cables and manage aging of non-EQ cables and extended operation.
Connections connections during the period of extended Not Subject to operation. A representative sample of accessible 10 CFR 50.49 cables and connections located in adverse Environmental localized environments will be visually inspected A-41
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
,(LRA APP. A)
Qualification at least once every 10 years for indications of Requirements accelerated insulation aging.
- 35) Electrical Existing program is credited. The program will be A.1.35 Prior to the period of Section B.1.35 Cables and enhanced to include:
extended operation.
Connections Not Subject to (1) A review of the Reactor Building High 10 CFR 50.49 Radiation Monitoring and Air Ejector Offgas Environmental Radiation Monitoring system calibration Qualification results for cable aging degradation before Requirements the period of extended operation and every Used in 10 years thereafter.
Instrumen-(2)
A review of the LPRM/APRM and IRM tation Circuits system cable testing results for cable aging degradation before the period of extended operation and every 10 years thereafter.
A-42
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS 11 COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
- 36) Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is new. The program manages the aging of inaccessible medium-voltage cables (2.4 kV, 4.16 kV, 13.8 kV and 34.5 kV) that feed equipment performing license renewal intended functions. These cables may at times be exposed to moisture and are subjected to system voltage for more than 25% of the time.
Manholes, conduits and sumps associated with these cables will be inspected for water collection every 2 years and drained as required.
In addition, the cable circuits will be tested using a proven test for detecting deterioration of the insulation system due to wetting, such as power factor or 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 cable circuits will be tested at an initialfrequency of six years, after which the frequency will be evaluated and adjusted, based on test results; the period between tests shall not exceed 10 years. Results of cable tests will be trended.
Trending will occur at the same frequency as cable testing. Inclusion of the 13.8 kV system circuits in this program reflects the scope expansion of the Station Blackout System electrical commodities. Inclusion of the 34.5 kV system circuits in this program reflects the scope A.1.36 Prior to the period of extended operation.
Section B.1.36 Letter 2130-06-20354 A-43
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT' ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) enhancement for reconciliation of this aging management program from the draft January 2005 GALL to the approved September 2005 GALL.
A-44
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
__(LRA APP. A)
- 37) Periodic Existing plant specific program is credited.
A.2.1 Ongoing Section B.2.1 Testing of Carbon steel piping upstream of the drywell and Containment torus spray nozzles is subject to possible general Spray corrosion. The periodic flow tests of drywell and Nozzles torus spray nozzles address a concern that rust from the possible general corrosion may plug the spray nozzles. These periodic tests verify that the drywell and torus spray nozzles are free from plugging that could result from corrosion product buildup from upstream sources.
- 38) Lubricating Oil Existing plant specific program is credited. The A.2.2 Prior to the period of Section B.2.2 Monitoring program manages loss of material, cracking, and extended operation.
Activities fouling in lubricating oil heat exchangers, systems, and components in the scope of license renewal by monitoring physical and chemical properties in lubricating oil. Sampling, testing, and monitoring verify lubricating oil properties.
Oil analysis permits identification of specific wear mechanisms, contamination, and oil degradation within operating machinery, and components of systems in scope for license renewal. The program will be enhanced to add surveillance for verification of flow through the Fire Protection Letter 2130-System diesel driven pump gearbox lubricating 06-20354 oil cooler.
A-45
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
AmerGen will enhance Oyster Creek Program 8.2.2 to include sampling and measurement of flash point of diesel engine lubricating oil to detect contamination of lubricating oil by fuel oil.
- 39) Generator Existing plant specific program is credited. The A.2.3 Ongoing Section B.2.3 Stator Water program manages loss of material aging effects Chemistry by monitoring and controlling water chemistry.
Activities Generator stator water chemistry control maintains high purity water in accordance with General Electric and EPRI guidelines for stator cooling water systems.
- 40) Periodic Existing plant specific program is credited. The A.2.4 Prior to the period of Section B.2.4 Inspection of program includes internal and external surface extended operation.
Ventilation inspections of ventilation system components for Systems indications of loss of material, such as rust, corrosion and pitting. Heat transfer surfaces are inspected for fouling. Flexible connection and door seal elastomer materials are inspected for detrimental changes in material properties, as evidenced by cracking, perforations in the material or leakage. The program will be enhanced to include duct exposed to soil, instrument piping and valves, restricting orifices and flow elements, and thermowells. The activities will also be enhanced to include A-46
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) inspection guidance for detection of the applicable aging effects.
