ML12089A396

Entergy Pre-Filed Hearing Exhibit ENT000241, EN-DC-348, Rev. 2, Non-EQ Insulated Cables & Connections Inspection.

ML12089A396
Person / Time
Site:	Indian Point
Issue date:	07/05/2011
From:	Entergy Nuclear Operations
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML12089A391	List: ML12089A392 ML12089A394 ML12089A395 ML12089A396 ML12089A397 ML12089A400 ML12089A404 ML12089A405 ML12089A406 ML12089A407 ML12089A408 ML12089A409 ML12089A410 ML12089A411 ML12089A412 ML12089A414
References
RAS 22115, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 EN-DC-348, Rev 2
Download: ML12089A396 (31)

Text

ENT000241 Submitted: March 29, 2012 NUCLEAR NON-QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 1 OF 31 Non-EQ Insulated Cables and Connections Inspection Procedure Contains NMM eB REFLIB Forms: YES NO Effective Garry G. Young Procedure Owner: Governance Owner: Oscar Limpias Date Director, Business

Title:

Title: VP, Engineering Development (NUC) 07/05/2011 Site: Site: HQN HQN Exception Site Site Procedure Champion Title Date*

ANO William Greeson Manager, Programs & Components N/A BRP N/A GGNS IPEC Michael Tesoriero Manager, Programs & Components JAF Patrick Scanlan Manager, Programs & Components PLP Jim Miksa Manager, Programs & Components PNPS Steven Woods Manager, Programs & Components N/A RBS VY George Wierzbowski Manager, Programs & Components N/A W3 N/A NP HQN Luis Terrazas Manager, Programs & Components Site and NMM Procedures Canceled or Superseded By This Revision Palisades site procedure MSE-E-51, Visual Inspection of Accessible Cables and Connections Located in Adverse Localized Environments in the scope of License Renewal Process Applicability Exclusion: All Sites:

Specific Sites: ANO BRP GGNS IPEC JAF PLP PNPS RBS VY W3 Change Statement This revision adds applicability of this procedure and license renewal commitments in Section 8.0 to provide an aging management program for Non-EQ insulated cables and connections consistent with NUREG-1801,Section XI.E1 for ANO, PLP, and VY.

This is an editorial revision for IPEC, JAF, and PNPS. Minor editorial corrections are also made.

Initially, Revision 0 of this procedure was issued to provide an aging management program for Non-EQ insulated cables and connections consistent with NUREG-1801 section XL.E1 for IPEC, JAF, and PNPS.

Revision 1 was prepared to add applicability of the procedure for ANO, PLP, and VY. However, an error was made during the process and Revision 1 was classified as obsolete in eB Reflib (CR-HQN-2011-00474).

Therefore, the procedure is being revised as Revision 2 using the existing RAFs and PADs that were submitted for Revision 1 with concurrence to use the existing RAFs and PADs from the site procedure champions.

• Requires justification for the exception

NUCLEAR NON-QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 2 OF 31 Non-EQ Insulated Cables and Connections Inspection TABLE OF CONTENTS Section Title Page 1.0 PURPOSE ................................................................................................ 3

2.0 REFERENCES

.......................................................................................... 3 3.0 DEFINITIONS AND ABBREVIATIONS .................................................. 7 4.0 RESPONSIBILITIES .............................................................................. 10 5.0 DETAILS .............................................................................................. 12 5.1 SCOPE OF PROCEDURE..................................................................... 12 5.2 PRECAUTIONS AND LIMITATIONS ..................................................... 13 5.3 SPECIAL TOOLS AND EQUIPMENT (TYPICAL)................................ 13 5.4 INSPECTION PREPARATION .............................................................. 14 5.5 INSPECTION PERFORMANCE ............................................................ 17 5.6 POST-INSPECTION FINDINGS REVIEW AND DISPOSITION ......... 21 5.7 ACCEPTANCE CRITERIA ..................................................................... 21 5.8 CORRECTIVE ACTION ......................................................................... 21 6.0 INTERFACES ......................................................................................... 22 7.0 RECORDS .............................................................................................. 22 8.0 SITE SPECIFIC COMMITMENTS ......................................................... 23 9.0 ATTACHMENTS..................................................................................... 24 ATTACHMENT 9.1 CABLE CONDITIONS IDENTIFIED D URING PREVIOUS INSPECTION BY THE INDUSTRY ........................................... 25 ATTACHMENT 9.2 TYPICAL STRUCTURE LISTING ............................................. 28 ATTACHMENT 9.3 ALEE INSPECTION

SUMMARY

REPORT CONTENT ............... 29 ATTACHMENT 9.4 ADVERSE L OCALIZED EQUIPMENT ENVIRONMENT (ALEE)

INSPECTION DATA SHEET ................................................... 30

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 3 OF 31 Non-EQ Insulated Cables and Connections Inspection 1.0 PURPOSE This procedure fulfills the license renewal commitment to provide an aging management program for non-EQ insulated cables and connections. It provides administrative controls to inspect plant spaces occupied by non-EQ insulated cables and connectors, inspect cable insulation, and identify adverse localized equipment environments (ALEEs) that can cause premature aging.

