ML17097A491: Difference between revisions

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{{#Wiki_filter:ATTACHMENT 4 NUREG-2191 and NUREG-2192 (February 2017 Draft)
{{#Wiki_filter:ATTACHMENT 4 Page 1 of 20 NUREG-2191 and NUREG-2192 (February 2017 Draft)
Electrical Comments Comment     Location of Description of Change                             Justification for Change
Electrical Comments Comment Location of Change Description of Change Justification for Change Table VI.A-1 GALL VI.A, Table line items for Metal Enclosed Bus and GALL XI.E4 The GALL XI.E4 AMP includes discussion of elastomers for metal enclosed bus, through program description and elements. The line item for elastomers in metal enclosed bus in the GALL table in VI.A has been deleted per the last entry of the table.
    #          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.
Editorial - content inconsistency Re-include line item VI.A.LP-29 in Table 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 VI.A-2 GALL VI.A, Table line items for Cable Bus Comment Table VI.A-1 above may also apply to cable bus. The first deleted line item at the end of the table deleted elastomers for cable bus.
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.
Editorial - content inconsistency Re-include line item VI.A.LP-08 in Table 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 VI.A-3 GALL VI.A, Table line VI.A.LP-33 The AMP name provided in the table does not match the new GALL SLR AMP name in GALL section XI.E1.
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.
Editorial - content inconsistency Change AMP title to Electrical Insulation Material for Electrical Table VI.A-4 GALL VI.A, Table line VI.A.LP-34 The AMP name provided in the table does not match the new GALL SLR AMP name in GALL section XI.E2.
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.
Editorial - content inconsistency Change AMP title to Electrical Insulation Material for Electrical Table VI.A-5 GALL VI.A, Table line VI.A.LP-47 Should include AAC conductor as well Editorial - content inconsistency Add AAC.
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.
Table VI.A-6 GALL VI.A, Table line VI.A.LP-48 This line item component name should be Transmission conductors connectors.
Page 1 of 20
Editorial - content error Change Transmission conductors connectors.
X.E1-1 X.E1-5, EQ Program Description, Lines17 - 18 The wording implies that all the passive EQ equipment will be inspected every 10 years to determine if they are in an ALE.
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.
Editorial - content clarification See Comment X.E1-2


ATTACHMENT 4 Comment   Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 2 of 20 Comment Location of Change Description of Change Justification for Change X.E1-2 X.E1-6, Element 4.
    #        Change X.E1-2 X.E1-6, Element 4. Element 4 states Visual inspection of accessible,       Recommend:
Detection of Aging Effects; Lines 37 -
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.
40 Element 4 states Visual inspection of accessible, passive EQ equipment is performed at least once every 10 years. The purpose of the visual inspection is to identify adverse localized environments that may impact qualified life. Potential adverse localized environments are evaluated through the applicants corrective action program.
The wording implies that all the passive EQ equipment will be inspected every 10 years to determine if they are in an ALE.
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.
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.
Recommend:
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.
Visual inspection of accessible, passive EQ equipment in adverse localized environments is performed at least once every 10 years. The purpose of the visual inspection is to identify adverse localized environments conditions that may impact qualified life. Passive EQ equipment in potential adverse localized environments are is evaluated through the applicants corrective action program.
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.
XI.E1-1 XI.E1-3, Element 4 Detection of Aging Effects, Lines 28-30 Testing was removed as a requirement for this program, and testing is now based on an engineering evaluation via the corrective action program. However, a sentence was left in Element 4, page XI.E1-3, Lines 28-30 which states A sample of accessible electrical cables and connections are tested for reduced electrical insulation resistance.
Page 2 of 20
Editorial This sentence should be removed.
XI.E1-2 XI.E1-4, Element 4 Detection of Aging Effects, Line 1 Element 4, page XI.E1-4, line 1 states: this AMP, then testing is performed for evaluation.
Editorial Since testing is now based on an engineering evaluation via the corrective action program, change this sentence to read then testing is may be performed for evaluation, or testing, if deemed necessary, is performed for evaluation.  


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 3 of 20 Comment Location of Change Description of Change Justification for Change XI.E2-1 XI.E2-1, Program Description, Line 18 The Program Description states An adverse localized environment is based on the most limiting environment  
    #        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...
... ALEs are not based on limiting environments, they exceed the most limiting environments.
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).
Editorial Reword the sentence as follows: An adverse localized environment is based on exceeds the most limiting environment...
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.
XI.E3A-1 XI.E3A-1, Program Description, Lines 10 - 14)
cables under consideration. Also, the term               Above ground cable is managed by the underground in this AMP is consistent with the         XI.E1 AMP.
The Program Description states that This AMP applies to all inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) medium voltage cables within the scope of subsequent license renewal (SLR) exposed to wetting or submergence (i.e., significant moisture).
definition given in Table IX.D as used for mechanical components.
The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the 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.
Also, the phrase wetting or submergence does not match the description of significant moisture given in Lines 28 - 30.
match the description of significant moisture given in Lines 28 - 30.
Change the scope statement to read This AMP applies to all inaccessible or underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) medium voltage cables within the scope of subsequent license renewal (SLR) exposed to wetting or submergence (i.e., significant moisture).
This change aligns XI.E3A, XI.E3B, and XI.E3C.
The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.
Page 3 of 20
Above ground cable is managed by the XI.E1 AMP.
The proposed change eliminates confusion between wetting or submergence and significant moisture.
This change aligns XI.E3A, XI.E3B, and XI.E3C.  


