ML091180734

Appendix a: Commitments for License Renewal of Ocgs, Including Handwritten Notes

ML091180734
Person / Time
Site:	Oyster Creek
Issue date:	03/20/2009
From:	- No Known Affiliation
To:	NRC Region 1
References
FOIA/PA-2009-0070
Download: ML091180734 (62)

Text

APPENDIX A: C M**S- FR LE RENEWAL OF O COMMITMENT ~ITEM NU MBR AND COMMITMENT. UPSAR ENHANCEMENT*. OR. SOURCE

,NUMBER SUPPLEMENT 1 IMP LE MENTATION-II -

~~ LOCATION SC..HEDULE~

_____________________

_______________________________________________________ ILA AP.P)P'-

-,A)~-

1) ASME Existing program is credited. For the isolation A.1.1 Prior to.the period.of Section B..1.1 Section Xl condensers this program also includes extenfded'operation. . .

Inservice enhancement activities identified in Inspection, NUREG-1 801, "Generic Aging Lessons Learned Subsections (GALL) Report," lines IV.C1-5 and IV.Cl-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). -'Eddycurrent testing of the tubes, with inspection (VT or UT) of the tube§heet and c I head, which will be performed.

(duringe first ten years- f the extended e 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

4) BWR Vessel ID Existing program is credited. A.1.4 Ongoing Section B.1.4 Attachment Welds A-3

i~i*  !;!AP;APPENDIX A: C,.OM M FOR, LICENSE RENEWAL OF OCGS - __

COMMITMENT -ITEM NUMBER-AND'COMMITMENTf' UFSARC 7ENHANCEMENT OR jSOURCE NUMBER SUPPLEMENT, 'IMPLEMENTATION *Ž"

~ LOCATION ~ SCHEDULE

- ~ ~ (LRAAPP. 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

APENI A: COMMITMENTS FOR LICESRNWAOFCG COMMITMENT" ITE..

.M.......

N UUBEL COMMITMENTR**MENT- EMN ENHANCEMET O SOURCE

-NUMBER SUPEMN MPLEMENTATION~

- '~K<.  ;,.~rLOCATION': SCHEDUILE.'

____________________________________________(LRAýAPP. A

__________________

permanent repair, once the NRC Letter 2130-approves the ASME code case (Code 06-20354 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

___________________ n _______________________________________________ L I j A-5

APPENDIX.A: COMMITMENTS FOR LICENSE RENEWAL OFOCOS_______

COMMITMENT ITEM NUjMBER AND COM~MITMENT UFSAR ~ ENHANCEMENT OR SOURCE NUMBER .,SUPPLEMENT ~MPLEMENTATION I ~ .. .

SLOCATION ~<. SCHEDULE

~(LRA APP. A)47 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 BWRVIP-104 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

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.

t 4- 1

10) Thermal Aging Program is new. The program will include a A.1.10 Prior to the period of Section B.1.10 and Neutron component specific evaluation of the loss of extended operation Irradiation fracture toughness in accordance with the criteria Letter 2130-Embrittlement specified in NUREG-1801, XI.M13. At least one 06-20358 of Cast year prior to the period of extended operation, Austenitic the following information will be submitted to the Stainless NRC: 1) the type and composition of CASS Steel (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 I II A-7

-,,PPEDI A: COJMMITMENTS FOR ICES ENW OF OCGS -

COMMITMENT ITEMINUMBER AND COMMITMENT SUC NUMBER SUPPLEMEN EIMALEMENTATORN. SUC LOCATION: ~ -SCHEDULE~*ZK.~-

1- *.* ~~~~~(LRAAPP. 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, December 1995.

. 0 )

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.

A-8

I

- -~

.:Y.~. APPEN DIX A: CO MM ITM ENTS FOR'LICENSE ~REN EWAL OF:OCGS COMMITMENT I,TEM NUMBER AND COMMITMENT . UFSARP :ENHANCEMVENT:OR SOURCE NUMBR SPPLMEN IMPLEMENTATION

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 Il/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 upgradeslenhancements, 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

of the RWCU System outboard of the second containment isolation valves have been eliminated.

I F 4

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.