2.0 REFERENCES

2.1 REGULATIONS AND GUIDANCE

[1] 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants

[2] NRC Documents (a) NUREG-1800, Rev. 1, Standard Review Plan for License Renewal Applications for Nuclear Power Plants, September 2005 (b) NUREG-1801 Volume 2 Rev. 1, Generic Aging Lessons Learned (GALL),

Chapter XI, Aging Management Programs (AMPs),Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, September 2005 (c) NUREG/CR-5643, Insights Gained from Aging Research, U.S. Nuclear Regulatory Commission, March 1992

[3] Industry Documents (a) NEI 95-10 Rev. 6, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, June 2005 (b) SAND 96-0344, Aging Management Guideline for Commercial Nuclear Power Plants - Electrical Cables and Terminations, September 1996

[4] EPRI Documents (a) EPRI Report No. 1013475, License Renewal Electrical Handbook, February 2007 (b) EPRI Report No. 1007933, Aging Assessment Field Guide, December 2003 (c) EPRI Report No. TR-109619, Guideline for the Management of Adverse Localized Equipment Environments, June 1999

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 4 OF 31 Non-EQ Insulated Cables and Connections Inspection 2.2 LICENSE RENEWAL APPLICATION LETTERS

[1] Arkansas Nuclear One - Unit 1 License Renewal Application Letters (a) Arkansas Nuclear One, Unit 1, ANO-1 Letter No. 1CAN010003 Enclosure, Dated January 31, 2000, License Renewal Application, Appendix B, Section 3.2 [ML003679667]

(b) Arkansas Nuclear One, Unit 1, ANO-1 Letter No. 1CAN010003 Enclosure, Dated January 31, 2000, License Renewal Application, Appendix A, Section 16.1.2 [ML003679667]

[2] Arkansas Nuclear One - Unit 2 License Renewal Application Letters (a) Arkansas Nuclear One, Unit 2, ANO-2 Letter No. 2CAN100302 Enclosure, Dated October 14, 2003, License Renewal Application, Appendix B, Section B.1.16 [ML032890492 and ML032930198]

(b) Arkansas Nuclear One, Unit 2, ANO-2 Letter No. 2CAN100302 Enclosure, Dated October 14, 2003, License Renewal Application, Appendix A, Section A.2.1.17 [ML032890492 and ML032930193]

[3] Palisades License Renewal Application Letters (a) Palisades Nuclear Plant, PLP Letter Enclosure, Dated March 22, 2005, License Renewal Application, Appendix B, Section B2.1.12 [ML050940434 and ML050940446]

(b) Palisades Nuclear Plant, PLP Letter Enclosure, Dated March 22, 2005, License Renewal Application, Appendix A, Section A2.12 [ML050940434 and ML050940446]

[4] James A. Fitzpatrick License Renewal Application Letters (a) James A. Fitzpatrick, JAF Letter No. JAFP-06-0109 Enclosure, Dated July 31, 2006, License Renewal Application, Appendix B, Section B.1.19

[ML062160491 and ML062160556]

(b) James A. Fitzpatrick, JAF Letter No. JAFP-06-0109 Enclosure, Dated July 31, 2006, License Renewal Application, Appendix A, Section A.2.1.21

[ML062160491 and ML062160553]

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 5 OF 31 Non-EQ Insulated Cables and Connections Inspection 2.2 cont.

[5] Pilgrim License Renewal Application Letters (a) Pilgrim Nuclear Power Station, PNPS Letter No. 2.06.003 Enclosure, Dated 1/25/06, License Renewal Application, Appendix B, Section B.1.21

[ML060300026, and ML060300028]

(b) Pilgrim Nuclear Power Station, PNPS Letter No. 2.06.003 Enclosure, Dated 1/25/06, License Renewal Application, Appendix A, Section A.2.1.23

[ML060300026, and ML060300028]

[6] Vermont Yankee License Renewal Application Letters (a) Vermont Yankee, VY Letter No. BVY 06-009 Enclosure, Dated January 25, 2006, License Renewal Application, Appendix B, Section B.1.19

[ML060300082 and ML060300085]

(b) Vermont Yankee, VY Letter No. BVY 06-009 Enclosure, Dated January 25, 2006, License Renewal Application, Appendix A, Section A.2.1.21

[ML060300082 and ML060300085]

[7] Indian Point Energy Center License Renewal Application Letters (a) Indian Point Energy Center Units 2 and 3, IPEC Letter No. NL-07-039 Enclosure, Dated April 23, 2007, License Renewal Application, Appendix B, Section B.1.25 [ML071210512 and ML071210523]

(b) Indian Point Energy Center Units 2 and 3, IPEC Letter No. NL-07-039 Enclosure, Dated April 23, 2007, License Renewal Application, Appendix A, Sections A.2.1.24 and A.3.1.24 [ML071210512 and ML071210520]

2.3 NRC DOCUMENTS

[1] Information Notices (a) Information Notice No. 84-01, Excess Lubricant in Electric Cable Sheaths, January 10, 1984 (b) Information Notice No. 86-49, Age/Environment Induced Electrical Cable Failures, June 16, 1986 (c) Information Notice No. 86-71, Recent Identified Problems with Limitorque Motor Operators, August 19, 1986

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 6 OF 31 Non-EQ Insulated Cables and Connections Inspection 2.3[1] cont.

(d) Information Notice No. 91-20, Electrical Wire Insulation Degradation Caused Failure in A Safety-Related Motor Control Center, March 19, 1991 (e) Information Notice No. 94-78, Electrical Component Failure Due to Degradation of Polyvinyl Chloride Wire Insulation, November 21, 1994 (f) Information Notice No. 2002-04, Wire Degradation at Breaker Cubicle Door Hinges, January 10, 2002

[2] Safety Evaluation Reports (SERs)

(a) NUREG-1743, Safety Evaluation Report Related to the License Renewal of Arkansas Nuclear One, Unit 1 [ML011640099, ML011640177, and ML011640217], May, 2001 (b) NUREG-1828, Safety Evaluation Report Related to the License Renewal of Arkansas Nuclear One, Unit 2 [ML051730233], June, 2005 (c) NUREG-1871, Safety Evaluation Report Related to the License Renewal of Palisades Nuclear Plant [ML062710074], January, 2007 (d) NUREG-1891, Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station [ML073241016], November 2007 (e) NUREG-1907, Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station [ML081430057 (Vol. 1),

ML081430109 (Vol. 2)], May, 2008 (f) NUREG-1905, Safety Evaluation Report Related to the License Renewal of James A. Fitzpatrick Nuclear Power Plant [ML080250372], April, 2008 (g) NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 [ML092240268], October, 2009 2.4 ENTERGY DOCUMENTS

[1] Entergy Quality Assurance Program Manual (QAPM)

[2] Procedures (a) EN-AD-101, Procedure Process (b) EN-AD-101-01, NMM Procedure Writer Manual

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 7 OF 31 Non-EQ Insulated Cables and Connections Inspection 2.4[2] cont.