ATTACHMENT 4 Comment     Location of Description of Change                         Justification for Change
ATTACHMENT 4 Page 4 of 20 Comment Location of Change Description of Change Justification for Change XI.E3A-2 XI.E3A-1, Program Description, Lines 22 - 24 The Program Description states Electrical insulation subjected to wetting or submergence could have an adverse effect on operability, or potentially lead to failure of the cable insulation system.
    #        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.
Editorial Regulatory link when not necessarily the case, between aging degradation and 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:
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.
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.  
Page 4 of 20


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 5 of 20 Comment Location of Change Description of Change Justification for Change XI.E3A-3 XI.E3A-2, Scope of Program, Lines 30
    #        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 The scope of program states that This AMP applies to inaccessible or underground medium voltage (2kV to 35kV) power cable installations (e.g., direct buried, buried conduit, duct bank, embedded raceway, cable trench, vaults, or manholes) within the scope of subsequent license renewal exposed to significant moisture.
        - 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.,
The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.
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.
Change the scope statement to read This AMP applies to inaccessible or underground medium voltage (2kV to 35kV) power cable installations (e.g.,
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.
direct buried, buried conduit, duct bank, underground embedded raceway, underground cable trench, vaults, or manholes) within the scope of subsequent license renewal exposed to significant moisture.
inaccessible is not needed to properly describe the    Above ground cable is managed by the cables under consideration. Also, the term               XI.E1 AMP.
The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.
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.
Above ground cable is managed by the XI.E1 AMP.
XI.E3C.
This change aligns XI.E3A, XI.E3B, and 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.
XI.E3A-4 XI.E3A-2, Scope of Program, Line 35 Extra parenthesis; (that should read that Editorial Editorial - remove the stray parenthesis.  
Page 5 of 20


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 6 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-1 XI.E3B-1, Program Description, Lines 10 - 13 The Program Description states that This AMP applies to inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of subsequent license renewal (SLR) exposed to significant moisture.
    #        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.
The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.
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.
Change the scope statement to read This AMP applies to inaccessible or underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of subsequent license renewal (SLR) exposed to significant moisture.
cables under consideration. Also, the term               Above ground cable is managed by the underground in this AMP is consistent with the         XI.E1 AMP.
The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.
definition given in Table IX.D as used for mechanical components.
Above ground cable is managed by the XI.E1 AMP.
This change aligns XI.E3A, XI.E3B, and XI.E3C.
This change aligns XI.E3A, XI.E3B, and XI.E3C.  
Page 6 of 20


ATTACHMENT 4 Comment     Location of Description of Change                             Justification for Change
ATTACHMENT 4 Page 7 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-2 XI.E3B-1, Program Description, Lines 24 - 26 The Program Description states mitigated in service, could have an adverse effect on operability, may lead to multiple random failures of the cable insulation system, and compromise system defense-in-depth.
    #        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.
Editorial Regulatory link when not necessarily the case, between aging degradation and operability, multiple random failures or defense in depth.
Operability, multiple random failures, or defense in depth; and intended functions may be related or may be separate.
Operability, multiple random failures, or defense in depth; and intended functions may be related or may be separate.
Revise as suggested:
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.
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 XI.E3B-1, Program Description, Line 41 The Program Description states that If required, initial testing is performed once by utilizing sampling to 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.
Sampling cannot determine the condition of the electrical insulation. It is used to establish the test population.
Page 7 of 20
Editorial Change the sentence to read If required, initial testing is performed once by utilizing sampling on a sample population to determine the condition of the electrical insulation.  


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 8 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-4 XI.E3B-2, Program Description, Lines 1-2 New text in this AMP states: Inaccessible instrumentation and control cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test.
    #        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 is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and testing for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for 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..
Requirements should be the same as cables that are not designed for submergence.
Page 8 of 20
Delete the referenced text and revise the text on page XI.E3B-1, Lines 10 - 13 as follows: This AMP applies to inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable tranches, cable troughs, duct banks, 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..  