A-10

APENI A: COMMITET FRLICENSE REN EWAL OF OCGS COMMITMENT ITEM NVUMBER ANCMIMN UVFSAR << ENHA~NCEMENT ~OR .SOURCE, NUMBER. ~SUPPLEMENTA IMPLEMENTATION LOCATION. SCHEDUIE

___________________________________________________(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 extended operation A-1I

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.

1- I 4-

22) Fuel Oil 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________________ J ____________________ ______________

A-12

_APPENDIX,.- -COMMITMENTS FOR LICENSE.REN COMMITMENT *I I!E1 M NUMBER AND COMMITMENT

• SUPPLEMENT I NUMB ER * *;i

!! ~h*

~i'f":::iI , !l.;!! ' 11~ i?*'1!!';*~i{iiI lll~, !~ll !III iIliiIlIi!*! i*;i!}i'

( OCATION (L.RA AP P. A)

I I 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 BWRVIP-116 "BWR 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 I _______________ L___________

A-13

PPNDX :COMMITMENTS FO LIES EEA.FOG COMMITMENT' 'ITEM NUMB'ER AND COMMIT~MENT UFSAR ý ENHANCEMENT OR SOURCE NUMBER SUPLEEN IMPLEMENTATION ~

~ LOCATION SCHEDULE,

________________________________(IRA 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

~k APPE NDIX~ A: CMIENSFO'R LIGENSE RENEWAL OF OCGS COMMITMENT I ' ITEM NUMBER AND GOMMlTMENT ~ UFA ENHANCEVIENT SOUR~CE

ýý,:NUMBER ',f SUPPLEMENT IMPLEMENTATION

.ii.?i, ~ ' ~ LOCATION ~ SCHEDULE ,

.,.,-,. j. ( ýRA 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 iAnteH6s*opef 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.

A-1 5

(6) To confirm loss of material in steel Incorporate into piping, piping components, and program prior to piping elements is insignificant in period of extended an indoor air (internal) operation environment.

(7) 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 4 stemerot covered by other aging managembentactivities..

18)* Two stainless steel pipe sections in a stagnant or low flow area in the Reactor Water Cleanup System, and tWmsta4less` *teel

.c .... t**h..heoem

~,. ~ipection, samples forý stress __

I ___________________ J. 1 _________________

R A-1

corrosion cracking.

I 4

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 Xl 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.

-t 1 I

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 of 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 I ____________ J_______________I ___________

A-17

APPNDIA:COMITMNT&FOR LICENSE RENEWAL'OF OCGSý COMMITMENT .:TMNUMBER AND COMMITMENT U FSAR .. ~ENHANCEMENT OR. :SURCE-,

NUM BER SUPPLEMENT  :~;IMPLEMENTATION .

~~ ~~~ ~LOCATIONSCEU .< .

S ~ ~ ~ ~ ~ ~~(LRA 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 13.1 .27 Section XI, enhanced to include: extended operation.

Subsection IWE (1) Ultrasonic Testing (UT) thickness Prior to the period of Letter 2l3O-measurements of the drywell shell in the extended operation 06-20354 sand bed region will be performed on a (completed during frequency of every 10 years, except that 2006 refueling Letter 2130-1 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 UIT m easurements were performed ______________________ 06-20358 A-1 8

in 1996. The inspection results will be co mpared toprdviousýs results. $ sJ*cia~-

significant deviations from th " 11991, 1994, and 1996 UT results wl-tsult 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.

____________ a _______________________________ J ____________ .1_______________ 1 ___________

A-19

APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS I J

.1 COIMMITMENT ITEM NUMBER AND COMMITMENT UFSAR EINHANCEMENT, OR SOURCE NUMBER SUPPLEMENT IMPLEMENTATION

~~ . - ~LOCATIONY SCHEDULE

~~.

~~. (LRA APP. A) ý ~

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) As tippjable --catihg-wil 15be-a plg!.dto the Refueling outages reactor cavity liner to prevent water prior to and during intrusion into the gap between the drywell the period of shield wall and the drywell shell dur ,ing i extended operation periods-wihe',hftheirea ctor -cIivity is

,flooded' (3) The reactor cavity seal leakage trough Periodically drains and the drywell sand bed region drains will be monitored for leakage.

