ML053490231

2005/12/09-Oyster Creek Generating Station - Response to NRC Request for Additional Information Related to License Renewal Application. Areas Discussed Include Appendix R Fire Scenarios & FSAR Supplement

ML053490231
Person / Time
Site:	Oyster Creek
Issue date:	12/09/2005
From:	Swenson C AmerGen Energy Co, Exelon Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
%dam200604, 2130-05-20239, TAC MC7624
Download: ML053490231 (60)

Text

AmerGen SM C. N. (Bud) Swenson Telephone 609.971.2300 An Exelon Company Site Vice President www.exeloncorp.com bud swenson@amergenenergy.com Oyster Creek Generating Station US Route g South P.. Box388 10 CFR 50 Forked River, NJ 08731 10 CFR 51 10 CFR 54 2130-05-20239 December 9, 2005 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Oyster Creek Generating Station Facility Operating License No. DPR-1 6 NRC Docket No. 50-219

Subject:

Response to NRC Request for Additional Information, dated November 9, 2005, Related to Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

References:

(1) "Application for Renewed Operating License," Oyster Creek Generating Station, dated July 22, 2005 (2) "Request for Additional Information (RAI) for the Review of the Oyster Creek Generating Station, License Renewal Application (TAC NO. MC7624)," dated November 9, 2005 In Reference (2), the NRC requested additional information related to Section 2.1.5.2 and Section 2.1.5.15 of the Oyster Creek Generating Station License Renewal Application (LRA). In the RAI, the NRC expressed the need for additional information to evaluate certain aspects of the scoping and screening methodology used by AmerGen in the license renewal application process.The responses to questions related to LRA Section 2.1.5.2 (RAI 2.1.5.2-1 and RAI 2.1.5.2-2) are self-contained and presented as the first items within the Enclosure.

AmerGen's evaluation of RAI 2.5.1.15-1 resulted in the decision to include additional equipment within the scope of license renewal due to its support role in coping with certain Appendix R Fire scenarios.

This decision necessitated the performance of scoping, screening, aging management reviews and specification of aging management programs for some SSCs. The results of these evaluations are presented in the Enclosure.

For ease of correlation to the LRA, updated sections of the LRA showing areas affected by this response have been included within the Enclosure.

These items are listed on the Table of Contents at the front of the Enclosure.

A summary of commitments is presented in Appendix A of the Enclosure.

4IlS December 9, 2005 Page 2 of 2 If you have any questions, please contact Fred Polaski, Manager License Renewal, at 610-765-5935.

I declare under penalty of perjury that the foregoing is true and correct.Respectfully, Executed on ________ ____C. N.w Senson Site Vice Prosident Oyster Creek Generating Station AmerGen EnergyCompany, LLC

Enclosure:

Response to Request for Additional Information cc: Regional Administrator, USNRC Region I, w/o Enclosure USNRC Project Manager, NRR -License Renewal, Safety USNRC Project Manager, NRR -License Renewal, Environmental, w/o Enclosure USNRC Project Manager, NRR -Project Manager, Oyster Creek USNRC Senior Resident Inspector, Oyster Creek, w/o EncloSure Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection File No. 05040 Enclosure Response to Requests for Additional Information Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)RAI 2.1.5.2-1 RAI 2.1.5.2-2 RAI 2.5.1.15-1 Note: For the response to RAI 2.5.1.15-1, Section and Table numbers within the Appendices of this Enclosure match the numbering protocol used with the License Renewal Application for ease of comparison.

Enclosure, Page 2 of 10 Enclosure

-Table of Contents Response to Requests for Additional Information

• RAI 2.1.5.2-1 and Response* RAI 2.1.5.2-2 and Response* RAI 2.5.1.15-1 and Response Summary of License Renewal Application Additions and ChanQes for RAI 2.5.1.15-1

• Appendix A o Summary of Commitments for RAI 2.5.1.15-1

• Appendix B o New Section 2.4.20, Meteorological Tower Structures o New Table 2.4.20, Meteorological Tower Structures

-Components Subject to Aging Management Review o Revised Section 2.5.1.15, Radio Communications System o Revised Table 2.5.1.15, Radio Communications System -Components Subject to Aging Management Review* Appendix C o New Summary Section 3.5.2.1.20, Meteorological Tower Structures o New Summary Section 3.6.2.1.10, Radio Communications System o New Oyster Creek LRA Table 1, Table 3.6.1D Summary of Aging Management Evaluations o New Oyster Creek LRA Table 2, Table 3.5.2.1.20, Meteorological Tower Structures o New Oyster Creek LRA Table 2, Table 3.6.2.1.3, Radio Communications System Enclosure, Page 3 of 10* Appendix D o Replacement and new text for Oyster Creek LRA Appendix A, Final Safety Analysis Report Supplement:

• A.1 .26B Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply* A.1.31 Structures Monitoring Program o Replacement and new text for Oyster Creek LRA Appendix A, Table A.5, License Renewal Commitment List, line items o Replacement and new text for Oyster Creek LRA Appendix B, Aging Management Programs* B.1.26B Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply* B.1.31 Structures Monitoring Program Enclosure, Page 4 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI 2.1.5.2-1 Grouted Penetrations Section 4.5.1 of Oyster Creek Position Paper PP-03, "Criteria for Scoping Systems and Structures Relied Upon to Demonstrate Compliance With 10 CFR 54.4(a)(2)," Revision 3, provides instructions for establishing system boundaries for nonsafety-related (NSR)piping systems connected directly to safety-related (SR) piping systems. One of the acceptable methods in PP-03 for establishing license renewal (LR) piping system boundaries is to extend the piping system boundary up to a wall or slab past the SR/NSR interface and credit the grouted wall or slab piping penetration as an anchor that is equivalent to a seismic anchor. The applicant stated that thirteen grouted wall or slab piping penetrations were credited as equivalent anchors. Two of the thirteen grouted wall or slab piping penetrations were included in Stress Calculation C-I 302-251-5320-004 Revision 4. The remaining 11 grouted wall or slab piping penetrations were not included in Stress Calculation C- 302-251-5320-004 Revision 4, nor were supported by any other technical analysis that demonstrated that grouted wall or slab piping penetrations are equivalent to a seismic anchor. Based on the staff's review of the applicant's scoping evaluation related to the 10 CFR 54.4a(2) criterion, the staff requires additional information to complete its review. Specifically, the staff requests the applicant provide the technical basis for establishing that the 11 grouted wall or slab piping penetrations are equivalent to seismic anchors.RAI 2.1.5.2-1 Response: The Oyster Creek pipe stress analysis Specification (SP 1302-12-294) defines an anchor as a structural anchor or three mutually perpendicular restraints (equivalent anchor). The Specification further states that the restraints imposed on a pipe run at wall and floor penetrations shall be modeled in the analysis.

Grouted penetrations with pipe shear lugs are modeled as anchors. Grouted penetrations without pipe shear lugs are modeled as anchors with the axial and torsional degrees of freedom released.

The Specification therefore allows generic use of grouted penetrations as equivalent anchors. For piping that requires a detailed stress analysis the penetration is modeled in the stress analysis as an anchor or a guide depending on penetration seal type and presence of shear lugs. For non-safety related piping systems there are no requirements under the current licensing basis to perform a detailed stress analysis.

As a result, an analysis that would explicitly define how a penetration through a wall or slab is treated may not exist. However, the design practice at Oyster Creek is to credit penetrations as anchors, consistent with the requirement of the Specification and industry practice for pipe support design.During the scoping and screening methodology audit, NRC Staff requested a count of grouted penetrations credited as equivalent anchors. In response to the request, AmerGen stated that 13 penetrations were credited as anchors, two of which are covered by engineering analysis.

The remaining 11 penetrations are not specifically covered by a specific analysis but enveloped by the generic criteria provided in the engineering Specification for performing pipe stress analysis.

Enclosure, Page 5 of 10 After the audit, additional reviews of plant design documentation were performed to ascertain that the 11 penetrations are required equivalent anchors. The additional reviews identified 7 of the 11 penetrations are also covered by specific analysis.

Two penetrations are associated with non-safety related Fire Protection system piping included in the stress analysis of the safety related Core Spray system piping (see drawing LR-JC-1 9479 sheet 3, location B5 and G5). These two penetrations are included in the stress model to provide structural support in 2 orthogonal directions to the Fire Protection system piping and Core Spray piping. The support in the third orthogonal direction (axial) is provided by other supports in the piping run thus forming an equivalent anchor as defined in the engineering Specification.