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 9 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-5 XI.E3B-2, Element 1, Scope of Program, Lines 18
    #          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.
- 21 The scope of program states that This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of SLR, exposed 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
The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.
        - 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.
Change the scope statement to read This AMP applies to inaccessible and underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of SLR, exposed to significant moisture.
cables under consideration. Also, the term               Above ground cable is managed by the underground in this AMP is consistent with the         XI.E1 AMP.
The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.
definition given in Table IX.D as used for mechanical components.
Above ground cable is managed by the XI.E1 AMP.
This change aligns XI.E3A, XI.E3B, and XI.E3C.
This change aligns XI.E3A, XI.E3B, and XI.E3C.  
Page 9 of 20


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 10 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-6 XI.E3B-2, Element 1 Scope of Program, Lines 35-38 New text in this AMP states: Cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test where additional tests and periodic visual inspections are determined by the test/inspection results and industry and plant-specific aging degradation OE with the applicable cable electrical insulation.
    #        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.
This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and test for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for 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.
Requirements should be the same as cables that are not designed for submergence.
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.
Delete the referenced text and revise the text on page XI.E3B-2, lines 18 - 21 as follows: This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control 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.
XI.E3B-7 XI.E3B-3, Element 4 Detection of Aging Effects, Lines 43-45 The industry proposed visual manhole inspections for accumulation of water. If water was found affecting cables, the cables would be evaluated to determine if testing is required. If no water was found affecting cables, no further action was required until the next manhole inspection for water accumulation. The revised GALL adds a requirement to perform a visual cable inspection at least once every 6 years regardless of the effects of water.
effects of water.
The requirement for visual inspection of the cable at least every 6 years should be changed to at least every 10 years to align with similar ALE inspections in other AMPs. Periodic inspection of manholes for water accumulation will provide further opportunities for identification of potential adverse effects on cable.
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:
XI.E3B-8 XI.E3B, Element 5 Monitoring and Trending, Lines 39
Trending, Lines 39 programs that are implemented in similar manners. The     However, condition monitoring cable
- 41 The last sentence of Element 5 is not consistent with Element 5 in XI.E3C. XI.E3B and XI.E3C are similar programs that are implemented in similar manners. The last sentence of Element 5 should be the same for both AMPs.
        - 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.
Revise the last sentence of Element 5 as follows:
Page 10 of 20
However, condition monitoring cable tests and inspection results that utilize the same visual or test methods that are trendable and repeatable provide additional information on the rate of cable insulation degradation.  


ATTACHMENT 4 Comment     Location of Description of Change                             Justification for Change
ATTACHMENT 4 Page 11 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-9 XI.E3B-5, Element 7 Corrective Actions, Lines 21 -
    #        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.
22 The scope expansion method does not align with this one-time confirmatory test portion of this AMP. The periodic man-hole inspection portion of this AMP is 100%; there is nothing to expand.
Actions, Lines 21 - periodic man-hole inspection portion of this AMP is 22                  100%; there is nothing to expand.
Recommend removing the 2nd paragraph in its entirety.
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.
XI.E3C-1 XI.E3C-1, Program Description, Lines 12-15 The scope of program states that This AMP applies to all inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of subsequent license renewal (SLR) exposed to 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.
The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.
cables under consideration. Also, the term               Above ground cable is managed by the underground in this AMP is consistent with the         XI.E1 AMP.
Change the scope statement to read This AMP applies to all inaccessible and underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of subsequent license renewal (SLR) exposed to significant moisture.
definition given in Table IX.D as used for mechanical components.
The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.
This change aligns XI.E3A, XI.E3B, and XI.E3C.
Above ground cable is managed by the XI.E1 AMP.
Page 11 of 20
This change aligns XI.E3A, XI.E3B, and XI.E3C.  


ATTACHMENT 4 Comment     Location of Description of Change                             Justification for Change
ATTACHMENT 4 Page 12 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-2 XI.E3C-1, Program Description, Lines 23 - 26 :
    #        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.
The Program Description states such as submergence represents an aging mechanism that if not anticipated in design or mitigated in service, could have an adverse effect on operability, may lead to multiple random failures of the cable insulation system, and compromise system defense-in-depth.
and compromise system defense-in-depth.
Editorial Regulatory link when not necessarily the case, between aging degradation and operability, multiple random failures or defense in depth.
Operability, multiple random failures, or defense in depth; and intended functions may be related or may be separate.
Operability, multiple random failures, or defense in depth; and intended functions may be related or may be separate.
Revise as suggested:
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.
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 XI.E3C-1, Program Description, Line 40 The Program Description states that If required, initial testing is performed once by utilizing sampling to 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.
Sampling cannot determine the condition of the electrical insulation. It is used to establish the test population.
Page 12 of 20
Editorial Change the sentence to read If required, initial testing is performed once by utilizing sampling on a sample population to determine the condition of the electrical insulation.  


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 13 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-4 XI.E3C-1, Program Description, Lines 42-44 New text in this AMP states: Inaccessible low-voltage power cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test.
    #        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.
This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and testing for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for 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..
Requirements should be the same as cables that are not designed for submergence.
Page 13 of 20
Delete the referenced text and revise the text on page XI.E3C-1, Lines 12 - 15 as follows: This AMP applies to inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable tranches, cable troughs, duct banks, 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..  