The sand bed region drains will be Daily during refueling monitored daily during refueling outages.

outagesfeakage is detected procedures will be in place to determine the source of leakage and investigate and address the impact of leakage on the drywell A- _________________ L A-20

APP ENDIX A: CO MM ITM EN TS FOR LICENSE RE N EWAL OF',0GC "COMMITMENT"I NUMBER ITEM NUMBR AND COMTMN I ,UFSAR SUPPLEMENT NACMITO IMP .EMENTATION, SOURCE~

LOC4~9ATION- SCHEIDULEa

- j~ ~ (LRA AP P.. A) ---

shell, includinuvrfication of the condition of the drywell shell ioating andllmoisture barrier sgý perforwne sITs of ecaindc.atens of te shein aarn th ups e ge*DzW Sudper 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 Quarterly during plant operating cycle. If leakage is non-outage periods.

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:

A. L A-21

oI nspection of the drywell shell coating and moisture barrier (seal) in the affected bays in the san

• UT--f-thWperdrywe ýregion consistent with the existing .

pro r

• 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 Prior to the period of inspections of the epoxy coating that was extended operation applied to the exterior surface of the (completed during Drywell shell in the sand bed region, such 2006 refueling that the coated surfaces in all 10 Drywell outage); then every bays will have been inspected at least other refueling once. In addition, the Inservice Inspection outage thereafter (ISI) Program will be enhanced to require inspection of 100% of the epoxy coating A-22

.APPENDIX A:COMMITMENTS FOR LICENSE RENEWAL OFOCGS _________,.

COMMITMENT NUMBER I.j ... ITEM NUMBER AND COMMITMENT I I UFSAR SUPPLEMENT LOCATION .

ENHANCEMENT OR IMPLEMENTATION SCHEDULE SOURCE*

__________

__________ __________(LRA APP. A) _ _ _ _ _ _ _ _ _ _ _ _ _ _

every 10 years during the period of extended operation. These inspections will be performed in accordance with ASME Section Xl, 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 inthe 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

AP..N.:- , *COMMITMENTS F LICENSE-RENEWAL OF.OCGS COMMITMENT NUMBER {jý ý:IE NUBE AN COMTEN FA SUPPLEMENT, ENHAN CEMENT.OR MLEEtA'O

~SOURCE

_______________________________________________ (LRA APP.,A) .. i; 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 Every other refueling Letter 2130 visually inspected in accordance with outage prior to 20426 ASME Section XI, Subsection IWE, per (completed during the Protective Coatings Program. The 2006 refueling scope of each of these inspections will outage) and during include the wetted area of all 20 torus the period of bays. Should the current torus coating extended operation.

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 Every other refueling measurements in the upper regions of the outage prior to drywell shell every other refueling outage (completed during I ______________________

A-24

-':R PEr'NDI A: 'CMMIITMENI FOR LI*EN*E REIN WALO FO:

COMMITMENT,ý -ITEM NUMBER AND COMMITMENT~ UFSARI ~ENHAN CEMENT OR SOURCES I. SUPP LEMENT ~~IMPLEMEN TAT ION NUMBER LOCATION <SCHEDULE.

.... (LRA APP. A) at the same locations as are currently 2006 refueling measured. outage) and during the period of extended operation (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 Prior to the period of (reference AmerGen 4/4/06 letter to extended operation NRC), an attempt will be made to locate (completed during and evaluate some of the locally thinned 2006 refueling areas identified in the 1992 inspection outage); then every from the exterior of the drywell. This other refueling testing will be performed using the latest outage thereafter 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).

a _ _ _ _ _ _A _ _ _ _ _ _ _ _ _ _ _ _

A-25

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 Prior to the period of plate at the junction between the 0.770 extended operation inch thick and 1.154 inch thick plates, in and two refueling the lower portion of the spherical region outages later.

of the drywell shell. These measurements will be taken at four locations 6it*i0 3 rThe

specific locations t6 66 s'elected 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).