The other 5 penetrations are covered by engineering analysis for Instrument Control Air system (see drawing LR-BR-2013 sheet 5 location F8, and LR-BR-2013 sheet 6 location D3, D7, and D8). These reactor building penetrations (designated with cross section double arrow on the above drawings) are credited for support in 2 orthogonal directions for the 4 inch, 3 inch, 2.5 inch and 2 inch diameter air supply headers connected to safety related tubing.The third orthogonal direction support is provided by supports connected to the reactor building structure or the exhaust tunnel concrete.Thus there are only 4 penetrations that do not have explicit design analysis to demonstrate that they are considered equivalent anchors in the CLB but are credited as equivalent anchors for license renewal. Two of the penetrations (1.5 inch and 3 inch diameter) are associated with Sumps and Waste Collection System pipes that penetrate primary containment (see LR-JC-147434 sheet 2 location C6, and drawing LR-JC-147434 sheet 3 location 07). The pipes are classified non-safety related after the primary containment isolation valves but the piping is assumed to provide structural support to the isolation valves up to and including reactor building penetrations.

The reactor building penetrations are credited for support in 2 orthogonal directions consistent with the Specification requirements and penetrations discussed above, which have explicit analysis.

The third orthogonal support is provided by the primary containment penetrations, which completes CLB requirements for an equivalent anchor.The remaining 2 penetrations, I associated with a 4-inch diameter Demineralized Water Transfer system pipe (see drawing LR-BR-2004 sheet 1 location E7), and 1 associated with a 6-inch diameter Condensate Transfer System pipe (see drawing LR-BR-2004 sheet 2 location F7) do not have explicit analysis but are credited as equivalent anchors.The 2 pipes are routed through grouted penetrations in the exterior south wall of the reactor building.

Because documentation required for establishing the presence of shear lugs could not be found, the penetrations are conservatively assumed not capable of supporting axial load consistent with stress analysis Specification requirements and penetrations discussed above. The penetrations are only credited for vertical and lateral loads and the axial load is resisted by supports in the pipe run; thus forming an equivalent anchor as defined in CLB.Conclusion:

The Oyster Creek pipe stress analysis Specification defines a seismic structural anchor as an anchor or three mutually perpendicular restraints (equivalent anchor). The Specification specifies that grouted pipes without shear lugs should be modeled as anchors with axial and torsonial degree of freedom released.

Thirteen penetrations are credited for providing structural support in 2 orthogonal directions consistent with the Specification requirements.

The third orthogonal direction is supported by other supports connected to the building structure; thus forming an equivalent anchor consistent with the CLB definition.

Explicit analysis that indicates the Enclosure, Page 6 of 10 penetrations are credited as equivalent anchors has been found for 9 of the 13 penetrations.

The 4 penetrations without explicit analysis are credited to provide structural support in 2 orthogonal directions.

The technical basis is that Oyster Creek Specification permits the use of grouted penetrations as equivalent anchors consistent with industry practices for pipe support design. The additional technical basis for these 4 penetrations is the fact that the 4 penetrations are bounded in size and construction details by the penetrations that have explicit analysis.

The support in the third direction is provided by supports in the pipe run, and the pipe run is included in scope for license renewal and subject to AMR.

Enclosure, Page 7 of 10 RAI 2.1.5.2-2 Underground Piping Section 2.1.5.2 of the Oyster Creek License Renewal Application (LRA) describes the applicant's screening and scoping methodology for NSR systems and structures affecting SR systems or structures.

This section of the LRA states that piping that exits a structure and is routed underground is credited as an anchor that is equivalent to a seismic anchor. This same method is described in Section 4.5.1.3 of PP-03. During the audit, the applicant clarified that although this method is described in the LRA and PP-03, it was not used at Oyster Creek. Based on the staff's review of the applicant's scoping evaluation related to the 10 CFR 54.4 a (2) criterion, the staff requires additional information to complete its review. Specifically, the staff requests the applicant verify that underground piping was not credited as an anchor that is equivalent to a seismic anchor.RAI 2.1.5.2-2 Response: The underground piping method described in the LRA (Section 2.1.5.2, item 4, "A point where the non-safety related line exits a structure and is routed underground")

and PP-03 was not used or credited as an anchor. Oyster Creek scoping and screening methodology does not rely on non-safety related piping run underground to provide structural support to safety related piping. The boundary for non-safety related piping that provides structural support to safety related piping terminates at the outside face of the exterior wall of the building.

The grouted penetration, not the ground, is credited as an equivalent anchor as defined in the CLB.