(c) EN-HU-101, Human Performance Procedure (d) EN-LI-101, 10CFR50.59 Review Program (e) EN-RP-100, Radworker Expectations (f) EN-RP-110, ALARA Program (g) EN-TQ-104, ESP Training Program (h) EN-TQ-201, Systematic Approach to Training Process 3.0 DEFINITIONS AND ABBREVIATIONS 3.1 DEFINITIONS

[1] Accessible - Cables and connections that can be readily approached and easily viewed [Reference EPRI 1013475] (i.e. those that can be accessed without installing ladders or scaffolding). Cables and connections in enclosures such as cabinets, junction boxes, terminal boxes, condulets, etc., are considered inaccessible and are not included in this inspection.

[2] Adverse Localized Equipment Environment (ALEE) - A condition in a limited plant area that is significantly more severe than the specified service condition for the area.

The service conditions of interest include normal, abnormal, and error-induced conditions, prior to the start of a design-basis accident or earthquake. For example, areas with high temperature process fluid piping and vessels, areas with equipment that operates at high temperature, and areas with limited ventilation are prone to high temperatures [Reference EPRI TR-109619 and EPRI 1013475].

[3] Aging Effect - A change in a components characteristics that occur with time due to an aging mechanism. Embrittlement, cracking, melting, swelling, and discoloration of electrical insulation or jackets are examples of aging mechanisms [Reference EPRI 1013475].

[4] Aging Mechanism - The specific processes, environment, etc. that gradually change the characteristics of a system or component with time or use which can cause aging effects over a period of time [Reference EPRI 1013475].

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 8 OF 31 Non-EQ Insulated Cables and Connections Inspection 3.1 cont.

[5] Bounding Method or Approach - A license renewal scoping method that includes additional systems, structures or components/ commodities in the aging management review that do not meet the scoping criteria of 10 CFR 54.4 and would not have to be included. Using a bounding review provides the benefit of less time spent on scoping, without the omission of required components / commodities. This also allows a greater population for samples of accessible cables for the NUREG-1801, XI.E1 program [Reference EPRI 1013475].

[6] Connection - Device used to join or fasten together cable conductors to other cables or electrical devices. Connections or terminations include plug-in connectors, splices, terminal blocks, and fuse holders.

[7] Jacket Surface Anomalies - Anomalies or visual indications on the surface of cable and connection jacket material, such as embrittlement, discoloration, cracking, or surface contamination.

[8] Representative Sample - Accessible cables and connections that are located near an ALEE.

[9] Scoping - The application of 10 CFR 54.4 criteria to determine whether a system or component is within the scope of license renewal [Reference EPRI 1013475].

[10] Service Conditions - The normal physical influences that can affect a component over its service life. For the purposes of this procedure, service conditions include the environmental stressors of heat, radiation, and moisture. For most sites, the normal values of these parameters are listed in the environmental qualification (EQ) documents, but any approved document with service conditions can be used.

In cable applications, heat comprises an external component in the form of ambient temperature and an internal component in the form of ohmic heating. Ohmic heating is only associated with power cable applications. Instrumentation circuits characteristically operate at low currents and control circuits typically operate intermittently, so no appreciable ohmic heating occurs.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 9 OF 31 Non-EQ Insulated Cables and Connections Inspection 3.1 cont.

[11] Significant - Having or likely to have measurable influence. In general, an adverse variation in environment would be significant if it could appreciably increase the rate of component aging or have an immediate adverse effect on operability. An adverse environment is significant if it is in excess of the conditions considered in the design basis for systems and components. The user can establish a quantitative definition of significance or evaluate each environment on a case-by-case basis. For example, elevated temperature can cause equipment to age prematurely, so a rough approximation of the effect can be gained by use of the 10°C rule, which estimates that an organic materials life is halved for each 10°C (18°F) increase in temperature

[Reference EPRI TR-109619].

[12] Spaces Approach - A survey method focused on plant-wide areas rather than specific plant equipment, such as specific cables [Reference EPRI 1013475].

[13] Stressor - An agent or stimulus that stems from pre-service or service conditions and can produce immediate or long-term aging degradation of a component. Stressors result in aging mechanisms, which are specific processes that gradually change the characteristic of a component with time.

[14] Surface Contamination - The presence of a foreign substance, such as an oil, caustic chemical, etc., that could adversely affect the insulation resistance properties of a cable.

3.2 ABBREVIATIONS

[1] Table 3.2-1 provides a list of abbreviations used in this procedure.

Table 3.2-1 Abbreviation Meaning ALARA As Low As Reasonably Achievable ALEE Adverse Localized Equipment Environment ANO Arkansas Nuclear One CFR Code of Federal Regulations GALL Generic Aging Lessons Learned EAMR Electrical Aging Management Review EPRI Electric Power Research Institute EQ Environmental Qualification IPEC Indian Point Energy Center JAF James A. Fitzpatrick Nuclear Power Station LR License Renewal

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 10 OF 31 Non-EQ Insulated Cables and Connections Inspection Abbreviation Meaning LRA License Renewal Application NEI Nuclear Energy Institute NUREG Nuclear Regulatory Commission Regulation OCC Outage Control Center OE Operating Experience PCRS Paperless Condition Reporting System PLP Palisades Nuclear Plant PNPS Pilgrim Nuclear Power Station QAPM Quality Assurance Program Manual RP Radiation Protection RWP Radiation Work Permit SER Safety Evaluation Report SBO Station Blackout VY Vermont Yankee 4.0 RESPONSIBILITIES 4.1 Vice President, Engineering (HQN), is responsible for:

[1] The overall implementation of the license renewal commitment described in this procedure.

4.2 Director, Engineering (HQN), is responsible for:

[1] Providing corporate management and oversight for this procedure from a fleet perspective.