L _______________ J.___________

A-26

COMMITMENTS FOR LICEN~SE RENEWAL OF OCGS~

IMMITMEN1T4 , ~UFSAR~ ENHANCEMENT 0 SUPPLEMENT IMPLEMENTATIO1 SLOCATION<

S(LRAAPP. A)'

q *

(11) AmerGen will conduct UT thickness measurements in the drywell shell "knuckle" area, on the 0.640 inch thick Prior to the period of plate above the weld to the 2.625 inch extended operation thick plate. These measurements will be and two refueling taken at four locations usIhle.6"tx6 outages later.

ri!§ihe 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).

(12) When the sand bed region drywell shell Prior to the period of coating inspection is performed extended operation (Commitment 27, Items 4 and 21), the (completed during seal at the junction between the sand bed 2006 refueling J.

A-27

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,*

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i~, l;**:E*)i *  ;*=* *!ii 'i-A P ..........

N I ... : C O M

. .. IT.....M N T .E *ýL IC E, N S E ..ýR.. N.*

. . . ; *,w P A"** F* *C G S*  ;-O  ;** "* *!.i :

SCOMMITMENT'~ ITEM N.UMBER AND COMMITMENT I UFSAR, ENHAN~CEMENT ORI SOURCE

,NUMBER . .SUPPLEMENT I]MPLEMENTATIONj LOCATION LQC . ~SCHEIDULEý.

~(RA~PP.)____________

-~

region concrete and the embedded outage); then every drywell shell will be inspected per the other refueling Protective Coatings Program. outage thereafter.

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 Once per refueling will be verified to be clear from blockage cycle.

once per refueling cycle. Any identified issues will be addressed via the corrective action process.

(14) UT thickness measurements will be taken During the 2008 from outside the drywell in the sand bed refueling outage and region during the 2008 refueling outage every other refueling on the locally thinned areas examined outage thereafter 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.

I ______________ J. _________________ I _____________

A-28

APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS COMMTIVENTITE NUBER ND OMMTMET USAR NHACEMNT R SURC 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 All 10 bays will be

.thickness measurements will be taken inspected during the from outside the drywell in the sand bed 2008 refueling region in two bays per outage, such that outage and every inspections will be performed in all 10 other refueling bays within a 10-year period. The two outage thereafter.

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.

£ J. 1.

A-29

/

APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL &F'-C.GS COMMITMENT, ITEM NUMBER AND COMMITMENT IjtR:ýý

'NUMBER I SUPPLEMENT EHNCMN-RSUC

ý.IMPLEMENTATION LOCATION SCHEDUL~E~

• ~~. ~ij (LRA APP A ) *iZ

(.16) Perform visual inspections of the drywell During the 2008 shell inside the trenches in bay # 5 and refueling outage and bay# 17 and take UT measurements subsequent refueling inside these trenches In 2008 at the outages until Ii same locations examined in 2006... trenches are restored Repeat(botWtleUT and visual)

... to original inspections at refueling outages during configuration.

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-m 7(1) Perform visual inspection o he moisfure-.

barrier between the drywell shell and the In accordance with cconcrete floor curb, installed inside the ASME Section XI, ddrywell during the October 2006 refueling I Subsection IWE.

0.outage, in accordance with ASME S'eti n Xl, Subsection IWE during the period of ext-endd-opefatien.

i~iIerben~iIl Perfor~n~ 3-0 fi~ite v~ Prior to the period of eleii~e'nt structural~~~ of~the prim ary4~7 extended operation

________________________ ________________________ £ L I

A-30

'APPENDI A:COMMITMENTS FOR LICEN~SE RENEWAL OF OCGSŽ COMT MENT ~ ITEM NUMBER AND COMMITMENT UFA NANEETORSUC NUMBER: SUPPLEMENT <IMPLEMENTATION.