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 14 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-5 XI.E3C-2, Element 1, Scope of Program, Lines 16
    #          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.
- 19 The scope of program states that This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of SLR exposed to 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
The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.
        - 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.
Change the scope statement to read This AMP applies to inaccessible and underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of SLR exposed to significant moisture.
cables under consideration. Also, the term               Above ground cable is managed by the underground in this AMP is consistent with the         XI.E1 AMP.
The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.
definition given in Table IX.D as used for mechanical components.
Above ground cable is managed by the XI.E1 AMP.
This change aligns XI.E3A, XI.E3B, and XI.E3C.
This change aligns XI.E3A, XI.E3B, and XI.E3C.  
Page 14 of 20


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 15 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-6 XI.E3C-2, Element 1 Scope of Program, Lines 28-32 New text in this AMP states: Cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test where additional tests and periodic visual inspections are determined by the test/inspection results and industry and plant-specific aging degradation OE with the applicable cable electrical insulation.
    #        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.
This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and test for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for 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.
Requirements should be the same as cables that are not designed for submergence.
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.
Delete the referenced text and revise the text on page XI.E3C-2, lines 16 - 19 as follows: This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power 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-7 XI.E3C-4, Element 4 Detection of Aging Effects, Lines 38 - 39 The industry proposed visual manhole inspections for accumulation of water. If water was found affecting cables, the cables would be evaluated to determine if testing is required. If no water was found affecting cables, no further action was required until the next manhole inspection for water accumulation. The revised GALL adds a requirement to perform a visual cable inspection at least once every 6 years regardless of the 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.
The requirement for visual inspection of the cable at least every 6 years should be changed to at least every 10 years to align with similar ALE inspections in other AMPs. Periodic inspection of manholes for water accumulation will provide further opportunities for identification of potential adverse effects on cable XI.E3C-8 XI.E3C-5, GALL, XI.E3C, Corrective Actions, Lines 14 -
Actions, Lines 14 - periodic man-hole inspection portion of this AMP is 15                  100%; there is nothing to expand.
15 The scope expansion method does not align with this one-time confirmatory test portion of this AMP. The periodic man-hole inspection portion of this AMP is 100%; there is nothing to expand.
Page 15 of 20
Recommend removing the 2nd paragraph in its entirety.


ATTACHMENT 4 Comment   Location of Description of Change                             Justification for Change
ATTACHMENT 4 Page 16 of 20 Comment Location of Change Description of Change Justification for Change XI.E4-1 XI.E4-4, Element 7, Corrective Actions, Lines 17 -
    #        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.
20 The standard phrase in the Corrective Action element does not align with the MEB AMP methods:
results, the operability of the component, the             Recommend:
The engineering evaluation considers the significance of the calibration, surveillance, inspection or test results, the operability of the component, the reportability of the event; the extent of the concern, the potential root causes for not meeting the acceptance criteria, the corrective actions required, and the likelihood of recurrence.
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.
Editorial Regulatory link when not necessarily the case, between aging degradation and operability or reportability.
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.
Recommend:
Page 16 of 20
The engineering evaluation considers the significance of the calibration, surveillance, inspection or test results, the 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.  


ATTACHMENT 4 Comment   Location of Description of Change                       Justification for Change
ATTACHMENT 4 Page 17 of 20 Comment Location of Change Description of Change Justification for Change XI.E5-1 XI.E5-1, Program Description, Lines 30 - 36 The comment on this section from the December draft was that the insulating material for fuse holders in stand-alone equipment that were subject to an ALE, but not frequently manipulated, may not be managed under E5. The insulating material for these fuse holders should be managed under E1. The request was to clarify this relationship between the AMPs.
    #        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:
Suggest the following changes to the wording in the February, 2017 draft to remove ambiguity with scope of electrical 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.
Fuse holders within the scope of SLR this 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
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]
[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.
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.  
Page 17 of 20


ATTACHMENT 4 Comment     Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 18 of 20 Comment Location of Change Description of Change Justification for Change XI.E5-2 XI.E5-2, Element 1, Scope of Program, Lines 4 -
    #        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.
10 The comment on this section from the December draft was that the insulating material for fuse holders in stand-alone equipment that were subject to an ALE, but not frequently manipulated, may not be managed under E5. The insulating material for these fuse holders should be managed under E1. The request was to clarify this relationship between the AMPs.
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.
Suggest the following changes to the revised wording in the February, 2017 draft to remove ambiguity with scope of electrical insulation visual inspections.
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.
This AMP manages in-scope fuse holders 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.
XI.E6-1 XI.E6, page XI.E6-2, Lines 3-4 The Program Description states A sample of cable connections within the scope of license renewal are tested on a one-time test basis or at least once every 10 years, or once every 5 years if only a visual inspection is used to The phrase or at least once every 10 years adds confusion to the sentence. The need for 10 year inspections due to findings of the initial one time inspection is clearly stated in the sentence that follows (Lines 5 - 6).
(Lines 5 - 6).
Editorial Revise the Program Description statement as follows: A sample of cable connections within the scope of license renewal are tested on a one-time test basis or at least once every 10 years, or periodically once every 5 years if only visual inspection is used to provide an indication of the integrity of the cable connections.
Page 18 of 20


ATTACHMENT 4 Comment     Location of Description of Change                             Justification for Change
ATTACHMENT 4 Page 19 of 20 Comment Location of Change Description of Change Justification for Change XI.E6-2 XI.E6-3, Element 5 Monitoring and Trending, Lines 31
    #        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:
- 37 Element 5 states Where practical, degradation is projected until the next scheduled inspection. Results are evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation.
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.
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:
Recommend to restore the original wording:
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.
Trending actions are not included as part of this AMP, because the ability to trend visual inspection and test results is dependent on the specific test or visual inspection program selected.
Page 19 of 20
XI.E6-3 XI.E6-3, Element 6 Acceptance Criteria, The standard phrase used in other electrical AMPs defining unacceptable indication is missing.
Editorial Recommend adding:
An unacceptable indication is defined as a noted condition or situation that, if left unmanaged, could potentially lead to a loss of intended function.  