Enclosure, Page 8 of 10 RAI 2.5.1.15-1 Support Systems Section 4 of the Oyster Creek Position Paper PP-07, "Systems and Structures Relied upon to Demonstrate Compliance with 10 CFR 54.48 -Fire Protection," Revision 3, states that first-level, primary support systems that are necessary for the functioning of equipment credited in the Fire Hazard Analysis Report or Safe Shutdown Analysis to demonstrate compliance with 10 CFR 54.48 (Fire Protection) are included in scope of LR. Table 1 of PP-07 lists the standby gas engine generator as in scope of LR.However, Section 2.5.1.15, "Radio Communication System," of the Oyster Creek LRA does not list the standby gas engine generator as in scope. The applicant stated during the audit that Section 2.5.1.15 of the LRA is correct and that the standby gas engine generator was removed from the scope of LR because it is not the radio communication system's primary power source.Section 2.1.3.1.3, "Regulated Events," of NUREG-1800, "Standard Review Plan," states that an applicant need not consider hypothetical failures or second, third or fourth-level support systems in determining the systems, structures, and components (SSCs) within the scope of the rule under 10 CFR 54.4(a)(3).

Section 2.1.3.1.3 also states that all SSCs that are relied upon in the plant's current licensing basis (CLB), plant-specific experience, industry-wide experience (as appropriate), and safety analyses or plant evaluations to perform a function that demonstrates compliance with NRC regulations identified under 10 CFR 54.4(a)(3), are required to be included within the scope of LR.Based on the staff's review of the applicant's scoping evaluation related to the 10 CFR 54.4a(3) criterion, the staff requires additional information to complete its review.Specifically, the staff requests the applicant:

A. Verify that the Oyster Creek CLB, plant-specific experience, industry-wide experience (as appropriate), and safety analyses or plant evaluations do not require the standby gas engine generator to perform a function that demonstrates compliance with NRC regulations identified under 10 CFR 54.4(a)(3), and B. Verify that second, third or fourth-level support systems were included in scope of LR if the Oyster Creek CLB, plant-specific experience, industry-wide experience (as appropriate), and safety analyses or plant evaluations require the second, third or fourth-level support system to perform a function that demonstrates compliance with NRC regulations identified under 10 CFR 54.4(a)(3).

Enclosure, Page 9 of 10 RAI 2.5.1.15-1 Response A. Standby Gas Engine Generator One of the reference documents used for scoping the Radio Communications system, Specification SP-1302-06-013, indicated that the repeater located at the Meteorological (Met) Tower was considered redundant to the primary Oyster Creek plant repeater located in the upper cable spreading room. On that basis, the repeater located at the Met Tower and the associated supporting structures and power supplies were not included in scope for license renewal. After receiving this RAI, AmerGen further reviewed the Radio Communications system CLB, with respect to the scope of equipment needed for compliance with 10CFR50.48.

AmerGen determined that during normal plant operation the Met Tower repeater is redundant.

However, during certain Appendix R fire scenarios, Specification SP-1302-06-013 indicates that the repeater located at the Met Tower is credited for communications capabilities.

Therefore, the Met Tower repeater and associated support equipment, including the backup gas (propane)engine generator, should have been included in the scope of license renewal. Enclosed with this response are the scoping and screening results, aging management review results and aging management programs associated with the Radio Communications system repeater located at the Met Tower.The mechanical components subject to aging management review are included with the Radio Communications system scoping. The structural components are included with the Meteorological Tower Structures.

The Structures Monitoring Program (B.1.31) is credited for aging management of the structural components and the external surfaces of the mechanical components.

A new aging management program, Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply (B.1.26B) is credited for aging management of the buried propane tank and associated buried fuel supply piping, both of which are owned by First Energy. The aging management program activities will be coordinated, as necessary, with First Energy pursuant to an Easement, License, and Restrictive Covenant Agreement.

The Radio Communications system Met Tower repeater electrical configuration and electrical commodity groups were reviewed with respect to intended functions and susceptibility to aging effects on long-lived passive components.

It was determined that the long-lived passive electrical commodities supporting the Met Tower repeater did not require aging reviews nor aging management programs.

This conclusion was based on the Met Tower electrical configuration, which does not include:* Electrical commodities (e.g., electrical penetrations, phase bus, switchyard bus, transmission conductors and connections),* Electrical commodities in suspect aging environments (e.g., insulated cables and connection in adverse localized environments), or* Electrical commodities independent of active components/assemblies (e.g., fuse holders, terminal blocks).B. Support Systems The Oyster Creek license renewal methodology ensures that systems, structures and components relied on in safety analyses or plant evaluations to perform functions that demonstrate compliance with the requirements of the fire protection, environmental Enclosure, Page 10 of 10 qualification, anticipated transients without scram (ATWS), and station blackout (SBO)regulations are included in the scope of license renewal. The methodology includes review of the Oyster Creek current licensing bases, including docketed correspondence addressing compliance with these regulations.