[2] Ensuring fleet focus and alignment of the implementation of this procedure.

[3] Ensuring fleet coordination of this procedure.

4.3 Director, Engineering (Site), is responsible for:

[1] Sponsoring all aspects of this procedure at the site.

4.4 Manager, Engineering Programs & Components (HQN), is responsible for:

[1] Standardizing the implementation of this procedure from site-to-site.

[2] Resolving conflicts that may arise in the interpretation of this procedure.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 11 OF 31 Non-EQ Insulated Cables and Connections Inspection 4.5 Manager, Engineering Programs & Components (site), is responsible for:

[1] Implementing all aspects of this procedure at the site.

[2] Ensuring that all activities associated with this procedure are performed in a timely and cost efficient manner commensurate with the risk and safety significance of the issue.

[3] Allocating adequate resources as necessary to implement this procedure.

[4] Ensuring inspection findings and observations are evaluated and resolved as necessary.

4.6 Supervisor, Engineering Programs & Components (site), is responsible for:

[1] Assigning a Program Coordinator to develop, implement, and maintain the sites license renewal aging management program commitments in accordance with this procedure.

[2] Ensuring the timely completion of inspections.

4.7 Design Engineering (Site) is responsible for:

[1] Supporting Program Coordinator in developing and maintaining a site specific procedure (if applicable) in accordance with this procedure.

[2] Supporting the development of acceptance criteria for degraded cable and connection insulation.

[3] Supporting the review of inspection findings, observations, and further evaluations of inspection anomalies.

4.8 Radiological Protection (site) is responsible for:

[1] Supporting the development of walkdown plans and work orders associated with this procedure.

[2] Providing special radiological work permits (RWPs) as needed for this procedure.

4.9 Planning and Scheduling (site) is responsible for:

[1] Developing work orders as applicable for performing inspections.

[2] Providing coordination with scheduled maintenance and outage activities.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 12 OF 31 Non-EQ Insulated Cables and Connections Inspection 4.10 Program Coordinator is responsible for:

[1] Identifying or requesting assignment of inspectors to complete the inspections associated with this procedure.

[2] Identifying the spaces/areas that are in scope and will be inspected.

[3] Providing engineering oversight and technical direction of field inspection activities.

[4] Reviewing and dispositioning inspection anomalies.

[5] Ensuring timely reporting of adverse trends in accordance with Corrective Action Process [Reference EN-LI-102].

[6] Ensuring inspectors have read and are familiar with industry cable aging identification, assessment, and management guidance documents [Reference EPRI 1003663 and EPRI 1011223].

4.11 Inspector is responsible for:

[1] Performing and documenting inspection plans, environment reviews, and OE searches.

[2] Identifying inspection anomalies that need additional Program Coordinator review.

[3] Understanding industry cable aging identification, assessment, and management guidance [Reference EPRI 1003663 and EPRI 1011223].

[4] Individuals performing walkdowns must be knowledgeable of EPRI guidance concerning cable aging mechanisms and cable aging inspection [Reference EPRI 1003317, EPRI 1003663, EPRI 1013475 and SAND 96-0344].

[5] Documenting the condition of cable and connections identified during the inspections.

[6] Initiating a condition report as required by EN-LI-102 for issues discovered during inspections.

5.0 DETAILS 5.1 SCOPE OF PROCEDURE

[1] Consistent with the guidance of NUREG-1801,Section XI.E1, the Non-EQ Insulated Cables and Connections Program will do the following.

(a) The procedure identifies all areas with ALEEs, which is based on the spaces approach.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 13 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.1[1] cont.

(b) All accessible electrical cables and connections in close proximity to any ALEE will be visually inspected for insulation or jacket surface anomalies, which is consistent with the bounding approach. A focus of this inspection is to distinguish cables exhibiting significant aging effects (i.e. deterioration) from those exhibiting little or no deterioration.

(c) The procedure identifies all insulated cables and connections (by conduit, cable tray, and/or cabinet number) exposed to an ALEE regardless of whether they are readily accessible and easily approached and viewed.

[2] The initial performance of this procedure shall commence prior to the expiration of the plants initial 40-year operating license, and shall be repeated every 10 years thereafter throughout the period of extended operation.

5.2 PRECAUTIONS AND LIMITATIONS

[1] Precautions (a) The non-EQ insulated cables and connections inspection may be performed in any plant operating mode; however, some plant locations may not be readily accessible during power operations or other plant evolutions. For inaccessible areas deemed of interest, the area may be inspected at another time. For example, when maintenance is performed on a component in a room or area, maintenance personnel may complete Attachment 9.4 as directed by the Program Coordinator.

[2] Limitations (a) The Non-EQ Insulated Cables and Connections Procedure activities contained herein consist of visual inspections only. Personnel performing visual inspections shall avoid physical contact with the cables and connections and other plant equipment.

5.3 SPECIAL TOOLS AND EQUIPMENT (TYPICAL)

[1] High-intensity flashlight (this equipment may not be suitable for all plant locations)

[2] Inspection mirror

[3] ALEE Inspection Data Sheet (Attachment 9.4) or equivalent

[4] Pens / pencils

[5] Clipboard / white board and marker (optional)

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[6] Voice-activated digital tape recorder (optional)

[7] Digital camera with optical zoom lens and flash (flash is optional and may not be suitable for all plant locations) - Video capability is another option

[8] Extra camera batteries and extra camera memory card

[9] Binoculars or spotting scope (optional)

[10] Hand-held thermometer

[11] Noncontact thermometer

[12] Standard personnel safety equipment

[13] Non-conductive tape measure (optional)

[14] Labels (optional) 5.4 INSPECTION PREPARATION

[1] Coordination with scheduled maintenance and outage activities via the Work Week Manager is recommended to facilitate access to cables and connections in plant areas not normally accessible during normal plant operation.

[2] Notify Radiation Protection (RP) of inspection plans prior to entering a Radiologically Controlled Area. Ensure Radiation Work Permits (RWPs) for these tasks are discussed.

