ML17097A491

Attachment 4 - NUREG-2191 and NUREG-2192 (February 2017 Draft) Electrical Comments

ML17097A491
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/07/2017
From:	Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17097A486	List: ML17097A487 ML17097A488 ML17097A489 ML17097A490 ML17097A491
References
NUREG-2191, NUREG-2192
Download: ML17097A491 (20)

Text

ATTACHMENT 4 NUREG-2191 and NUREG-2192 (February 2017 Draft)

Electrical Comments Comment Location of Description of Change Justification for Change

1. Change Table GALL VI.A, Table The GALL XI.E4 AMP includes discussion of elastomers Editorial - content inconsistency VI.A-1 line items for Metal for metal enclosed bus, through program description Re-include line item VI.A.LP-29 in Table Enclosed Bus and and elements. The line item for elastomers in metal VI-A.

GALL XI.E4 enclosed bus in the GALL table in VI.A has been deleted per the last entry of the table.

Table GALL VI.A, Table Comment Table VI.A-1 above may also apply to cable Editorial - content inconsistency VI.A-2 line items for bus. The first deleted line item at the end of the table Re-include line item VI.A.LP-08 in Table Cable Bus deleted elastomers for cable bus. VI.A.

Table GALL VI.A, Table The AMP name provided in the table does not match Editorial - content inconsistency VI.A-3 line VI.A.LP-33 the new GALL SLR AMP name in GALL section XI.E1. Change AMP title to Electrical Insulation Material for Electrical Table GALL VI.A, Table The AMP name provided in the table does not match Editorial - content inconsistency VI.A-4 line VI.A.LP-34 the new GALL SLR AMP name in GALL section XI.E2. Change AMP title to Electrical Insulation Material for Electrical Table GALL VI.A, Table Should include AAC conductor as well Editorial - content inconsistency VI.A-5 line VI.A.LP-47 Add AAC.

Table GALL VI.A, Table This line item component name should be Editorial - content error VI.A-6 line VI.A.LP-48 Transmission conductors connectors. Change Transmission conductors connectors.

X.E1-1 X.E1-5, EQ The wording implies that all the passive EQ equipment Editorial - content clarification Program will be inspected every 10 years to determine if they are See Comment X.E1-2 Description, in an ALE.

Lines17 - 18 To be clear; the process is to look for ALEs every 10 years first. Then, the passive EQ equipment (cables jackets and connection insulation) will be visually inspected.

Page 1 of 20

ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change X.E1-2 X.E1-6, Element 4. Element 4 states Visual inspection of accessible, Recommend:

Detection of Aging passive EQ equipment is performed at least once every Visual inspection of accessible, passive EQ Effects; Lines 37 - 10 years. The purpose of the visual inspection is to equipment in adverse localized 40 identify adverse localized environments that may impact environments is performed at least once qualified life. Potential adverse localized environments every 10 years. The purpose of the visual are evaluated through the applicants corrective action inspection is to identify adverse localized program. environments conditions that may impact qualified life. Passive EQ equipment in The wording implies that all the passive EQ equipment potential adverse localized will be inspected every 10 years to determine if they are environments are is evaluated through the in an ALE. applicants corrective action program.

To be clear; the process is to look for ALEs every 10 years first. Then, the passive EQ equipment (cables jackets and connection insulation) will be visually inspected.

Testing was removed as a requirement for this Editorial program, and testing is now based on an engineering This sentence should be removed.

XI.E1-3, Element 4 evaluation via the corrective action program. However, Detection of Aging XI.E1-1 a sentence was left in Element 4, page XI.E1-3, Lines Effects, Lines 28-28-30 which states A sample of accessible electrical 30 cables and connections are tested for reduced electrical insulation resistance.