ATTACHMENT 4 Comment   Location of Description of Change                           Justification for Change
ATTACHMENT 4 Page 20 of 20 Comment Location of Change Description of Change Justification for Change XI.E6-4 XI.E6-4, Element 7 Corrective Actions, Lines 8 - 17 Element 7 includes the new paragraph Additional inspections are conducted if one of the inspections does not meet the acceptance criteria due to current or projected degradation (i.e., trending). The number of increased inspections is determined in accordance with the sites corrective action process; however, there are no fewer than two additional inspections for each inspection that did not meet the acceptance criteria.
    #        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:
The additional inspections are completed within the interval (e.g., refueling outage interval, 10-year inspection interval) in which the original inspection was conducted. Additional samples are inspected for any recurring degradation to ensure corrective actions 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.
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.
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.
Recommend retaining the GALL Rev 2 wording:
Page 20 of 20}}
If acceptance criteria are not met, the corrective action program is used to perform an evaluation that considers the extent of the condition, the indications of aging effect, and changes to the one-time testing program or alternative inspection program. Corrective actions may include, but are not limited to, sample expansion, increased inspection frequency, and replacement or repair of the affected cable connection components.
XI.E7-1 XI.E7-1, Program Description, Line 13 The Program Description includes the phrase more rapidly than expected when installed in a harmful environment.
The environment should be stated in aging terms.
Editorial Reword as follows: more rapidly than expected when installed in an harmful environment conducive to aging.}}

Latest revision as of 10:35, 9 January 2025

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:
References
NUREG-2191, NUREG-2192
Download: ML17097A491 (20)
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Text

ATTACHMENT 4 Page 1 of 20 NUREG-2191 and NUREG-2192 (February 2017 Draft)

Electrical Comments Comment Location of Change Description of Change Justification for Change Table VI.A-1 GALL VI.A, Table line items for Metal Enclosed Bus and GALL XI.E4 The GALL XI.E4 AMP includes discussion of elastomers for metal enclosed bus, through program description and elements. The line item for elastomers in metal enclosed bus in the GALL table in VI.A has been deleted per the last entry of the table.

Editorial - content inconsistency Re-include line item VI.A.LP-29 in Table VI-A.

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

Editorial - content inconsistency Re-include line item VI.A.LP-08 in Table VI.A.

Table VI.A-3 GALL VI.A, Table line VI.A.LP-33 The AMP name provided in the table does not match the new GALL SLR AMP name in GALL section XI.E1.

Editorial - content inconsistency Change AMP title to Electrical Insulation Material for Electrical Table VI.A-4 GALL VI.A, Table line VI.A.LP-34 The AMP name provided in the table does not match the new GALL SLR AMP name in GALL section XI.E2.

Editorial - content inconsistency Change AMP title to Electrical Insulation Material for Electrical Table VI.A-5 GALL VI.A, Table line VI.A.LP-47 Should include AAC conductor as well Editorial - content inconsistency Add AAC.

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

Editorial - content error Change Transmission conductors connectors.

X.E1-1 X.E1-5, EQ Program Description, Lines17 - 18 The wording implies that all the passive EQ equipment will be inspected every 10 years to determine if they are in an ALE.

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.

Editorial - content clarification See Comment X.E1-2

ATTACHMENT 4 Page 2 of 20 Comment Location of Change Description of Change Justification for Change X.E1-2 X.E1-6, Element 4.

Detection of Aging Effects; Lines 37 -

40 Element 4 states Visual inspection of accessible, passive EQ equipment is performed at least once every 10 years. The purpose of the visual inspection is to identify adverse localized environments that may impact qualified life. Potential adverse localized environments are evaluated through the applicants corrective action program.

The wording implies that all the passive EQ equipment will be inspected every 10 years to determine if they are in an ALE.

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.

Recommend:

Visual inspection of accessible, passive EQ equipment in adverse localized environments is performed at least once every 10 years. The purpose of the visual inspection is to identify adverse localized environments conditions that may impact qualified life. Passive EQ equipment in potential adverse localized environments are is evaluated through the applicants corrective action program.

XI.E1-1 XI.E1-3, Element 4 Detection of Aging Effects, Lines 28-30 Testing was removed as a requirement for this program, and testing is now based on an engineering evaluation via the corrective action program. However, a sentence was left in Element 4, page XI.E1-3, Lines 28-30 which states A sample of accessible electrical cables and connections are tested for reduced electrical insulation resistance.