- 41) Periodic Plant specific program is new. The program A.2.5 Prior to the period of Section B.2.5 Inspection includes systems in the scope of license renewal extended operation.
Program that require periodic monitoring of aging effects, and are not covered by other existing periodic monitoring programs. Activities consist of a periodic inspection of selected systems and components to verify integrity and confirm the absence of identified aging effects. The inspections are condition monitoring examinations intended to assure that existing environmental conditions are not causing material degradation that could result in a loss of system intended functions.
- 42) Wooden Utility Plant specific program is new. The program is A.2.6 Prior to the period of Section B.2.6 Pole Program used to manage loss of material and change of extended operation.
material properties for wooden utility poles in or near the Oyster Creek Substation that provide structural support for the conductors connecting the Offsite Power System and the 480/208/120V Utility (JCP&L) Non-Vital Power System to the Oyster Creek plant. The program consists of inspection on a 10-year interval by a qualified inspector. The wooden poles are inspected for A-47
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) loss of material due to ant, insect, and moisture damage and for change in material properties due to moisture damage.
- 43) Periodic Monitoring of Combustion Turbine Power Plant -
Electrical A new plant specific program is credited. The program will be used in conjunction with the existing Structures Monitoring Program, the new Inaccessible Medium Voltage Cables Not Subject to 10 CFR50.49 Environmental Qualification Requirements program and the new Electrical Cable Connections Not Subject to 10 CFR 50.49 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; and 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 A.1.37 Prior to the period of extended operation.
Section B.1.37 Letter 2130-06-20354 A-48
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) 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.
- 44) Metal Fatigue Existing program is credited. The program will be A.3.1 Prior to the period of Section B.3.1 of Reactor enhanced to use the EPRI-licensed FatiguePro extended operation.
Coolant cycle counting and fatigue usage factor tracking Letter 2130-Pressure computer program. The computer program 06-20354 Boundary provides for calculation of stress cycles and fatigue usage factors from operating cycles, automated counting of fatigue stress cycles and automated calculation and tracking of fatigue cumulative usage factors. The program will also be enhanced to provide for calculating and tracking of the cumulative usage factors for bounding locations for the reactor pressure vessel, Class I piping, the torus, torus vents, Prior to the period of torus attached piping and penetrations, and the extended operation.
isolation condenser.
AmerGen will revise the Oyster Creek UFSAR to update the current licensing basis to reflect that a cumulative usage factor of 1.0 will be used in Prior to the period of fatigue analysis for reactor coolant pressure extended operation.
boundary components, as endorsed by the NRC in 10 CFR 50.55a.
A-49
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
Certification by a Professional Engineer of the reactor vessel design specification and design reports prepared for the fatigue activities associated with the Oyster Creek License Renewal Application will be performed.
- 45) Environmental Existing program is credited. EQ components A.3.2 Ongoing Section B.3.2 Qualification that cannot be qualified for 60-years will be (EQ) Program replaced before the end of their qualified life.
- 46) New P-T Revised pressure-temperature (P-T) limits for a A.4.1.3 Prior to the period of Section 4.2.3 curves 60-year licensed operating life have been extended operation.
prepared and will be submitted to the NRC for approval.
- 47) Circum-Apply for extension Reactor Vessel A.4.1.4 Prior to the period of Section 4.2.4 ferential Weld Circumferential extended operation.
Exam Relief Weld Examination Relief for 60-year operation
- 48) Axial weld Apply for extension Reactor Vessel Axial Weld A.4.1.5 Prior to the period of Section 4.2.5 Exam Relief Examination Relief for 60-year operation extended operation.
- 49) Measure Drywell wall thickness will be monitored to A.4.5.2 Ongoing Section 4.7.2 Drywell wall ensure minimum wall thickness is maintained.
thickness The ASME Section XI, Subsection IWE Program, A-50
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS 11 COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR NUMBER SUPPLEMENT IMPLEMENTATION.
LOCATION SCHEDULE.
(LRA APP. A) will manage the aging effects.
- 50) Fluence The NRC has issued a SER for RAMA approving A.4.1.1 Prior to the period of Methodology RAMA for reactor vessel fluence calculations.
extended operation.
Oyster Creek will comply with the applicable requirements of the SER.