[3] The inspectors shall review previous inspection reports prior to conducting the inspection ensuring previous ALEE areas are inspected for further degradation.

[4] The inspectors should conduct interviews with Maintenance, Engineering, and Operations personnel to collect anecdotal information relating to the existence of ALEEs and any known cable issues.

[5] The inspectors shall conduct a review of temperature monitoring data taken since the prior inspection and the design data found in the site environmental qualification (EQ) documents. The review shall be documented in the ALEE Inspection Data Sheet (Attachment 9.4). Significant increases in temperature readings may indicate a potential ALEE, and any such area(s) shall be thoroughly examined during the inspection.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 15 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.4 cont.

[6] The inspectors shall conduct an OE Review using the Paperless Condition Reporting System (PCRS), which includes industry OE since the date of the prior inspection or license renewal OE search. The review shall consider OE related to ALEEs, hot spots, environmental changes, cables, and insulating materials that may be related to the long-term performance of the cables within the scope of this procedure. The results shall be appropriately documented in Attachment 9.3. The following keyword phrases must be used as part of this OE search: high temperature, high radiation, moisture accumulation, sodium pentaborate leakage (BWR), boric acid leakage (PWR), and steam leaks. Additional words, terms, and phrases may be searched as determined appropriate by the Program Coordinator.

[7] The inspectors shall perform a review of current RP survey data, EQ data, or area radiation monitor data for areas containing in-scope cable. The purpose of this review is to determine the maximum general area dose rate and any hot spots within each room. The general area dose rate shall be compared to the values obtained during the most recent inspection. Significant increases in radiation readings may indicate a potential ALEE, and any such area(s) should be thoroughly examined during the walkdown (dependent on ALARA and RP considerations for personnel).

Note that the values may still be below the 60-year dose for insulating materials.

Areas below the 60-year dose still require walkdown for other potential non-radiation ALEEs such as temperature and moisture.

[8] Table 5.4-1 below identifies the common insulation materials for non-EQ insulated cables and connections along with the material 60-year service-limiting environments.

This table does not address ALEEs, moisture, or chemicals. Connections include connectors, splices, and terminal blocks (includes fuse block bases and terminals).

Insulation materials used in power and I&C applications are identified separately so that potential ohmic heating issues can be addressed for power cables and connections. Ceramic and glass materials are not identified below, since they do not have temperature or radiation aging effects that require management.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 16 OF 31 Non-EQ Insulated Cables and Connections Inspection Table 5.4-1 Materials, Applications, and 60-Year Service-Limiting Environments for Non-EQ Insulated Cable and Connection [Reference EPRI 1013475]

60-Year Design Service-Limiting Cables Connections Insulation Material Environment Power I&C Power I&C Temperature Radiation Dose Butyl Rubber, BR 9 125qF (51.8qC) 5 x 106 rads Chloroprene, Neoprene 9 9 107qF (41.7qC) 2 x 106 rads CSPE (Hypalon) 9 9 167qF (75.0qC) 2 x 106 rads Cross-linked Polyethylene, 9 9 188qF (86.6qC) 1 x 108 rads XLPE, XLP Epoxy, XR5126 9 150qF (65.7qC) 7 1 x 10 rads (Westinghouse)

EPDM 9 9 9 189qF (87.2qC) 5 x 107 rads EP, EPR 9 9 9 9 167qF (75.0qC) 5 x 107 rads 8

Halar, ECTFE 9 306qF (152.0qC) 1 x 10 rads 6

Hypalon (CSPE) 9 9 167qF (75.0qC) 2 x 10 rads HTK (Kerite) 9 185qF (85.2qC) 1 x 108 rads Kerite FR, FR (HC-711) 9 9 129qF (54.1qC) 5 x 107 rads Kerite FR, FR (HI-70) 9 9 141qF (60.8qC) 5 x 107 rads Kerite FR2, FR2 9 193qF (89.2qC) 5 x 107 rads 7

Kerite FR3, FR3 9 167qF (74.8qC) 5 x 10 rads 7

Melamine 9 9 205qF (96.2qC) 5 x 10 rads Nylon 9 119qF (48.5qC) 2 x 106 rads PE, HDPE, HMPE 9 9 112qF (44.4qC) 2 x 107 rads Phenolic 9 9 231qF (110.6qC) ~4 x 10 7 rads Polyalkene 9 190qF (87.5qC) 1 x 107 rads Polyimide (Kapton),

9 266qF (130.2qC) 2 x 108 rads Thermosets Polypropylene, PP 9 70qF (21.2qC) 5 x 106 rads PVC 9 9 9 112qF (44.4qC) 2 x 107 rads Polyvinyldine Fluoride, PVF 9 227qF (108.1qC) 1 x 107 rads (Kynar) 6 Silicone Rubber (SR) 9 9 9 273qF (133.9qC) 3 x 10 rads Teflon, FEP 9 9 647qF (341.7qC) 4 5 x 10 rads Tefzel 9 9 9 228qF (108.6qC) 3 x 107 rads XLPO, XLPE 9 9 9 9 188qF (86.6qC) 1 x 108 rads Western Cable Sleeve Fire 9 192qF (88.7qC) 1 x 108 rads Resistant-Nuclear, WCSF-N 9 indicates material application

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 17 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.4 cont.

[9] Inspectors shall prepare an inspection plan consisting of a specific listing of all locations that will be inspected based on in-scope structures. Lists of example structures are provided in Attachment 9.2.

[10] Based on the review of the RP dose maps and the planned inspection locations, the inspectors, with the assistance of radiation protection, shall develop a dose budget assessment for the inspection. The RP dose maps may be used during the inspection to identify potential or actual ALEE locations in relation to major structures or equipment.

[11] Credit may be taken for inspections performed prior to implementation of this procedure if deemed acceptable by the program coordinator.

[12] The inspectors shall review the inspection plan for each tour with appropriate plant personnel (i.e., RP, Operations, Work Week Manager, or the OCC). The review should highlight potential concerns and limitations such as limited or no flash photography near sensitive or open cabinets, limited or no high intensity flash lights, potential plant evolutions that may occur during the shift, etc. The review should include a protocol for conditions identified as affecting operability.