Systems, structures and components (SSC) that are relied upon in the Oyster Creek current licensing bases, safety analyses or plant evaluations to perform a function that demonstrates compliance with NRC regulations identified under 10 CFR 54.4(a)(3), have been included in scope. Plant evaluations for the regulated events include consideration of plant-specific experience and industry-wide experience as appropriate.

Operating experience, both internal and external, is used at Oyster Creek to enhance plant programs, prevent repeat events, and prevent events that have occurred at other plants from occurring at Oyster Creek. The Oyster Creek Operating Experience process screens, evaluates, and acts on operating experience documents and information to prevent or mitigate the consequences of similar events.The identified scope for 10 CFR 54.4(a)(3) includes all SSC specifically relied upon to demonstrate compliance with the applicable NRC regulations, including support systems. Such SSCs include, but are not limited to, auxiliary cooling water systems or other support systems that are required for operability of the credited SSC, supports for the credited equipment, and any applicable power supplies specifically required for proper operation of the credited equipment.

Section 2.1.3.1.3, "Regulated Events," of NUREG-1800, "Standard Review Plan," states that an applicant need not consider hypothetical failures or second, third or fourth-level support systems in determining the systems, structures, and components (SSCs) within the scope of the rule under 10 CFR 54.4(a)(3).

When considering these support systems, hypothetical failures that could result from system interdependencies that are not part of the current licensing bases and that have not been previously experienced, need not be considered.

Therefore, second, third or fourth-level support systems were included in the scope of license renewal if the Oyster Creek CLB, plant-specific experience, industry-wide experience (as appropriate), and safety analyses or plant evaluations required the second, third or fourth-level support system to perform a function that demonstrates compliance with NRC regulations identified under 10 CFR 54.4(a)(3).

No support systems were excluded from scope if they were specifically relied upon for compliance with the applicable NRC regulation.

Appendix A, Page 1 of 3 Enclosure Appendix A Summary of Commitments The following table identifies and describes commitments made in this response.

One commitment from the original LRA, commitment 31, has been updated to reflect the changes associated with this submittal.

The updated aspects of commitment 31 are formatted in bold font for ease of identification.

The additional commitment being made in this submittal is a new item associated with the new mechanical aging management program for the Meteorological Tower based radio communications system repeater backup gas engine generator supply fuel. The new commitment is numbered to sequentially follow the commitments previously made for Oyster Creek license renewal.Any other actions discussed in this submittal represent Intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.

Commitment Committed One-Time Programmatic Date or Outage Action (Yes/No) (Yes/No)31) Structures Monitoring Program Prior to period of No Yes Existing program is credited.

The program includes elements of the Masonry Wall extended Program and the RG 1.127, Inspection of Water-Control Structures Associated With operation Nuclear Power Plants aging management program. The Structures Monitoring Program will be enhanced to include: 1. Buildings, structural components and commodities that are not In scope of maintenance rule but have been determined to be in the scope of license renewal. These include miscellaneous platforms, flood and secondary containment doors, penetration seals, sump liners, structural seals, and anchors and embedment 2. Component supports, other than those in scope of ASME Xl, Subsection IWF.3. Inspection of Oyster Creek external surfaces of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bolting. Inspection and acceptance criteria of the external surfaces will be the same as those specified for structural steel components and structural bolting.4. The visual inspection of Insulated surfaces will require the removal of insulation.

Removal of insulation will be on a sampling basis that bounds insulation material type, susceptibility of insulated piping or component material to potential degradations that could result from being in contact with insulation, Appendix A, Page 2 of 3 Commitment Committed One-Time Programmatic Date or Outage Action (Yes/No) (Yes/No)and system operating temperature.

5. Inspection of electrical panels and racks, junction boxes, instrument racks and panels, cable trays, offsite power structural components and their foundations, and anchorage.

6. Periodic sampling, testing, and analysis of ground water to confirm that the environment remains non-aggressive for buried reinforced concrete.7. Periodic inspection of components submerged in salt water (Intake Structure and Canal, Dilution structure) and in the water of the fire pond dam, including trash racks at the Intake Structure and Canal.8. Inspection of penetration seals, structural seals, and other elastomers for change in material properties.

9. Inspection of vibration isolators, associated with component supports other than those covered by ASME Xl, Subsection IWF, for reduction or loss of isolation function.10. The current inspection criteria will be revised to add loss of material, due to corrosion for steel components, and change in material properties, due to leaching of calcium hydroxide and aggressive chemical attack for reinforced concrete.

Wooden piles and sheeting will be Inspected for loss of material and change in material properties.

11. Periodic inspection of the Fire Pond Dam for loss of material and loss of form.12. Inspection of Station Blackout System structures, structural components, and phase bus enclosure assemblies.