~~ ~ ~ ~ 10 LCATION ~ SCHEDULE '---

~ ~ ~ ~ ~" ~(tRA AP.P 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 ofthinnred areas affect;Cod6`7'ýiarg inis. If 1the 'Inaly'is, determijies that the drywell shell does not-,

meet required thickness-values, the NRC i will be pqtified in.ac6-rdance with 10. i r50F9 quireme nts. -

(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

.5. ______________ 1 _________________ _____________

A-31

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 During the 2008 bed region inspections prior to the period refueling outage and of extended operation and then every every other refueling other refueling outage thereafter. The full outage thereafter. If scope is defined as: the analysis being performed under UT measurements from inside the drywell Item 18 above (Item 1) establishes increased margin, or Visual inspections of the drywell external if ongoing shell epoxy coating in all 10 bays ( Item inspections continue

4) to demonstrate that J. __________________ £ A-32

APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS

~COMMIT~MENT ITEM NUMBER AND COMMITMENT UFS~AR.; ENHANCEMENT OR SORE NUMBER § w<7.SUPPLEMENT IMPLEMENTATION

>.i~

~ 7 >iKK~r.LOCATION SCHEDULE

_______

______ ______ _______ ______ ______ ______(LRA APP. A) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

-' drywell corrosion has

.7 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 K 12) may able increased

- to minimize

• UT measurements at the external areas personnel radiation inspected in 2006 (items 9an~d 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 Xl, 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 CER 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

I~",*,""~"" C..MMIIMENT"" LICENSE RENEWAL ... uGu OF COMMITMENT ITEM NUMBER AND COMMITMENTý UFA':.. -. NACEMENT OR SOURCEý:

NUMBERi-' SUPPLEMENT IMPLEMENTATION A4*

~j~3/44'.LOCATiION SCHEDULE

• • ~.(LRA APP. A)ý

31) Structures Existing program is credited. The program A.1.31 Prior to the period of Section B.1.31 Monitoring includes elements of the Masonry Wall Program extended operation.

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 Letter 2130-embedment. 06-20354 (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 Drywell since operating experience has J _____________ L I A-34

____________'APPENDIX A: COMMITMENTS FOR LICENSERENEWAL OF OCGS COMMITMENT,, ITEM NUMBER AND COMMITMENT~

• -,,,*. *.*:,**:-.___-________________:_______________________________________________

• ii**ii ;;*  ::* i* * }*? !*IF  ! UFSAR.....ENHANCEMENT ILE**i~;*::** A) OR

_______:_-_____,._______.,______,_______ SOURCE  ;;

• ii *::

__________,______________*;**:**:::.i~i*

NUMBER - SU.PPLEMENT, IMPLEMENTATION

~~~ ~~LO'CATION <SCHEDULE "-'-..

... RA -. .. 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 J. I A-35

'COMITMET~APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS

'OMTETITEM NUMBER AND COMMITMENTX ;jUFSAR ENHANCEMENT"OR 2~SOURCE q NUMBER'ý SUPPLEMENT 'IMPLEMENTATION LOCATION ~'~SCHED.ULE

________

__ _______

_____ ________ ________ _______(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 NUMBER ITEM NUMBER AND COMMITMENT

• • ~~~~~** ~~(LRA I ~ UFSAR'

,SUPPLEMENT-APP., A)

ENHANCEMENT OR,~

IMPLEMENAIN

________________

SOURCE '

,

___ _________

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 I ____________ .1______________ +/- __________

A-37

APEDX-:ZMMTETSFRLICENSE, RENEWAL 0 FOCGSIj S-COMMITMENTv ITEM NUMBER AND COMMITMENTý .>FAREHACMETO SOURCE NUMBER ~ 4Ž*y ~~~ŽŽ~SUPPLEMENT, IMPLEMENTATION t

~ ~~4LOCATION, SCHEDULE;

______________________________________

_______________ LRA AP P. 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 I

COMMITMENT ITEM NUMBERAND COMMITMENT UFSARESOUR* ENHANCEMENT OR NUBRSUPPLEMENT. IMPLEMENTATION NU MBER 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 I I I A-39

~~~PPNI A: COMMITMENTS FOR LICENSE RENEWAL OF OCGS~ ______

'COMMITMENT ITEM NUMBER AND COMMITMENT- *WUFSAR A'ENHANCEMENT OR SOURCE.

NUMBER UPPLEMENT,

-S~ IMPLEMENTATION

- LOUATIIN SCHDUL evaluation will be performed to determine if identified degradation warrants more frequent inspection or corrective actions.