Editorial This sentence should be removed.

XI.E1-2 XI.E1-4, Element 4 Detection of Aging Effects, Line 1 Element 4, page XI.E1-4, line 1 states: this AMP, then testing is performed for evaluation.

Editorial Since testing is now based on an engineering evaluation via the corrective action program, change this sentence to read then testing is may be performed for evaluation, or testing, if deemed necessary, is performed for evaluation.

ATTACHMENT 4 Page 3 of 20 Comment Location of Change Description of Change Justification for Change XI.E2-1 XI.E2-1, Program Description, Line 18 The Program Description states An adverse localized environment is based on the most limiting environment

... ALEs are not based on limiting environments, they exceed the most limiting environments.

Editorial Reword the sentence as follows: An adverse localized environment is based on exceeds the most limiting environment...

XI.E3A-1 XI.E3A-1, Program Description, Lines 10 - 14)

The Program Description states that This AMP applies to all inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) medium voltage cables within the scope of subsequent license renewal (SLR) exposed to wetting or submergence (i.e., significant moisture).

The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.

Also, the phrase wetting or submergence does not match the description of significant moisture given in Lines 28 - 30.

Change the scope statement to read This AMP applies to all inaccessible or underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) medium voltage cables within the scope of subsequent license renewal (SLR) exposed to wetting or submergence (i.e., significant moisture).

The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.

Above ground cable is managed by the XI.E1 AMP.

The proposed change eliminates confusion between wetting or submergence and significant moisture.

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

ATTACHMENT 4 Page 4 of 20 Comment Location of Change Description of Change Justification for Change XI.E3A-2 XI.E3A-1, Program Description, Lines 22 - 24 The Program Description states Electrical insulation subjected to wetting or submergence could have an adverse effect on operability, or potentially lead to failure of the cable insulation system.

Editorial Regulatory link when not necessarily the case, between aging degradation and 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.

ATTACHMENT 4 Page 5 of 20 Comment Location of Change Description of Change Justification for Change XI.E3A-3 XI.E3A-2, Scope of Program, Lines 30

- 33 The scope of program states that This AMP applies to inaccessible or underground medium voltage (2kV to 35kV) power cable installations (e.g., direct buried, buried conduit, duct bank, embedded raceway, cable trench, vaults, or manholes) within the scope of subsequent license renewal exposed to significant moisture.

The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.

Change the scope statement to read This AMP applies to inaccessible or underground medium voltage (2kV to 35kV) power cable installations (e.g.,

direct buried, buried conduit, duct bank, underground embedded raceway, underground cable trench, vaults, or manholes) within the scope of subsequent license renewal exposed to significant moisture.

The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.

Above ground cable is managed by the XI.E1 AMP.

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

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

ATTACHMENT 4 Page 6 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-1 XI.E3B-1, Program Description, Lines 10 - 13 The Program Description states that This AMP applies to inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of subsequent license renewal (SLR) exposed to significant moisture.

The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.

Change the scope statement to read This AMP applies to inaccessible or underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of subsequent license renewal (SLR) exposed to significant moisture.

The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.

Above ground cable is managed by the XI.E1 AMP.

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

ATTACHMENT 4 Page 7 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-2 XI.E3B-1, Program Description, Lines 24 - 26 The Program Description states mitigated in service, could have an adverse effect on operability, may lead to multiple random failures of the cable insulation system, and compromise system defense-in-depth.

Editorial Regulatory link when not necessarily the case, between aging degradation and operability, multiple random failures or 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.

XI.E3B-3 XI.E3B-1, Program Description, Line 41 The Program Description states that If required, initial testing is performed once by utilizing sampling to determine the condition of the electrical insulation.

Sampling cannot determine the condition of the electrical insulation. It is used to establish the test population.

Editorial Change the sentence to read If required, initial testing is performed once by utilizing sampling on a sample population to determine the condition of the electrical insulation.

ATTACHMENT 4 Page 8 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-4 XI.E3B-2, Program Description, Lines 1-2 New text in this AMP states: Inaccessible instrumentation and control cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test.

This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and testing for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for submergence.

Requirements should be the same as cables that are not designed for submergence.

Delete the referenced text and revise the text on page XI.E3B-1, Lines 10 - 13 as follows: This AMP applies to inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable tranches, cable troughs, duct banks, 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..

ATTACHMENT 4 Page 9 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-5 XI.E3B-2, Element 1, Scope of Program, Lines 18

- 21 The scope of program states that This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of SLR, exposed to significant moisture.

The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.

Change the scope statement to read This AMP applies to inaccessible and underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables within the scope of SLR, exposed to significant moisture.

The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.

Above ground cable is managed by the XI.E1 AMP.

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

ATTACHMENT 4 Page 10 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-6 XI.E3B-2, Element 1 Scope of Program, Lines 35-38 New text in this AMP states: Cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test where additional tests and periodic visual inspections are determined by the test/inspection results and industry and plant-specific aging degradation OE with the applicable cable electrical insulation.

This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and test for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for submergence.

Requirements should be the same as cables that are not designed for submergence.