Element 4, page XI.E1-4, line 1 states: this AMP, Editorial then testing is performed for evaluation. Since testing is now based on an engineering evaluation via the corrective XI.E1-4, Element 4 action program, change this sentence to XI.E1-2 Detection of Aging read then testing is may be performed Effects, Line 1 for evaluation, or testing, if deemed necessary, is performed for evaluation.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change The Program Description states An adverse localized Editorial XI.E2-1, Program environment is based on the most limiting environment Reword the sentence as follows: An XI.E2-1 Description, Line ... ALEs are not based on limiting environments, they adverse localized environment is based 18 exceed the most limiting environments. on exceeds the most limiting environment...

XI.E3A-1 XI.E3A-1, Program The Program Description states that This AMP applies Change the scope statement to read This Description, Lines to all inaccessible or underground (e.g., installed in AMP applies to all inaccessible or 10 - 14) buried conduit, embedded raceway, cable trenches, underground (e.g., installed in buried cable troughs, duct banks, vaults, manholes, or direct conduit, underground embedded buried installations) medium voltage cables within the raceway, underground cable scope of subsequent license renewal (SLR) exposed to trenches, underground cable troughs, duct wetting or submergence (i.e., significant moisture). banks, vaults, manholes, or direct buried installations) medium voltage cables within the scope of subsequent license The AMP applies to underground cables routed either in renewal (SLR) exposed to wetting or raceway underground or directly buried. The AMP submergence (i.e., significant moisture).

manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such The proposed changes clarify that this as manholes and vaults. Since manholes and vaults are AMP applies to underground cable confined spaces and require administrative controls for installations which aligns with the AMP entry, they are considered inaccessible. Use of the term goals of managing water accumulation inaccessible is not needed to properly describe the and its effect on underground cable.

cables under consideration. Also, the term Above ground cable is managed by the underground in this AMP is consistent with the XI.E1 AMP.

definition given in Table IX.D as used for mechanical components.

The proposed change eliminates confusion between wetting or submergence and Also, the phrase wetting or submergence does not significant moisture.

match the description of significant moisture given in Lines 28 - 30.

This change aligns XI.E3A, XI.E3B, and XI.E3C.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E3A-2 XI.E3A-1, Program The Program Description states Electrical insulation Editorial Description, Lines subjected to wetting or submergence could have an Regulatory link when not necessarily the 22 - 24 adverse effect on operability, or potentially lead to case, between aging degradation and failure of the cable insulation system. operability.

Aging degradation can impact performance of intended functions, not necessarily operability. Operability and intended functions may be the related or may be separate. Revise as suggested:

Electrical insulation subjected to wetting or submergence could have an adverse effect on the operability on performance of intended functions, or potentially lead to failure of the cable insulation system.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E3A-3 XI.E3A-2, Scope of The scope of program states that This AMP applies to Change the scope statement to read This Program, Lines 30 inaccessible or underground medium voltage (2kV to AMP applies to inaccessible or

- 33 35kV) power cable installations (e.g., direct buried, underground medium voltage (2kV to buried conduit, duct bank, embedded raceway, cable 35kV) power cable installations (e.g.,

trench, vaults, or manholes) within the scope of direct buried, buried conduit, duct subsequent license renewal exposed to significant bank, underground embedded moisture. raceway, underground cable trench, vaults, or manholes) within the scope of subsequent license renewal exposed to The AMP applies to underground cables routed either in significant moisture.

raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are The proposed changes clarify that this inspected at locations where they can be accessed such AMP applies to underground cable as manholes and vaults. Since manholes and vaults are installations which aligns with the AMP confined spaces and require administrative controls for goals of managing water accumulation entry, they are considered inaccessible. Use of the term and its effect on underground cable.

inaccessible is not needed to properly describe the Above ground cable is managed by the cables under consideration. Also, the term XI.E1 AMP.

underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical This change aligns XI.E3A, XI.E3B, and components.

XI.E3C.