33) Protective Existing program is credited. The Oyster Creek A.1 .33 Prior to the period of Section B.1 .33 Coating Protective Coating Monitoring and Maintenance extended operation.

Monitoring Program provides for aging management of and Service Level I coatings inside the primary Maintenance containment and Service Level 11coatings for the Program external drywell shell in the area of the sand bed region. The program will be enhanced to include: Letter 2130-06-20354 (1) The inspection of Service Level I and Service Level 11protective 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 [WE 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-40

APPE NDIX; A: COMMI FOR LICENSE RENEWAL-OF OCGS *

-~ r I ITEM NUBRADCOMMITMENT ~UFSAR ,

NU~MBER~. SUPPLfEMENlLT LOCATION,~

(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 Xl, 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:' POMMITMENTS FOR LICENSE RENEWAL OF OCGS ,

COMMITMENT ITEM NUMBER ANDý'COMMITMENT-` UFSAR ENHANCEMENT 'OR. ýS'SOURCE~

NUMBER'~i~ SUPPLEMENT, 'IMPL:EMENTATION,~<",

V~~ ~LOCATION SCHDUL S. ~~ ~ (LRA APP-.A) 1 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

APPENDIXA: "-.MITMENT', FOR LICENSE RENEWAL: u1....

'COMMITMENT ITEM NUMBER AND, COMMITMENT UFSAR ENH.ANCEMENT

.. OR.

NUMBER .. ,, . .I..MPLEMENTATION SUPPLEMENT ILOCATION, SCHEDULE

_______

_______ ______ ______ _______ ______ ______(LRA APP.A _ _ _ _ _ _ _ _ _

36) Inaccessible Program is new. The program manages the A.1.36 Prior to the period of Section B.1.36 Medium aging of inaccessible medium-voltage cables extended operation.

Voltage (2.4 kV, 4.16 kV, 13.8 kV and 34.5 kV) that feed Cables Not equipment performing license renewal intended Subject to functions. These cables may at times be Letter 2130-10 CFR 50.49 exposed to moisture and are subjected to system 06-20354 Environmental voltage for more than 25% of the time.

Qualification Manholes, conduits and sumps associated with Requirements these cables will be inspected for water collection every 2 years and drained as required.

In addition Jhth b lee';ircbUit`

-ca will be' Itested Using" ah fes fidtcin detrio_`r -atin o'f t hes grvý insulatitno.rsystem du11e to wetting, such as power fafctorror partial discharge, as described in EPRI TR-1 03834-P 1-2, or other testing that is state of-the-artat the-time the test is: performed.I The c6able circuits will be tested at an initial frequency 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 I ______________ I ___________

A-43

rAPPENDIXA: UUOMMIIMW'JI1,FR9 i.LCENSE RENWr~ALuruOuG COMMITMENT ITEM NUMBER AND COMMITMENT A: UFSAR, ENHANCEMENT OR- SOURCE'

NUMBER,

') .£ SUPPLEMENT

-*!.. IMPLEMENTATION.

tt~4

~tt~u.

~>UKKY LOCATIOŽN r W I E gDkK enhancement for reconciliation of this aging management program from the draft January 2005 GALL to the approved September 2005 GALL.

A-44

APPENDX A: COMMITM-ENTS FOR LICENSE.R'*EWAL OF OCGS-COMMITMENTý3 ITEM NUMBER AND COMMITMENT UFSAR ~~ ENACMN,1 .SUC

ýNUMBERWr ~SUPPLEMENT iAmEHANCMENTATORNORE LOCTIO SCHEDULE 3 ~.

4 ~

3I~3~ ~34~333 ~ (LRA3 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

'PPENDIX A:~COMM ITMENTSýFOR, LICENSE RENEWAL OF. OCGS K.