- 51) Bolting Integrity-FRCT The Bolting Integrity - FRCT Program is a new program that provides for condition monitoring of bolts and bolted joints within the scope of license renewal at the Forked River Combustion Turbine power plant. This program is based on the General Electric recommendations for proper bolting material selection, lubrication, preload application, installation and maintenance associated with the combustion turbine units and auxiliary systems. The program also includes periodic walkdown inspections for bolting degradation or bolted joint leakage at a frequency of at least once every four years. The program manages the loss of material and loss of preload aging effects. This new program will be implemented prior to entering the period of extended operation.
A.1.12A Prior to the period of extended operation.
Section B.1.12A Letter 2130-05-20228
- 52) Closed-Cycle The Closed-Cycle Cooling Water System -
A.1.14A Prior to the period of Section B.1.14A Cooling Water FRCT Program is a new program that manages extended operation.
Letter 2130-A-51
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
System -
aging of piping, piping components, piping 05-20228 FRCT elements and heat exchangers that are included in the scope of license renewal for loss of material and cracking, and are exposed to a closed cooling water environment at the Forked River Combustion Turbine power plant. The Closed-Cycle Cooling Water System - FRCT Program relies on preventive measures to minimize corrosion by maintaining water chemistry control parameters and by performing system monitoring and maintenance inspection activities to confirm that the aging effects are adequately managed. Chemistry control, performance monitoring and inspection activities are based on industry-recognized guidelines of EPRI TR-107396, "Closed Cooling Water Chemistry Guidelines," for closed-cycle cooling water systems.
Chemical control parameters will be monitored by annual water chemistry sampling. System operational monitoring activities will be performed at a frequency of at least once every six months. This new program will be implemented prior to entering the period of extended operation.
A-52
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
- 53) Aboveground Steel Tanks -
FRCT The Above ground Steel Tanks - FRCT Program is a new program that will manage corrosion of aboveground outdoor steel tanks. Paint coating is a corrosion preventive measure, and periodic visual inspections will monitor degradation of the paint coating and any resulting metal degradation of tank external surfaces. The aboveground tanks external surfaces will be visually inspected for coating degradation by walkdown at least once every two years.
The Main Fuel Oil tank bottom is in contact with concrete and soil, and is inaccessible for visual inspection. Therefore, the program includes periodic Non-destructive wall-thickness examinations of the Main Fuel Oil tank bottom to verify that significant corrosion is not occurring.
This program, including the initial tank external paint inspections, will be implemented prior to the period of extended operation. The recommended UT inspection of the Main Fuel Oil tank bottom was performed in October 2000, so it is not necessary to perform this inspection again prior to entering the period of extended operation. Based on the results of the October 2000 inspections, and subsequent A.1.21A Prior to the period of extended operation.
Section B.1.21A Letter 2130-05-20228 I
-1 1
1 A-53
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) repairs to the tank floor, the tank was certified to be suitable for the storage of number 2 fuel oil for a period of time not to exceed 20 years from October 2000, before the next internal inspection would be necessary. Therefore, additional UT inspectionswill be performed prior to October 2020.
- 54) Fuel Oil The Fuel Oil Chemistry - FRCT Program is a A.1.22A Prior to the period of Section B.1.22A Chemistry-new program that provides assurance that extended operation.
Letter 2130-FRCT contaminants are maintained at acceptable 05-20228 levels in new and stored fuel oil for systems and components within the scope of License Renewal. The Fuel Oil Storage Tank will be maintained by monitoring and controlling fuel oil contaminants in accordance with the guidelines of the American Society for Testing Materials (ASTM). Fuel oil sampling activities will be in accordance with ASTM D 4057 for multilevel and tank bottom sampling. Fuel oil will be periodically sampled and analyzed for particulate contamination in accordance with modified ASTM Standard D 2276 Method A or ASTM Standard D 6217, and, for the presence of water and sediment in accordance with ASTM Standard D 2709 or ASTM Standard D 1796.
The Fuel Oil Storage Tank will be periodically A-54
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS I
COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) drained of accumulated water and sediment and will be periodically drained, cleaned, and internally inspected. These activities effectively manage the effects of aging by providing reasonable assurance that potentially harmful contaminants are maintained at low concentrations.
This new program will be implemented prior to entering the period of extended operation. The internal inspection of the Main Fuel Oil tank was performed in October 2000, so it is not necessary to perform this inspection again prior to entering the period of extended operation.