13. Inspection of Forked River Combustion Turbine power plant external surfaces of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bolting. Inspection and acceptance criteria of the external surfaces will be the same as those specified for structural steel components and structural bolting.14. The program will be enhanced to include inspection of Meteorological Tower structures.

Inspection and acceptance criteria will be the same as those specified for other structures in the scope of the program.15. The program will be enhanced to Include Inspection of exterior surfaces of piping and piping components associated with the Radio Communications system, located at the meteorological tower site, for loss of material due to corrosion.

Inspection and acceptance criteria will be the same as those specified for other external surfaces of mechanical components.

Appendix A, Page 3 of 3 Commitment Committed One-Time Programmatic Date or Outage Action (Yes/No) (Yes/No)61) Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply Prior to period of No Yes extended The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply operation aging management program Is a new program that manages the external surface aging effects of loss of material for copper and carbon steel piping, and carbon steel tanks in a soil (external) environment.

The program activities consist of preventive and condition-monitoring measures to manage the loss of material due to external corrosion for piping and tanks in the scope of license renewal that are in a soil (external) environment.

The program scope includes buried portions of the Met Tower based radio communications system repeater backup engine generator fuel (propane) supply piping and the associated buried fuel supply tank, located at the Meteorological Tower.External inspections of buried components will occur opportunistically when they are excavated during maintenance.

Within 10 years prior to entering the period of extended operation, inspection of buried piping will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of buried piping will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period.This program will be Implemented prior to entering the period of extended operation.

Enclosure Appendix B New Section 2.4.20, Meteorological Tower Structures New Table 2.4.20, Meteorological Tower Structures

-Components Subject to Aging Management Review Revised Section 2.5.1.15, Radio Communications System Revised Table 2.5.1.15, Radio Communications System -Components Subject to Aging Management Review Appendix B. Page 2 of 7 2.4.20 Meteorological Tower Structures System Purpose The Meteorological Tower Structures are comprised of the meteorological tower, the communications building, and the foundation for the gas engine unit. The Meteorological Tower Structures are located north northwest of the Reactor Building outside the protected area. The communications building consists of prefabricated precast concrete panels supported on concrete footings.

The meteorological tower is a carbon steel tube structure with guy wires anchored to concrete footings.

The foundation for the gas engine is a reinforced concrete slab located adjacent to the communications building.

The Meteorological Tower Structures are classified nonsafety related, non-seismic.

The purpose of the Meteorological Tower Structures is to provide structural support, shelter, and protection for communications components, located at the meteorological tower site, that perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), and for components which support the intended function of the system. The communications building provides structural support, shelter, and protection for the repeater, batteries, conduits, cables, and other components associated with the repeater.The meteorological tower provides structural support for the antenna and the signal cable to the repeater.

The foundation for the engine provides structural support to the engine.Included in the evaluation boundary of the Meteorological Tower Structures are structural elements of the communications building which include precast concrete panels, structural steel, roofing, concrete slab and footings.

Also included in the evaluation boundary are structural elements of the meteorological tower (supports antenna and cable) , including structural steel, guy wires, footings, concrete anchors, and miscellaneous steel. Other components in the evaluation boundary include a foundation for the engine, cable trays, conduits, engine supports, vibration isolators, panels and enclosures, racks for the repeater and batteries, seals, structural bolts, and supports for these components and cables. These structures and components are in scope of license renewal because they provide structural support, shelter, and protection for components that perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48).The additional buildings and components that share the site with the Meteorological Tower Structures are not included in the scope of license renewal. The buildings and structures have been determined not to perform an intended function under 10 CFR 54.4 a (1), a (2), a(3), or support a function of systems and structures credited for 10 CFR 50.48.Reason for Scone Determination The Meteorological Tower Structures meet 10 CFR 54.4(a)(3) because they are relied upon in the safety analyses and plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48).The structures do not meet 10 CFR 54.4(a)(1) because they are not safety related or relied on to remain functional during and following design basis events. The structures do not meet 10 CFR 54.4(a)(2) because failure of non-safety related portions of the structures would not prevent satisfactory accomplishment of function(s) identified for 10 CFR 54.4(a)(1).