[13] The inspectors shall collect all required tools and equipment prior to the specific inspection and ensure that they are in good working order. The inspectors will ensure that camera batteries are charged, digital memory cards are unfilled, and any equipment requiring calibration has a current calibration sticker.

[14] The inspectors may review the EPRI Aged Cable Sample Box (if available), which contains many aged cable samples and is useful in illustrating the types of insulation or jacket degradation that can be caused by elevated temperatures. See EPRI Report No. 1001391 - Training Aids for Visual and Tactile Inspection of Electrical Cables for Detection of Aging.

5.5 INSPECTION PERFORMANCE

[1] The inspectors shall notify the Operations Shift Manager and, if required, contact RP prior to initiating the inspection.

CAUTION Cables shall not be touched or manipulated.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 18 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.5 cont.

[2] The inspectors shall use visual inspection only. No equipment, piping, cable, or connection is to be touched or manipulated by hand, with a tool, or instrument. This prohibition includes wiping the cable to remove dust to read cable markings.

[3] If the temperature in a room or area is much greater than normal for standard operating conditions, record the temperature. This reading does not require a high degree of accuracy, since it is intended to be only a general indication of room temperature. The recommended accuracy is +/-5°F. Inspectors should be aware of factors that may affect the room temperature and equipment service conditions, such as multi-train operation, equipment energization, outages, ventilation system operation, and outside ambient conditions. These should be noted during the inspection.

[4] For each plant area in the inspection plan, the accessible cables and connections shall be visually inspected to identify any evidence of an aging effect that could be caused by an ALEE (i.e., embrittlement, cracking, discoloration, etc).

The areas most likely to contain an ALEE are those containing or near the following equipment.

x Pits x Feedwater piping, feedwater heaters, and moisture separators x Main steam piping, steam driven pumps, and the condenser components x Area and room space heaters x Energized electrical equipment x Operating equipment x Steam piping (auxiliary, heating, etc.)

x Leaking components or piping x Fluorescent lighting x High intensity incandescent lighting x Radiation hot spots

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 19 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.5 cont.

[5] The inspectors should also note any of the following on Attachment 9.4.

x Evidence of sodium pentaborate (BWR) x Evidence of boric acid (PWR) x Unusual vibrations x Unusual sounds x Unusual odors x Corrosion / rusting x Any liquid accumulation / wet areas

[6] Although not required by the procedure activities, observed design or installation deficiencies should be noted on Attachment 9.4.

[7] For any suspected temperature ALEEs, a noncontact thermometer shall be used to measure the temperature of the suspected temperature ALEE. The inspectors shall document on Attachment 9.4 the precise location of the ALEE for further investigation as needed.

[8] For identified ALEEs, visually inspect all accessible electrical equipment in the affected zone of the ALEEs. Typically, cables and connections within 3 feet of steam and high temperature process piping shall be inspected and the results documented on Attachment 9.4.

[9] Accessible cables and connections in the affected zone of ALEEs shall be visually inspected for the following physical characteristics that are indications of insulation or jacket degradation [Reference EPRI 1003663].

x Discoloration - compare the color in the vicinity of the ALEE with a section of cable or a connector away from the ALEE.

x Swelling or blistering x Evidence of melting or glazing x Cracking, splitting, or crazing x Surface contamination or green ooze

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 20 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.5 [9] cont.

x White powdery coating

[10] In the event evidence of an ALEE is found, record cable, cable tray, or conduit markings and distinguishing features on Attachment 9.4 for identification during subsequent inspections.

CAUTION The use of flash photography may be limited or excluded in some plant locations.

[11] The inspectors shall take clear digital images of any suspected ALEE sources and cables and connections in the immediate area. To assist in locating the ALEEs at a later date, the inspector should take an additional wide-angle photograph of the general area to orient the ALEE within the plant. Photograph numbers shall be recorded on Attachment 9.4. In addition to using multiple photos, the written description should include:

x Nearest column x Direction of the photo (i.e., looking up at ceiling, horizontal) x Approximate height from floor elevation x Any other directional bearings (e.g., north wall, painted markings on floor, etc.)

If necessary, have personnel point at a discrepancy in photo or add graphics and text description to photos. The use of a white board and marker to note the location and cable run may be used in the field of the picture to ensure that the information is accurately transmitted.

[12] The inspectors shall document all findings on Attachment 9.4 and attach additional notes, comments, or drawings. A determination of the extent of degradation, its effect on operability of the cable, or the extent of condition is not required to be performed during the inspection.

[13] For ALARA consideration, other devices such as a voice-activated digital tape recorder may be used to document inspections. The voice recording may then be transcribed to Attachment 9.4.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 21 OF 31 Non-EQ Insulated Cables and Connections Inspection 5.6 POST-INSPECTION FINDINGS REVIEW AND DISPOSITION

[1] Upon completion of inspection activities, inspectors shall conduct a post-inspection de-brief with the Program Coordinator. The Program Coordinator will determine if any additional activities or notifications are required based on the results presented.

[2] The Program Coordinator shall perform a post-inspection review of the findings and observations in accordance with Section 6 of Attachment 9.4.

5.7 ACCEPTANCE CRITERIA

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

[2] An unacceptable indication is a condition or situation that, if left unmanaged, could lead to a loss of intended function. Evaluation of the condition should consider the age and operating environment of the component, severity of the anomaly, and whether such an anomaly has previously been correlated to degradation of conductor insulation or connections.

[3] Attachment 9.1 (Cable Conditions Identified During Previous Inspections by the Industry) provides industry information concerning various cable conditions that could be identified during the inspections, and possible causes for those indications.