XI.E3A-4 XI.E3A-2, Scope of Extra parenthesis; (that should read that Editorial Program, Line 35 Editorial - remove the stray parenthesis.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E3B-1 XI.E3B-1, Program The Program Description states that This AMP applies Change the scope statement to read This Description, Lines to inaccessible or underground (e.g., installed in buried AMP applies to inaccessible or 10 - 13 conduit, embedded raceway, cable trenches, cable underground (e.g., installed in buried troughs, duct banks, vaults, manholes, or direct buried conduit, underground embedded installations) instrumentation and control cables within raceway, underground cable the scope of subsequent license renewal (SLR) exposed trenches, underground cable troughs, duct to significant moisture. banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of subsequent The AMP applies to underground cables routed either in license renewal (SLR) exposed to raceway underground or directly buried. The AMP significant moisture.

manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such The proposed changes clarify that this as manholes and vaults. Since manholes and vaults are AMP applies to underground cable confined spaces and require administrative controls for installations which aligns with the AMP entry, they are considered inaccessible. Use of the term goals of managing water accumulation inaccessible is not needed to properly describe the and its effect on underground cable.

cables under consideration. Also, the term Above ground cable is managed by the underground in this AMP is consistent with the XI.E1 AMP.

definition given in Table IX.D as used for mechanical components.

This change aligns XI.E3A, XI.E3B, and XI.E3C.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E3B-2 XI.E3B-1, Program The Program Description states mitigated in Editorial Description, Lines service, could have an adverse effect on operability, Regulatory link when not necessarily the 24 - 26 may lead to multiple random failures of the cable case, between aging degradation and insulation system, and compromise system defense-in- operability, multiple random failures or depth. defense in depth.

Operability, multiple random failures, or defense in depth; and intended functions may be related or may be separate.

Revise as suggested:

mitigated in service, could have an adverse effect on operability on performance of intended functions, may lead to multiple random failures of the cable insulation system, and compromise system defense-in-depth or potentially lead to failure of the cable insulation system.

The Program Description states that If required, initial Editorial testing is performed once by utilizing sampling to Change the sentence to read If required, XI.E3B-1, Program determine the condition of the electrical insulation.

XI.E3B-3 Description, Line initial testing is performed once by Sampling cannot determine the condition of the utilizing sampling on a sample population 41 electrical insulation. It is used to establish the test to determine the condition of the electrical population. insulation.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change New text in this AMP states: Inaccessible Requirements should be the same as instrumentation and control cables designed for cables that are not designed for continuous wetting or submergence are also included in submergence.

this AMP as a one-time inspection and test. Delete the referenced text and revise the This is a new requirement for cables that are designed text on page XI.E3B-1, Lines 10 - 13 as for submergence. The text, as written, requires both follows: This AMP applies to inaccessible XI.E3B-2, Program inspection and testing for cable designed for or underground (e.g., installed in buried XI.E3B-4 Description, Lines submergence as opposed to inspection, and testing if conduit, embedded raceway, cable 1-2 deemed appropriate, for cable not designed for tranches, cable troughs, duct banks, submergence. vaults, manholes, or direct buried installations) instrumentation and control cables (including those designed for continuous wetting or submergence) within the scope of subsequent license renewal (SLR) exposed to significant moisture..

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change The scope of program states that This AMP applies to Change the scope statement to read This inaccessible and underground (e.g., installed in buried AMP applies to inaccessible and conduit, embedded raceway, cable trenches, cable underground (e.g., installed in buried troughs, duct banks, vaults, manholes, or direct buried conduit, underground embedded installations) instrumentation and control cables within raceway, underground cable the scope of SLR, exposed to significant moisture. trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control The AMP applies to underground cables routed either in cables within the scope of SLR, exposed raceway underground or directly buried. The AMP XI.E3B-2, Element to significant moisture.

manages water accumulation and its effects on 1, Scope of XI.E3B-5 underground cable. Within this AMP cables are Program, Lines 18 inspected at locations where they can be accessed such The proposed changes clarify that this

- 21 as manholes and vaults. Since manholes and vaults are AMP applies to underground cable confined spaces and require administrative controls for installations which aligns with the AMP entry, they are considered inaccessible. Use of the term goals of managing water accumulation inaccessible is not needed to properly describe the and its effect on underground cable.

cables under consideration. Also, the term Above ground cable is managed by the underground in this AMP is consistent with the XI.E1 AMP.

definition given in Table IX.D as used for mechanical components.