COMMITMENT. ITEM NUMBER ANDCOMMITMENT. UFSAR ~ENHANCEMENT OR SOURCEr' NUMBER :SUPPLEMENT IMPLEMENTATION

LOCATION-

.~ SCHEDULE"

_________________

_________________________________________(LRAAPP._A) ______________ __________

AmerGen will enhance Oyster Creek Program B.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

1, .:APPENDIXAc'QOMMITMENTS FOR LICENSE'RENEWALOF OCGS

.COMMITMENT i <.' ITEM NUMBER AND COMMITMENT :UFSAR ENHANC EM ENT OR* _,SOURCE

.NUMBER SUPPLEMENT ~JIMPLEMETTO 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

~AJ APPENDIX A: IflOMITKMETSQO LIES RE~NEWAE,01.GG COMMITMENT ITEM NUMBER AND COMMITMENT JUFSAR:; ENHANCEMENJTO.R SOURCE NUMBER,'- ~ SUPPLEMENT IMPLEMENTATION

~ .~.~,.LOCATIONW" ~ SCHEDULE

______ ______

______ ______ _____(LRAAPP. A) ii loss of material due to ant, insect, and moisture damage and for change in material properties due to moisture damage.

43) Periodic A new plant specific program is credited. The A.1.37 Prior to the period of Section B.1.37 Monitoring of program will be used in conjunction with the extended operation.

Combustion existing Structures Monitoring Program, the new Turbine Power Inaccessible Medium Voltage Cables Not Plant - Subject to 10 CFR50.49 Environmental .Letter 2130-.

Electrical Qualification Requirements program and the new 06-20354 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-48

COMMITMENT ITEM-NUMBER AND COMMITMENT ~ U FSAR ~ ENACMNO ORE'ý NUMBER SUPPLEMENT KIMPL~EMENTATIONJ

'I LOCATION SCEDULE

~~ (LRA APP. A) ý.

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 OCG& _______

COMMITMENT~ ITEM'NUMBER AND COMMITMENT> UFSAR ~ ENHANCEMENTORSORC NUMBER SUPPLEM.ENT IMPLEMENTATION Lý.

~ ~*~ ~LOCATION SCHEDbULE

~ ~ ~

_________________________ ~ . ~ ~ ~(LRIA 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 h4, 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

-ExamRelief Exam ination' 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

>444,C~4 44,4.4,4$,4.~*44;44~.444.4.

.4..444$.44.4.4.4.4.444444444,<,4~

4444.4'4 44 4..4~,.44 4~44.44.44~,444~44

.4 444.~4,4444

,ICENSE REN EWAL OF OCG COMMITMENT  ;

ENHANCEMENT: OR -SOURCE' NUMBER SUPPLEMENT IMPLEMENTATION LOCATIOIN,1 **SCHEDULE I(LRAAP P. A)

-I 9 9 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 Section 4.2.1 Methodology RAMA for reactor vessel fluence calculations. extended operation.

Oyster Creek will comply with the applicable requirements of the SER.

51) Bolting The Bolting Integrity - FRCT Program is a new A.1.12A Prior to the period of Section B.1.12A Integrity- program that provides for condition monitoring of extended operation. Letter 2130-FRCT bolts and bolted joints within the scope of license 05-20228 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.

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 NU MBER AN D COMMITMEN T ~ .UFSAR Q ý~.~ENHAN CEM ENT OR' ~SOURCE, N.UMB ERE'~ii *2W SUPIPLEMENT~~IMPLEMENTATION ,.

~

w.~ ~ ~(LRAA APP. A)_CEDL 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.

L ____________ z______________ .1___________

A-52

APP:ENDIX AR*C.MMIMENT FOR LICENSE RENEWAL

.C OF ,

COMMITMENT I ITTEM NUMBER AND COMMITMENT 9ENHANCEMENTý,6R SOU.CE

.!,.NUMBER' SPLMENT~ ~MPLEMENTATION~

I

~LOCATION ~ -'SC HED ULE

~(4RAAPP. A) N-1~

-I- I I

53) Aboveground The Above ground Steel Tanks - FRCT Program A.1.21A Prior to the period of Section B.1.21A Steel Tanks - is a new program that will manage corrosion of extended operation.