Delete the referenced text and revise the text on page XI.E3B-2, lines 18 - 21 as follows: This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) instrumentation and control cables (including those designed for continuous wetting or submergence) within the scope of SLR, exposed to significant moisture.

XI.E3B-7 XI.E3B-3, Element 4 Detection of Aging Effects, Lines 43-45 The industry proposed visual manhole inspections for accumulation of water. If water was found affecting cables, the cables would be evaluated to determine if testing is required. If no water was found affecting cables, no further action was required until the next manhole inspection for water accumulation. The revised GALL adds a requirement to perform a visual cable inspection at least once every 6 years regardless of the effects of water.

The requirement for visual inspection of the cable at least every 6 years should be changed to at least every 10 years to align with similar ALE inspections in other AMPs. Periodic inspection of manholes for water accumulation will provide further opportunities for identification of potential adverse effects on cable.

XI.E3B-8 XI.E3B, Element 5 Monitoring and Trending, Lines 39

- 41 The last sentence of Element 5 is not consistent with Element 5 in XI.E3C. XI.E3B and XI.E3C are similar programs that are implemented in similar manners. The last sentence of Element 5 should be the same for both AMPs.

Revise the last sentence of Element 5 as follows:

However, condition monitoring cable tests and inspection results that utilize the same visual or test methods that are trendable and repeatable provide additional information on the rate of cable insulation degradation.

ATTACHMENT 4 Page 11 of 20 Comment Location of Change Description of Change Justification for Change XI.E3B-9 XI.E3B-5, Element 7 Corrective Actions, Lines 21 -

22 The scope expansion method does not align with this one-time confirmatory test portion of this AMP. The periodic man-hole inspection portion of this AMP is 100%; there is nothing to expand.

Recommend removing the 2nd paragraph in its entirety.

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

The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.

Change the scope statement to read This AMP applies to all inaccessible and underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of subsequent license renewal (SLR) exposed to significant moisture.

The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.

Above ground cable is managed by the XI.E1 AMP.

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

ATTACHMENT 4 Page 12 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-2 XI.E3C-1, Program Description, Lines 23 - 26 :

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

Editorial Regulatory link when not necessarily the case, between aging degradation and operability, multiple random failures or 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.

XI.E3C-3 XI.E3C-1, Program Description, Line 40 The Program Description states that If required, initial testing is performed once by utilizing sampling to determine the condition of the electrical insulation.

Sampling cannot determine the condition of the electrical insulation. It is used to establish the test population.

Editorial Change the sentence to read If required, initial testing is performed once by utilizing sampling on a sample population to determine the condition of the electrical insulation.

ATTACHMENT 4 Page 13 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-4 XI.E3C-1, Program Description, Lines 42-44 New text in this AMP states: Inaccessible low-voltage power cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test.

This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and testing for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for submergence.

Requirements should be the same as cables that are not designed for submergence.

Delete the referenced text and revise the text on page XI.E3C-1, Lines 12 - 15 as follows: This AMP applies to inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable tranches, cable troughs, duct banks, 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..

ATTACHMENT 4 Page 14 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-5 XI.E3C-2, Element 1, Scope of Program, Lines 16

- 19 The scope of program states that This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of SLR exposed to significant moisture.

The AMP applies to underground cables routed either in raceway underground or directly buried. The AMP manages water accumulation and its effects on underground cable. Within this AMP cables are inspected at locations where they can be accessed such as manholes and vaults. Since manholes and vaults are confined spaces and require administrative controls for entry, they are considered inaccessible. Use of the term inaccessible is not needed to properly describe the cables under consideration. Also, the term underground in this AMP is consistent with the definition given in Table IX.D as used for mechanical components.

Change the scope statement to read This AMP applies to inaccessible and underground (e.g., installed in buried conduit, underground embedded raceway, underground cable trenches, underground cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables within the scope of SLR exposed to significant moisture.

The proposed changes clarify that this AMP applies to underground cable installations which aligns with the AMP goals of managing water accumulation and its effect on underground cable.

Above ground cable is managed by the XI.E1 AMP.

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

ATTACHMENT 4 Page 15 of 20 Comment Location of Change Description of Change Justification for Change XI.E3C-6 XI.E3C-2, Element 1 Scope of Program, Lines 28-32 New text in this AMP states: Cables designed for continuous wetting or submergence are also included in this AMP as a one-time inspection and test where additional tests and periodic visual inspections are determined by the test/inspection results and industry and plant-specific aging degradation OE with the applicable cable electrical insulation.

This is a new requirement for cables that are designed for submergence. The text, as written, requires both inspection and test for cable designed for submergence as opposed to inspection, and testing if deemed appropriate, for cable not designed for submergence.

Requirements should be the same as cables that are not designed for submergence.

Delete the referenced text and revise the text on page XI.E3C-2, lines 16 - 19 as follows: This AMP applies to inaccessible and underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage power cables (including those designed for continuous wetting or submergence) within the scope of SLR, exposed to significant moisture.