This change aligns XI.E3A, XI.E3B, and XI.E3C.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change New text in this AMP states: Cables designed for Requirements should be the same as continuous wetting or submergence are also included in cables that are not designed for this AMP as a one-time inspection and test where submergence.

additional tests and periodic visual inspections are Delete the referenced text and revise the determined by the test/inspection results and industry text on page XI.E3B-2, lines 18 - 21 as and plant-specific aging degradation OE with the follows: This AMP applies to inaccessible XI.E3B-2, Element applicable cable electrical insulation.

1 Scope of and underground (e.g., installed in buried XI.E3B-6 This is a new requirement for cables that are designed conduit, embedded raceway, cable Program, Lines 35-38 for submergence. The text, as written, requires both trenches, cable troughs, duct banks, inspection and test for cable designed for submergence vaults, manholes, or direct buried as opposed to inspection, and testing if deemed installations) instrumentation and control appropriate, for cable not designed for submergence. cables (including those designed for continuous wetting or submergence) within the scope of SLR, exposed to significant moisture.

The industry proposed visual manhole inspections for The requirement for visual inspection of accumulation of water. If water was found affecting the cable at least every 6 years should be cables, the cables would be evaluated to determine if changed to at least every 10 years to align XI.E3B-3, Element testing is required. If no water was found affecting with similar ALE inspections in other 4 Detection of XI.E3B-7 cables, no further action was required until the next AMPs. Periodic inspection of manholes for Aging Effects, manhole inspection for water accumulation. The revised water accumulation will provide further Lines 43-45 GALL adds a requirement to perform a visual cable opportunities for identification of potential inspection at least once every 6 years regardless of the adverse effects on cable.

effects of water.

XI.E3B-8 XI.E3B, Element 5 The last sentence of Element 5 is not consistent with Revise the last sentence of Element 5 as Monitoring and Element 5 in XI.E3C. XI.E3B and XI.E3C are similar follows:

Trending, Lines 39 programs that are implemented in similar manners. The However, condition monitoring cable

- 41 last sentence of Element 5 should be the same for both tests and inspection results that utilize the AMPs. same visual or test methods that are trendable and repeatable provide additional information on the rate of cable insulation degradation.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E3B-9 XI.E3B-5, Element The scope expansion method does not align with this Recommend removing the 2nd paragraph 7 Corrective one-time confirmatory test portion of this AMP. The in its entirety.

Actions, Lines 21 - periodic man-hole inspection portion of this AMP is 22 100%; there is nothing to expand.

XI.E3C-1 XI.E3C-1, Program The scope of program states that This AMP applies to Change the scope statement to read This Description, Lines all inaccessible and underground (e.g., installed in AMP applies to all inaccessible and 12- 15 buried conduit, embedded raceway, cable trenches, underground (e.g., installed in buried cable troughs, duct banks, vaults, manholes, or direct conduit, underground embedded buried installations) low-voltage power cables within the raceway, underground cable scope of subsequent license renewal (SLR) exposed to trenches, underground cable troughs, duct significant moisture. banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of subsequent license The AMP applies to underground cables routed either in renewal (SLR) exposed to significant raceway underground or directly buried. The AMP moisture.

manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such The proposed changes clarify that this as manholes and vaults. Since manholes and vaults are AMP applies to underground cable confined spaces and require administrative controls for installations which aligns with the AMP entry, they are considered inaccessible. Use of the term goals of managing water accumulation inaccessible is not needed to properly describe the and its effect on underground cable.

cables under consideration. Also, the term Above ground cable is managed by the underground in this AMP is consistent with the XI.E1 AMP.

definition given in Table IX.D as used for mechanical components.