FRCT aboveground outdoor steel tanks. Paint coating Letter 2130-is a corrosion preventive measure, and periodic 05-20228 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. _______________ £ ___________

A-53

A~PPENDIX A: COMMITMETFO LICENSE REN EWAL O.~ OCG

~COMMITMENT IT~EM NUMBER AND COMMITMENT. UF SAR ENHANCEMENT OR~ SOURCE NUMBER ~SUPPLEMENT IMPLEMENTATION r .< LOCATION'~~ SCHEDULE

~

____________________ ~ ~ ~ (LRA APP. A) 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.

Inspections will 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.11.22A 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

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 extended operation. Letter 2130-A-55

<>APPENDIXi M NUMBEF U

4

~ -~

E 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.

t . i I

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 I £ _______________________ I _________________

A-56

APP~lTENDXA NOMTETS FOR LICENSE REIRlEWA?4 OF OCGS C'OMMITMENT-4 ITEM NUMBER AND COMMITMENT ~ UFSAR ENHANCEMENT OR SOURCE NUMBER, SUPPLiEMENT IMPLEMENTATION ..

.,LOCATION SCEUE

~~ . ~ (LRA.2APP., 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

COMMITMENTr

'NUMVIRER 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.

t 1 4.

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 I J. ____________

A-58

.. . .. . .p - -* .* * * = ' '. * :,  ;  ;- *

• t , ; : I z ' .* : ' * : I  ;.  : * * :, , ,*, : ,* . *,. 'o*;.* .. 2' ' :' i**,* : * ! *; !;! i;* ... . .

7. w.cv APPENDlX A: COMMITMENTS FOR LICENSE RNWLFOG COMMITMENT ITEM NUMBER AND COMMITMENT ýý',U FSAR< ~ENHANCEMENT.OR  % SOURCE NUM IBER"ý SiJPPLEMENT' IMPL~EMENTATION LOCATION> -SCHEDUL.E~

~~ ~~ (LRA ~~APP- A) ý__________

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 The Lubricating Oil Analysis Program - FRCT is A.1.39 Prior to the period of Section B.1.39 Analysis a new program that includes measures to verify extended operation Program - the oil environment in mechanical equipment is Letter 2130-FRCT maintained to the required quality. The 05-20228 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 Letter 2130-A-59

.APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF, O:CG.

COMMITMENT. ITEM NUMBER'AND COMMITMENT ~ U~ FSAR `ýENHANCEMENT OR SOURCE

-NUMBER ~ A:~? ~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

APPEDIA: COMMITMENTS FOR LICENSE RE~NEWAL OF OCGS "-

COMMITMENT ITEM NUMBER AND COMMITMENT ~ 7 UFSAR'" ENHANCEMENT OR SOURCE NUMBER SUPPLEMENT~ IMPLEMENTATION-

~~~(LRA APP. A), ______________ _________

60) Periodic The Periodic Inspection Program - FRCT is a A.2.5A Inspection for CT Section B.2.5A Inspection new program that will consist of periodic Unit 1 will be Program - inspections of selected components to verify the performed by Letter 2130-FRCT integrity of the system and confirm the absence May 2014, and 05-20228 of identified aging effects. Inspections will be inspection for CT scheduled to coincide with major combustion Unit 2 will be turbine maintenance inspections, when the performed by subject components are made accessible. These November 2015.

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 I I J I A-61

'APPENDIX A: COMMITMENTS FOR LICENSE RENEA OFOG COMMITMENT" ITEM NUMBER AND COMMITMENT USR:EHNEET RSUC NUBE SUPPLEMENTj~ IMPLEMENTATION r~LOCATION, SCHEDULE-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.1.2613 Prior to the period of Section B3.1.26B3 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

v APPEN DIX A: COMMITMENTS FOR LICENSE RENEWAL OF:Q .-

COMMITMENT TMNMBER AND COMMITMENT ENHANCMENT O SOURCE~

~ NUMBER - SUPPLEMENT IAMPLEMENTATION

~~ LOCATION SCHEDUL2E~z'

~~~~~1/2. ~~~~~~~ ~(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 UFSARE A O SENHANCEMENT OR SOURCE NUMBR SUPLEENT IMPLEMENTATION, A ~* AY ~LOCATION A SCHEDULE:~

A~(R rA PPA(A L)

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.O.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.0.5 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