Based on the results of the October 2000 inspections and repairs, the tank was certified to be suitable for the storage of number 2 fuel oil for a period of time not to exceed 20 years from October 2000, before the next internal inspection would be necessary. Therefore, additional internal inspections of the tank floor are not necessary prior to entering the period of extended operation and will be performed prior to October 2020.
- 55) One-Time The One-Time Inspection - FRCT program will A.1.24A Prior to the period of Section B.1.24A Inspection -
provide measures to verify that an aging I
extended operation.
Letter2130-.
A-55
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR
- SOURCE, NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A)
FRCT management program is not needed, confirms 05-20228 the effectiveness of existing activities, or determines that degradation is occurring which will require evaluation and corrective action. The program will be implemented prior to the period of extended operation.
Inspection methods will include visual examination or volumetric examinations. Should aging effects be detected, the program will initiate actions to characterize the nature and extent of the aging effect and determines what subsequent monitoring is needed to ensure intended functions are maintained during the period of extended operation.
- 56) Selective The Selective Leaching of Materials - FRCT A.1.25A This new program Section B.1.25A Leaching of Program is a new program that will consist of will be implemented Letter 2130-Materials inspections of components constructed of in the time period 05-20228
-FRCT susceptible materials to determine if loss of after January 2018 material due to selective leaching is occurring, and prior to For the FRCT power plant, these are limited to January 2028.
copper alloy materials exposed to a closed cooling water environment. Onetime inspections will consist of visual inspections supplemented by hardness tests. If selective leaching is found, the condition will be evaluated to determine the A-56
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) ability of the component to perform its intended function until the end of the period of extended operation and for the need to expand inspections. This new program will be implemented in the time period after January 2018 and prior to January 2028.
- 57) Buried Piping The Buried Piping Inspection - FRCT Program is A.1.26A Prior to the period of Section B.1.26A Inspection -
a new program that manages the external extended operation.
Letter 2130-FRCT surface aging effects of loss of material for 05-20228 carbon steel piping and piping system components in a soil (external) environment. The program activities consist of preventive and condition-monitoring measures to manage the loss of material due to external corrosion for piping and piping system components in the scope of license renewal that are in a soil (external) environment. The program scope includes buried portions of glycol cooling water piping located at the Forked River Combustion Turbine station.
External inspections of buried components will occur opportunistically when they are excavated during maintenance. Within 10 years prior to entering the period of extended operation, A-57
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) inspection of buried piping will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of buried piping will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period. This program will be implemented prior to entering the period of extended operation.
- 58) Inspection of The Inspection of Internal Surfaces in A.1.38 Inspection for CT Section B.1.38 Internal Miscellaneous Piping and Ducting Components -
Unit 1 will be Surfaces in FRCT Program is a new program that consists of performed by Letter 2130-Miscellaneous visual inspections of the internal surfaces of steel May 2014, and 05-20228 Piping and piping, valve bodies, ductwork, filter housings, inspection for CT Ducting fan housings, damper housings, mufflers and Unit 2 will be Components-heat exchanger shells in the scope of license performed by FRCT renewal at the Forked River Combustion Turbine November 2015.
power plant that are not covered by other aging management programs. Internal inspections will be performed during scheduled maintenance activities when the surfaces are made accessible for visual inspection. The program includes visual inspections to assure that existing environmental conditions are not causing material degradation that could result in a loss of component intended functions. These A-58
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) inspections will be performed during the major combustion turbine inspection outages and will be performed on a frequency of at least once every 10 years.
The initial inspections associated with this program will be performed at the next major inspection outage for each unit. Based on an inspection frequency of 10 years, the next inspection for CT Unit 1 will be performed by May 2014, and the next inspection for CT Unit 2 will be performed by November 2015.
- 59) Lubricating Oil Analysis Program -
FRCT The Lubricating Oil Analysis Program - FRCT is a new program that.includes measures to verify the oil environment in mechanical equipment is maintained to the required quality. The Lubricating Oil Analysis Program - FRCT maintains oil systems contaminants (primarily water and particulates) within acceptable limits, thereby preserving an environment that is not conducive to loss of material, cracking, or reduction in heat transfer. Lubricating oil testing activities include sampling and analysis of lubricating oil for detrimental contaminants. The presence of water or particulates may also-be indicative of inleakage and corrosion product A.1.39 Prior to the period of extended operation Section B.1.39 Letter 2130-05-20228 Letter 2130-A-59
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) buildup. The program will also include the 06-20354 measurement of flash point. This program is augmented by the One Time Inspection - FRCT (B.1.24A) program, to verify the effectiveness of the Lubricating Oil Analysis Program - FRCT.