This change aligns XI.E3A, XI.E3B, and XI.E3C.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E3C-2 XI.E3C-1, Program The Program Description states such as Editorial Description, Lines submergence represents an aging mechanism that if Regulatory link when not necessarily the 23 - 26 : not anticipated in design or mitigated in service, could case, between aging degradation and have an adverse effect on operability, may lead to operability, multiple random failures or multiple random failures of the cable insulation system, defense in depth.

and compromise system defense-in-depth.

Operability, multiple random failures, or defense in depth; and intended functions may be related or may be separate.

Revise as suggested:

such as submergence represents an aging mechanism that if not anticipated in design or mitigated in service, could have an adverse effect on operability, on performance of intended functions, may lead to multiple random failures of the cable insulation system, and compromise system defense-in-depth or potentially lead to failure of the cable insulation system.

The Program Description states that If required, initial Editorial testing is performed once by utilizing sampling to Change the sentence to read If required, XI.E3C-1, Program determine the condition of the electrical insulation.

XI.E3C-3 Description, Line initial testing is performed once by Sampling cannot determine the condition of the utilizing sampling on a sample population 40 electrical insulation. It is used to establish the test to determine the condition of the electrical population. insulation.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change New text in this AMP states: Inaccessible low-voltage Requirements should be the same as power cables designed for continuous wetting or cables that are not designed for submergence are also included in this AMP as a one- submergence.

time inspection and test. Delete the referenced text and revise the This is a new requirement for cables that are designed text on page XI.E3C-1, Lines 12 - 15 as for submergence. The text, as written, requires both follows: This AMP applies to inaccessible XI.E3C-1, Program inspection and testing for cable designed for or underground (e.g., installed in buried XI.E3C-4 Description, Lines submergence as opposed to inspection, and testing if conduit, embedded raceway, cable 42-44 deemed appropriate, for cable not designed for tranches, cable troughs, duct banks, submergence. vaults, manholes, or direct buried installations) low-voltage power cables (including those designed for continuous wetting or submergence) within the scope of subsequent license renewal (SLR) exposed to significant moisture..

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change The scope of program states that This AMP applies to Change the scope statement to read This inaccessible and underground (e.g., installed in buried AMP applies to inaccessible and conduit, embedded raceway, cable trenches, cable underground (e.g., installed in buried troughs, duct banks, vaults, manholes, or direct buried conduit, underground embedded installations) low-voltage power cables within the scope raceway, underground cable of SLR exposed to significant moisture. trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables The AMP applies to underground cables routed either in within the scope of SLR exposed to raceway underground or directly buried. The AMP XI.E3C-2, Element significant moisture.

manages water accumulation and its effects on 1, Scope of XI.E3C-5 underground cable. Within this AMP cables are Program, Lines 16 inspected at locations where they can be accessed such The proposed changes clarify that this

- 19 as manholes and vaults. Since manholes and vaults are AMP applies to underground cable confined spaces and require administrative controls for installations which aligns with the AMP entry, they are considered inaccessible. Use of the term goals of managing water accumulation inaccessible is not needed to properly describe the and its effect on underground cable.

cables under consideration. Also, the term Above ground cable is managed by the underground in this AMP is consistent with the XI.E1 AMP.

definition given in Table IX.D as used for mechanical components.

This change aligns XI.E3A, XI.E3B, and XI.E3C.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change New text in this AMP states: Cables designed for Requirements should be the same as continuous wetting or submergence are also included in cables that are not designed for this AMP as a one-time inspection and test where submergence.

additional tests and periodic visual inspections are Delete the referenced text and revise the determined by the test/inspection results and industry text on page XI.E3C-2, lines 16 - 19 as and plant-specific aging degradation OE with the follows: This AMP applies to inaccessible XI.E3C-2, Element applicable cable electrical insulation.