5.8 CORRECTIVE ACTION

[1] Attachment 9.4 shall document the as-found plant conditions, anomalies, and adverse plant conditions. No attempt shall be made to rectify, change, clean, or otherwise correct the As-Found condition. Each finding shall be reviewed by the Program Coordinator and addressed through the appropriate procedures which may include the corrective action process [Reference EN-LI-102], housekeeping

[Reference EN-MA-132], or work management process [Reference EN-WM-101].

Conditions requiring Engineering evaluations shall be directed to the applicable Engineering Manager as appropriate.

[2] ALEEs shall be reviewed to determine the potential effects on accessible and inaccessible cable and to determine the extent of the effect. Note that the NUREG-1801, XI.E1 program is a visual inspection of readily accessible cables. However, all cables affected by an ALEE, even those cables that may not be accessible for visual inspection, must be considered in the evaluation by the Program Coordinator.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 22 OF 31 Non-EQ Insulated Cables and Connections Inspection 6.0 INTERFACES 6.1 PROCEDURES

[1] EN-LI-102, Corrective Action Process

[2] EN-MA-132, Housekeeping/Facility Grounds Maintenance

[3] EN-AD-103, Document Control and Records Management Programs

[4] EN-DC-147, Engineering Reports

[5] EN-DC-178, System Walkdowns

[6] EN-WM-101, On-line Work Management Process 6.2 INDUSTRY DOCUMENTS

[1] EPRI (a) EPRI Report No. 1003663, Integrated Cable System Aging Management Guidance, January 2003 (b) EPRI Report No. 1011223, Aging Identification and Assessment Checklist, January 2005 (c) EPRI Report No. 1003317, Cable System Aging Management, April 2002 (d) EPRI Report No. 1001391, Training Aids for Visual and Tactile Inspection of Electrical Cables for Detection of Aging, March 2002 7.0 RECORDS 7.1 ACCEPTANCE VERIFICATION AND SIGNOFF - FINAL CONDITIONS

[2] Document inspection findings on Attachment 9.4.

[3] A listing of all areas inspected and the information from Attachment 9.4 shall be included in an engineering report following the outline shown in Attachment 9.3

[Reference EN-DC-147].

[4] Perform a post-inspection de-brief with all inspectors and the Program Coordinator.

[5] The Program Coordinator shall review all documented ALEEs and cable findings and determine appropriate further actions.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 23 OF 31 Non-EQ Insulated Cables and Connections Inspection 7.1 cont.

[6] The Summary Report shall be submitted to Administrative Services Group in accordance with EN-AD-103.

8.0 SITE SPECIFIC COMMITMENTS Step Site Document Commitment Number or Reference All ANO-1 1CAN010003 NRC Commitment A-17874, License Renewal, Implement new electrical component inspection program and maintain program as described in the source documents All ANO-2 2CAN100302 NRC Commitment A-17923, License Renewal, Implement and maintain non-EQ insulated cables and connections program All JAF JAFP-06-0109 NRC Commitment Number A-18352, Action #11 of CR-LAR-2008-0048, License Renewal, Implement and maintain the Non-EQ Insulated Cables and Connections Program as described in LRA Section B.1.19 All PLP Letter 3/22/05 RLC 01038742-01, "Non-EQ Commodities Condition Monitoring," License Renewal, Develop and implement non-EQ commodities condition monitoring program (MSE-E-51)

All PNPS LTR 2.07.029 NRC Commitment RC07-2029-17; License Renewal, Implement the Non-EQ Insulated Cables and Connections Program as described in LRA Section B.1.21 All IP2 NL-07-039 NRC Commitment LAR-2008-130-17, License Renewal, Implement Non-EQ Insulated Cables and NL-07-153 Connections Program as described in LRA Section B.1.25 All IP3 NL-07-039 NRC Commitment LAR-2008-130-17, License Renewal, Implement Non-EQ Insulated Cables and NL-07-153 Connections Program as described in LRA Section B.1.25 All VY BVY 06-009 NRC Commitment A-16784, License Renewal, Implement Non-EQ Insulated Cables and Connections Program as described in LRA Section B.1.19

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 24 OF 31 Non-EQ Insulated Cables and Connections Inspection 9.0 ATTACHMENTS 9.1 CABLE CONDITIONS IDENTIFIED DURING PREVIOUS INSPECTIONS BY THE INDUSTRY 9.2 TYPICAL STRUCTURE LISTING 9.3 ALEE INSPECTION

SUMMARY

REPORT CONTENT 9.4 ADVERSE LOCALIZED EQUIPMENT ENVIRONMENT (ALEE) INSPECTION DATA SHEET

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 25 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.1 CABLE CONDITIONS IDENTIFIED D URING PREVIOUS INSPECTION BY THE INDUSTRY Sheet 1 of 3 Condition Cause Comment Bubbles Moisture under jacket Single conductor power cables were identified where (manufacturing water ran out between the strands of the conductor.

defect) The water was condensate from steam used in the insulation vulcanizing process.

Blisters, (1) Excess heat from Bare high-temperature feedwater line and pipe flange Brittle, or either current load or whose thermal insulation had been removed during Burned external source repair work and had not been replaced. See IN 86-49.

(hot spot) Burn damage to internal wiring in Limitorque motor operators was caused by electric heater elements in (2) Excess radiation the limit switch compartment. Wires were close to (or in contact with) the heater element or bracket. The wiring was not properly routed and was not restrained from contacting the heater element or bracket. See IN 86-71 Cracked (1) Severe aging Wire degradation at breaker cubicle door hinges degradation caused by wires being forced into the side of the breaker cubicle when the cubicle door is closed. The wire on the inside of the bend exceeds the minimum (2) Mechanical bend radius, resulting in cold-working of the strands.

damage Subsequent cycling of the door eventually results in wire failure. See IN 2002-04.