This new program will be implemented prior to the period of extended operation.
A-60
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE (ERA APP. A)
- 60) Periodic Inspection Program -
FRCT The Periodic Inspection Program - FRCT is a new program that will consist of periodic inspections of selected components to verify the integrity of the system and confirm the absence of identified aging effects. Inspections will be scheduled to coincide with major combustion turbine maintenance inspections, when the subject components are made accessible. These inspections will be-performed on a frequency not to exceed once every 10 years. The purpose of the inspection is to determine if a specified aging effect is occurring. If the aging effect is occurring, an evaluation will be performed to determine the effect it will have on the ability of affected components to perform their intended functions for the period of extended operation, and appropriate corrective action is taken. Inspection methods may include visual examination, surface or volumetric examinations. When inspection results fail to meet established acceptance criteria, an evaluation will be conducted to identify actions or measures necessary to provide reasonable assurance that the component intended function is maintained during the period of extended operation. The initial inspections associated with this program will be performed at the next major inspection A.2.5A Inspection for CT Unit 1 will be performed by May 2014, and inspection for CT Unit 2 will be performed by November 2015.
Section B.2.5A Letter 2130-05-20228 A-61
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
_(LRA APP. A) outage for each unit. Based on an inspection frequency of 10 years, the next inspection for CT Unit 1 will be performed by May 2014, and the next inspection for CT Unit 2 will be performed by November 2015.
- 61) Buried Piping The Buried Piping and Tank Inspection - Met A.1.26B Prior to the period of Section B.1.26B and Tank Tower Repeater Engine Fuel Supply Program is extended operation Inspection -
a new program that manages the external Letter 2130-Met Tower surface aging effects of loss of material for 05-20239 Repeater copper and carbon steel piping, and carbon steel Engine Fuel tanks in a soil (external) environment. The Supply program activities consist of preventive and condition-monitoring measures to manage the loss of material due to external corrosion for piping and tanks in the scope of license renewal that are in a soil (external) environment. The program scope includes buried portions of the Met Tower based radio communications system repeater backup engine generator fuel (propane) supply piping and the associated buried fuel supply tank, located at the Meteorological Tower.
External inspections of buried components will occur opportunistically when they are excavated during maintenance. Within 10 years prior to entering the period of extended operation, A-62
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT-IMPLEMENTATION LOCATION SCHEDULE (LRA APP. A) inspection of buried piping will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of buried piping will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period. This program will be implemented prior to entering the period of extended operation.
- 62) Spent Fuel AmerGen will commit to perform monitoring of Prior to the period of GALL Pool any leakage from the spent fuel pool liner via the extended operation Reconciliation pool leak chase piping.
Letter 2130-06-20293
- 63) Buried Piping AmerGen will replace the previously un-replaced, Prior to the period of Letter 2130-buried safety-related ESW piping prior to the extended operation 06-20328 period of extended operation.
- 64) Electrical The Electrical Cable Connections Not Subject to A.1.40 Prior to the period of Section B.1.40 Cable 10 CFR 50.49 Environmental Qualification extended operation Connections Requirements Program is a new program that Letter 2130-Not Subject to will be used to manage the aging effects of 06-20354 10 CFR 50.49 metallic parts of non-EQ electrical cable Environmental connections within the scope of license renewal Qualification during the period of extended operation. A A-63
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMITMENT ITEM NUMBER AND COMMITMENT UFSAR ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION LOCATION SCHEDULE
_(LRA APP. A)
Requirements 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.
- 65) Corrective Prior to the period of extended operation, A.0.5 Prior to the period of B.0.3
- Action, AmerGen will ensure that procedures are extended operation Confirmation established to implement the program elements Letter 2130-and of Corrective Action, Confirmation, and 06-20334 Administrative Administrative Controls, as described in Controls for Sections A.O.5 and B.0.3 of Enclosure 1 of Forked River AmerGen letter 2130-06-20334, for the Forked Combustion River Combustion Turbine aging management Turbine activities.
Activities A-64