1 Scope of and underground (e.g., installed in buried XI.E3C-6 This is a new requirement for cables that are designed conduit, embedded raceway, cable Program, Lines 28-32 for submergence. The text, as written, requires both trenches, cable troughs, duct banks, inspection and test for cable designed for submergence vaults, manholes, or direct buried as opposed to inspection, and testing if deemed installations) low-voltage power appropriate, for cable not designed for submergence. cables (including those designed for continuous wetting or submergence) within the scope of SLR, exposed to significant moisture.

The industry proposed visual manhole inspections for The requirement for visual inspection of accumulation of water. If water was found affecting the cable at least every 6 years should be cables, the cables would be evaluated to determine if changed to at least every 10 years to align XI.E3C-4, Element testing is required. If no water was found affecting with similar ALE inspections in other 4 Detection of XI.E3C-7 cables, no further action was required until the next AMPs. Periodic inspection of manholes for Aging Effects, manhole inspection for water accumulation. The revised water accumulation will provide further Lines 38 - 39 GALL adds a requirement to perform a visual cable opportunities for identification of potential inspection at least once every 6 years regardless of the adverse effects on cable effects of water.

XI.E3C-8 XI.E3C-5, GALL, The scope expansion method does not align with this Recommend removing the 2nd paragraph XI.E3C, Corrective one-time confirmatory test portion of this AMP. The in its entirety.

Actions, Lines 14 - periodic man-hole inspection portion of this AMP is 15 100%; there is nothing to expand.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E4-1 XI.E4-4, Element The standard phrase in the Corrective Action element Editorial 7, Corrective does not align with the MEB AMP methods: Regulatory link when not necessarily the Actions, Lines 17 - The engineering evaluation considers the significance case, between aging degradation and 20 of the calibration, surveillance, inspection or test operability or reportability.

results, the operability of the component, the Recommend:

reportability of the event; the extent of the concern, the The engineering evaluation considers the potential root causes for not meeting the acceptance significance of the calibration, criteria, the corrective actions required, and the surveillance, inspection or test results, the likelihood of recurrence.

operability of the component, the reportability of the event; on performance of intended functions, the extent of the concern, the potential root causes for not meeting the acceptance criteria, the corrective actions required, and the likelihood of recurrence.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E5-1 XI.E5-1, Program The comment on this section from the December draft Suggest the following changes to the Description, Lines was that the insulating material for fuse holders in wording in the February, 2017 draft to 30 - 36 stand-alone equipment that were subject to an ALE, but remove ambiguity with scope of electrical not frequently manipulated, may not be managed under insulation visual inspections:

E5. The insulating material for these fuse holders should be managed under E1. The request was to Fuse holders within the scope of SLR this clarify this relationship between the AMPs.

AMP for potential aging effects to metallic clips as described above are also visually inspected to provide an indication of the condition of the electrical insulation portion of the fuse holders. Fuse holders are visually inspected for electrical insulation surface anomalies indicating signs of reduced insulation resistance due to thermal/thermoxidative degradation of organics, radiolysis and photolysis

[ultraviolet (UV) sensitive materials only]

of organics, radiation-induced oxidation, and moisture intrusion as indicated by signs of embrittlement, discoloration, cracking, melting, swelling, or surface contamination. Electrical insulation for fuse holders in active components or with metallic clamps that are not subject to AMR are managed with other electrical insulation, in adverse localized environments, by the aging management program for electrical insulation for cables and connections not subject to the EQ program.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E5-2 XI.E5-2, Element The comment on this section from the December draft Suggest the following changes to the 1, Scope of was that the insulating material for fuse holders in revised wording in the February, 2017 Program, Lines 4 - stand-alone equipment that were subject to an ALE, but draft to remove ambiguity with scope of 10 not frequently manipulated, may not be managed under electrical insulation visual inspections.