XI.E3C-7 XI.E3C-4, Element 4 Detection of Aging Effects, Lines 38 - 39 The industry proposed visual manhole inspections for accumulation of water. If water was found affecting cables, the cables would be evaluated to determine if testing is required. If no water was found affecting cables, no further action was required until the next manhole inspection for water accumulation. The revised GALL adds a requirement to perform a visual cable inspection at least once every 6 years regardless of the effects of water.

The requirement for visual inspection of the cable at least every 6 years should be changed to at least every 10 years to align with similar ALE inspections in other AMPs. Periodic inspection of manholes for water accumulation will provide further opportunities for identification of potential adverse effects on cable XI.E3C-8 XI.E3C-5, GALL, XI.E3C, Corrective Actions, Lines 14 -

15 The scope expansion method does not align with this one-time confirmatory test portion of this AMP. The periodic man-hole inspection portion of this AMP is 100%; there is nothing to expand.

Recommend removing the 2nd paragraph in its entirety.

ATTACHMENT 4 Page 16 of 20 Comment Location of Change Description of Change Justification for Change XI.E4-1 XI.E4-4, Element 7, Corrective Actions, Lines 17 -

20 The standard phrase in the Corrective Action element does not align with the MEB AMP methods:

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

Editorial Regulatory link when not necessarily the case, between aging degradation and operability or reportability.

Recommend:

The engineering evaluation considers the significance of the calibration, surveillance, inspection or test results, the 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.

ATTACHMENT 4 Page 17 of 20 Comment Location of Change Description of Change Justification for Change XI.E5-1 XI.E5-1, Program Description, Lines 30 - 36 The comment on this section from the December draft was that the insulating material for fuse holders in stand-alone equipment that were subject to an ALE, but not frequently manipulated, may not be managed under E5. The insulating material for these fuse holders should be managed under E1. The request was to clarify this relationship between the AMPs.

Suggest the following changes to the wording in the February, 2017 draft to remove ambiguity with scope of electrical insulation visual inspections:

Fuse holders within the scope of SLR this 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.

ATTACHMENT 4 Page 18 of 20 Comment Location of Change Description of Change Justification for Change XI.E5-2 XI.E5-2, Element 1, Scope of Program, Lines 4 -

10 The comment on this section from the December draft was that the insulating material for fuse holders in stand-alone equipment that were subject to an ALE, but not frequently manipulated, may not be managed under E5. The insulating material for these fuse holders should be managed under E1. The request was to clarify this relationship between the AMPs.

Suggest the following changes to the revised wording in the February, 2017 draft to remove ambiguity with scope of electrical insulation visual inspections.

This AMP manages in-scope fuse holders 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.

XI.E6-1 XI.E6, page XI.E6-2, Lines 3-4 The Program Description states A sample of cable connections within the scope of license renewal are tested on a one-time test basis or at least once every 10 years, or once every 5 years if only a visual inspection is used to The phrase or at least once every 10 years adds confusion to the sentence. The need for 10 year inspections due to findings of the initial one time inspection is clearly stated in the sentence that follows (Lines 5 - 6).

Editorial Revise the Program Description statement as follows: A sample of cable connections within the scope of license renewal are tested on a one-time test basis or at least once every 10 years, or periodically once every 5 years if only visual inspection is used to provide an indication of the integrity of the cable connections.

ATTACHMENT 4 Page 19 of 20 Comment Location of Change Description of Change Justification for Change XI.E6-2 XI.E6-3, Element 5 Monitoring and Trending, Lines 31

- 37 Element 5 states Where practical, degradation is projected until the next scheduled inspection. Results are evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation.

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

Recommend to restore the original wording:

Trending actions are not included as part of this AMP, because the ability to trend visual inspection and test results is dependent on the specific test or visual inspection program selected.

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

Editorial Recommend adding:

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

ATTACHMENT 4 Page 20 of 20 Comment Location of Change Description of Change Justification for Change XI.E6-4 XI.E6-4, Element 7 Corrective Actions, Lines 8 - 17 Element 7 includes the new paragraph Additional inspections are conducted if one of the inspections does not meet the acceptance criteria due to current or projected degradation (i.e., trending). The number of increased inspections is determined in accordance with the sites corrective action process; however, there are no fewer than two additional inspections for each inspection that did not meet the acceptance criteria.

The additional inspections are completed within the interval (e.g., refueling outage interval, 10-year inspection interval) in which the original inspection was conducted. Additional samples are inspected for any recurring degradation to ensure corrective actions 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.

Recommend retaining the GALL Rev 2 wording:

If acceptance criteria are not met, the corrective action program is used to perform an evaluation that considers the extent of the condition, the indications of aging effect, and changes to the one-time testing program or alternative inspection program. Corrective actions may include, but are not limited to, sample expansion, increased inspection frequency, and replacement or repair of the affected cable connection components.

XI.E7-1 XI.E7-1, Program Description, Line 13 The Program Description includes the phrase more rapidly than expected when installed in a harmful environment.

The environment should be stated in aging terms.

Editorial Reword as follows: more rapidly than expected when installed in an harmful environment conducive to aging.

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