(3) Ultraviolet Several dozen wires made with high density radiation from polyethylene (HDPE) and installed in the control room fluorescent lights of the Pilgrim nuclear plant were discovered to have circumferential cracks. Wires with white insulation contained the cracks, but identical wires that had blue and black insulation did not have any cracks. There was no apparent heat source. A special type of aging may have occurred, namely, degradation of polyethylene caused by ultraviolet (UV) radiation emitted by fluorescent lights. The white-colored insulation did not contain sufficient carbon black (~3%)

to inhibit the degrading effects of UV.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 26 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.1 CABLE CONDITIONS IDENTIFIED D URING PREVIOUS INSPECTION BY THE INDUSTRY Sheet 2 of 3 Condition Cause Comment Crystals Sodium pentaborate drip Discolored (1) Initial aging (2) Chemical spill Dull (1) Normal - new (2) Chemical spill Green Plasticizer from PVC Plasticizers are organic liquids or solids that are added Ooze to hard or tough resins to make them more flexible. A vegetable-oil plasticizer in PVC insulation or jacket, which decomposes at high temperatures, oxidizes and then interacts with the copper conductor.

A black or green sticky gel underneath the insulation can result from the interaction of corrosion on the surface of the copper conductor with the chlorine leaching from the PVC. See IN 91-20 and 94-78 Limp (1) Aging process for certain materials (2) Chemical spill Oily (1) Manufacturing Oily fluid seeping from cut ends of Okonite power and defect control cables was caused by the application of excess lubricant to the surface of filler materials (2) Oil/Chemical spill covering the conductors of multi-conductor cables.

See IN 84-01 Red Goo Adhesive from heat-at Splice shrink material flowed out of splice.

Shiny (1) Normal - new (2) Chemical spill

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 27 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.1 CABLE CONDITIONS IDENTIFIED D URING PREVIOUS INSPECTION BY THE INDUSTRY Sheet 3 of 3 Condition Cause Comment Slimy Wetting and biological growth Stiff (1) Normal - new (2) Intermediate aging process for some materials Swollen (1) Moisture absorption (2) Chemical spill Sticky or (1) External -

Tacky chemical or oil spill A black or green sticky gel underneath the insulation (2) Internal plasticizer can result from the interaction of corrosion on the surface of the copper conductor with the chlorine leaching from the PVC. See IN 91-20 and 94-78 White Bloom from PVC Bloom is a visible exudation (oozing) of Dust jacket efflorescence on the surface of a material. That is, the cable surface becomes covered with a powdery crust from the loss of water of crystallization. Bloom can indicate that PVC has aged over 50% of its thermal life.

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 28 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.2 T YPICAL STRUCTURE LISTING Sheet 1 of 1 TYPICAL BWR STRUCTURE LISTING Auxiliary Boiler Room Administration Building Containment Atmosphere Dilution Building Chlorine Addition Building Emergency Diesel Generator Building Intake Structure Primary Access Security Primary Containment Reactor Building Radwaste Building Secondary Access Security Stack and Iodine Building Switchyard Control Building Turbine Building Training Building Warehouse Yard Areas TYPICAL PWR STRUCTURE LISTING Administration Building Auxiliary Building Containment Building Emergency Diesel Generator Building Intake Structure Primary Access Security Radwaste Building Secondary Access Security Switchyard Control Building Turbine Building Training Building Warehouse Yard Areas

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 29 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.3 ALEE INSPECTION

SUMMARY

REPORT C ONTENT Sheet 1 of 1 The ALEE and Cable and Connection Inspection Summary Report shall be generated after the inspections are complete. The information shall be submitted to the Administrative Services Group in accordance with EN-AD-103. The following report sections shall be included. Other sections may be included as necessary [Reference EN-DC-147].

1. Purpose

2. Scope

3. Input Documents

4. Detailed Discussion - Including but not limited to the following:

x Process and Methods x Periods of Performance x Pre-job Briefing x Team Participants x Interviews x Tools and Equipment x Inspection Items

5. Operating Experience

6. Summary of Results x Inspection Results x General Plant Observations

7. Conclusions

8. Recommendations

9. References

10. Attachments Potential Attachments:

x Attachment A - Inspection Location List x Attachment B - Inspection Summary x Attachment C - Inspection Details and Photos

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 30 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.4 ADVERSE L OCALIZED EQUIPMENT ENVIRONMENT (ALEE) INSPECTION DATA SHEET Sheet 1 of 2 Section 1: Room / Area Location Data Plant: _________________________ Unit:_____ Building: __________________

EQ Zone (Number): ___________________ Elevation: _______________

Room

Description:

Unit Operating Status:_____________________________________________________

Section 2: Design and Operating Data EQ Zone Temperature ____________________________________________________

Results from Temperature History Review ___________________________________

Results from OE/PCRS Review _____________________________

Normal Operational Area Dose _____________________________

Highest Hot Spot Dose ____________________________

Radiation Protection Survey Map Attached: No Yes Section 3: Inspection Data General Area Temperature in the EQ Zone ____________________________

Temperature ALEEs in the EQ Zone Degrees Fahrenheit Location - Raceway/Equipment #, etc Section 4: ALEE Determination ALEE Present: Yes No Indicate Types Below (Thresholds in accordance with EAMR):

Temperature (>112qF) Radiation (>3805 mrad/hr)

Moisture (any signs) Fluorescent Lighting (w/in 6 in.)

Other (Specify):

NUCLEAR NON -QUALITY RELATED EN-DC-348 REV. 2 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 31 OF 31 Non-EQ Insulated Cables and Connections Inspection ATTACHMENT 9.4 ADVERSE L OCALIZED EQUIPMENT ENVIRONMENT (ALEE) INSPECTION DATA SHEET SHEET 2 OF 2 Section 5: Cable Information Provide Inspection Details (attach additional numbered sheets if needed):

Cable Nos (if known): _______________________________________________________

Document all Vendor Data printed on cable(s):

Photographs Taken: Yes No  ; Provide Photo Numbers: _____________________

Observer Name (print) and Signature / Date: Verifier Name (print) and Signature / Date Section 6: Program Coordinator Review and Disposition CR: No Yes # ________________ Engineering Review No Yes Program Coordinator Name (print) Signature Date Section 7: Engineering Review CR required No Yes CR# ________________

Engineering Manager Name (print) Signature Date