E5. The insulating material for these fuse holders should be managed under E1. The request was to This AMP manages in-scope fuse holders clarify this relationship between the AMPs.

outside of active devices that are considered susceptible to the following aging effects: increased resistance of connection due to chemical contamination, corrosion, and oxidation or fatigue caused by ohmic heating, thermal cycling, electrical transients, frequent removal and replacement, or vibration. as well as It also manages degradation of electrical insulation for the fuse holders with metallic clamps, susceptible to the aging effects identified. Fuse holders inside an active device (e.g. switchgears, power supplies, inverters, battery chargers, and circuit boards) and not susceptible to the aging effects identified are not within the scope of this AMP.

The Program Description states A sample of cable Editorial connections within the scope of license renewal are Revise the Program Description statement tested on a one-time test basis or at least once every as follows: A sample of cable connections 10 years, or once every 5 years if only a visual within the scope of license renewal are XI.E6, page XI.E6- inspection is used to tested on a one-time test basis or at least XI.E6-1 2, Lines 3-4 The phrase or at least once every 10 years adds once every 10 years, or periodically once confusion to the sentence. The need for 10 year every 5 years if only visual inspection is inspections due to findings of the initial one time used to provide an indication of the inspection is clearly stated in the sentence that follows integrity of the cable connections.

(Lines 5 - 6).

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E6-2 XI.E6-3, Element 5 Element 5 states Where practical, degradation is Recommend to restore the original Monitoring and projected until the next scheduled inspection. Results wording:

Trending, Lines 31 are evaluated against acceptance criteria to confirm Trending actions are not included as part

- 37 that the sampling bases (e.g., selection, size, of this AMP, because the ability to trend frequency) will maintain the components intended visual inspection and test results is functions throughout the subsequent period of dependent on the specific test or visual extended operation based on the projected rate and inspection program selected.

extent of degradation.

It is not practical to project degradation until the next scheduled inspection for a one-time confirmatory AMP.

XI.E6-3 XI.E6-3, Element 6 The standard phrase used in other electrical AMPs Editorial Acceptance defining unacceptable indication is missing. Recommend adding:

Criteria, An unacceptable indication is defined as a noted condition or situation that, if left unmanaged, could potentially lead to a loss of intended function.

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ATTACHMENT 4 Comment Location of Description of Change Justification for Change

1. Change XI.E6-4 XI.E6-4, Element 7 Element 7 includes the new paragraph Additional Recommend retaining the GALL Rev 2 Corrective Actions, inspections are conducted if one of the inspections does wording:

Lines 8 - 17 not meet the acceptance criteria due to current or If acceptance criteria are not met, the projected degradation (i.e., trending). The number of corrective action program is used to increased inspections is determined in accordance with perform an evaluation that considers the the sites corrective action process; however, there are extent of the condition, the indications of no fewer than two additional inspections for each aging effect, and changes to the one-time inspection that did not meet the acceptance criteria. testing program or alternative inspection The additional inspections are completed within the program. Corrective actions may include, interval (e.g., refueling outage interval, 10-year but are not limited to, sample expansion, inspection interval) in which the original inspection was increased inspection frequency, and conducted. Additional samples are inspected for any replacement or repair of the affected recurring degradation to ensure corrective actions cable connection components.

appropriately address the associated causes. At multi-unit sites, the additional inspections include inspections at all of the units with the same material, environment, and aging effect combination.

This scope expansion method does not align with a one-time confirmatory AMP.

XI.E7-1 XI.E7-1, Program The Program Description includes the phrase more Editorial Description, Line rapidly than expected when installed in a harmful Reword as follows: more rapidly than 13 environment. expected when installed in an harmful The environment should be stated in aging terms. environment conducive to aging.

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