The Appendix B. Page 3 of 7 structures are not relied upon in any safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulation for Environmental Qualification (10 CFR 50.49), ATWS (10 CFR 50.62) or Station Blackout (10 CFR 50.63).System Intended Functions 1. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). 10 CFR 54.4(a)(3).UFSAR References 2.3.3.1.1, 9.5.2.g License Renewal Boundary Drawings N/A Appendix B, Page 4 of 7 Table 2.4.20 Meteorological Tower Structures Components Subject to Aging Management Review Component Type Intended Functions Cable Tray Structural Support Concrete anchor Structural Support Conduits Enclosure Protection Structural Support Door Enclosure Protection Engine supports (support member) Structural Support Engine Vibration isolators Vibration Isolation Foundation concrete at locations of Structural Support expansion and grouted anchors Guy wires Structural Support Miscellaneous steel (tumbuckles, pins, Structural Support plate, shackles)Panels and enclosures Enclosure Protection

____ ____ ____ ___ ____ ____ ___ Structural Support Precast concrete panel walls, slabs Enclosure Protection Structural Support Racks for repeater, batteries Structural Support Reinforced concrete foundations (above Structural Support nd below grade)Roofing Enclosure Protection Seals Enclosure Protection Structural Bolts Structural Support Structural steel Structural Support Structural steel (Tower) Structural Support Supports for conduits and cable Structural Support The aging management review results for these components are provided in Table 3.5.2.1.20 Meteorological Tower Structures-Summary of Aging Management Evaluation Appendix B, Page 5 of 7 2.5.1.15 Radio Communications System System Purpose The Radio Communications System is an electrical system designed to provide two-way voice communication between operations personnel operating safe shutdown equipment during a fire emergency and Station Blackout.

The Radio Communications System accomplishes this by providing the operators with two-way portable radio units supported by repeaters and antennas.The Radio Communication System is comprised of primary, independent emergency and backup base station transmitter-repeaters, portable radio units with batteries and chargers stored in the Oyster Creek Generating Station control room, and antennas with associated cabling. The radio repeaters are electronic devices. The primary repeater system is located in the Upper Cable Spreading Room. The independent emergency and backup systems are located at the Meteorological Tower and at the Oyster Creek Administration Building (OCAB), respectively.

The OCAB repeater is a backup repeater and is not credited for Station Blackout or Appendix R safe shutdown, and therefore is not required to support a license renewal intended function.

The Meteorological Tower based repeater system is required to support safe shutdown upon loss of the primary system. The individual portable radios also have a direct mode (talk-around) feature that provides direct communication between radios without utilizing repeaters.

Electrical power for the primary base station transmitter and repeater is supplied from the 120VAC Vital Power System. The independent emergency base station /repeater located at the Meteorological Tower communications building is normally powered from offsite power, and is also provided with a battery backup power supply located in the communications building.

To ensure operability for Appendix R, an automatic standby propane gas engine generator located outside the Meteorological Tower communications building is available through a transfer switch as a backup AC power supply.Reason for Scope Determination The Radio Communications System meets 10 CFR 54.4(a)(3) because it is relied upon in the safety analyses and plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for Fire Protection (10 CFR 50.48) and Station Blackout (10 CFR 50.63).The system does not meet 10 CFR 54.4(a)(1) because it is not safety related or relied on to remain functional during and following design basis events. The system does not meet 10 CFR 54.4(a)(2) because failure of non-safety related portions of the system would not prevent satisfactory accomplishment of function(s) identified for 10 CFR 54.4(a)(1).

The system is not relied upon in any safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulation for Environmental Qualification (10 CFR 50.49) or ATWS (10 CFR 50.62).System Intended Functions 1. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commissions regulations for Fire Protection (10 CFR 50.48) (10 CFR 54.4(a)(3)).

Appendix B, Page 6 of 7 2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commissions regulations for Station Blackout (10 CFR 50.63) (10 CFR 54.4(a)(3))-

UFSAR References None License Renewal Boundary Drawings None Appendix B, Page 7 of 7 Table 2.5.1.15 Radio Communications System Components Subject to Aging Management Review Conmponent Ty e Intended Functions Piping and fittings Pressure Boundary Tanks lPressure Boundary Valve Body Pressure Boundary The aging management review results for these components are provided in Table 3.6.2.1.3 Radio Communications System-Summary of Aging Management Evaluation Enclosure Appendix C New Summary Section 3.5.2.1.20, Meteorological Tower Structures New Summary Section 3.6.2.1.10, Radio Communications System New Oyster Creek LRA Table 1, Table 3.6.1 D Summary of Aging Management Evaluations New Oyster Creek LRA Table 2, Table 3.5.2.1.20, Meteorological Tower Structures New Oyster Creek LRA Table 2, Table 3.6.2.1.3, Radio Communications System Appendix C, Page 2 of 20 3.5.2.1.20 Meteoroloaical Tower Structures Materials The materials of construction for the Meteorological Tower Structures are:* Aluminum* Carbon and low alloy steel* Concrete* Elastomer* Galvanized Steel* Polyvinyl Chloride (PVC)* Stainless Steel Environments The Meteorological Tower Structures are exposed to the following environments:

• Concrete* Indoor Air* Outdoor Air* Soil Aging Effects Requiring Management The following aging effects associated with the Meteorological Tower Structures require management:

• Change in Material Properties

• Cracking* Loss of Material* Loss of Preload* Reduction or Loss of Isolation Function* Reduction in concrete capacity due to local concrete degradation Aging Management Programs The following aging management programs manage the aging effects for the Meteorological Tower Structures:

• Structures Monitoring Program (B.1.31)Table 3.5.2.1.20, Summary of Aging Management Evaluation

-Meteorological Tower Structures summarizes the results of the aging management review for the Meteorological Tower Structures.

Appendix C, Page 3 of 20 3.6.2.1.10 Radio Communications System Materials The materials of construction for the Radio Communications System components are:* Brass* Carbon and low allow steel* Copper Environments The Radio Communications System components are exposed to the following environments:

• Outdoor Air* Propane* Soil Aging Effects Requiring Management The following aging effects associated with the Radio Communications System components require management:

• Loss of Material Aging Management Programs The following aging management programs manage the aging effects for the Radio Communications System components:

• Buried Piping and Tanks Inspection

-Met Tower Repeater Engine Fuel Supply* Structures Monitoring Program Table 3.6.2.1.3, Summary of Aging Management Evaluation

-Radio Communications System summarizes the results of the aging management review for the Radio Communications System.

Appendix C, Page 4 of 20 Table 3.6.1 D .Summary of Aging Management Evaluations Item Component Aging Aging Management Further Evaluation Discussion/Further Evaluation Number Effect/Mechanism Programs Recommended 3.3.1-58 Steel external Loss of material due to External Surfaces No surfaces exposed to general corrosion Monitoring The Structures Monitoring Program, air- indoor B.1.31, will be used to manage the uncontrolled loss of material on the external (external), air- surfaces of carbon steel piping, piping outdoor (external), components, and piping elements and condensation exposed to an outdoor air (external)(external) environment.

3.3.1-61 Elastomer fire barrier Increased hardness, Fire Protection No penetration seals shrinkage and loss of The Structures Monitoring Program, exposed to air -strength due to B.1.31, will be used to manage the outdoor or air -indoor weathering change in material properties of uncontrolled elastomer seals, roofing, and conduits exposed to an outdoor air environment.

3.3.1-92 Galvanized steel None None NA -No AEM or AMP piping, piping Consistent with NUREG-1801.

components, and piping elements exposed to air -indoor uncontrolled 3.3.1-96 Steel and stainless None None NA -No AEM or AMP steel piping, piping Consistent with NUREG-1801.

components, and piping elements in concrete Appendix C, Page 5 of 20 Table 3.6.1 D -Summary of Aging Management Evaluations Item Component Aging Aging Management Further Evaluation Discussion/Further Evaluation Number Effect/Mechanism Programs Recommended 3.3.1-97 Steel, stainless steel, None None NA -No AEM or AMP aluminum, and Consistent with NUREG-1801.

copper alloy piping, piping components, and piping elements exposed to gas 3.4.1-11 Buried steel piping, Loss of material due to Buried Piping and Tanks No piping components, general, pitting, crevice, Surveillance NUREG 1800, subsection 3.4.2.2.5.1 piping elements, and and microbiologically-states: Loss of material due to tanks (with or without influenced corrosion or general, pitting and crevice corrosion, coating or wrapping) and MIC could occur in steel (with or exposed to soil Buried Piping and Tanks Yes, detection of aging without coating or wrapping) piping, Inspection effects and operating piping components, piping elements experience are to be and tanks exposed to soil. The buried further evaluated (See piping and tanks inspection program subsection 3.4.2.2.5.1) relies on industry practice, frequency of pipe excavation, and operating experience to manage the effects of loss of material from general corrosion, pitting and crevice corrosion, and MIC.The effectiveness of the buried piping and tanks inspection program should be verified to evaluate an applicant's inspection frequency and operating experience with buried components, ensuring that loss of material is not occurring.

Further Evaluation:

Consistent with NUREG-1801 with exceptions.

The new Buried Piping and Tanks Inspection

-Met Tower Repeater Engine Fuel Supply, B.1.26B, aging management program will be used to manage the loss of material in copper and carbon steel piping and carbon Appendix C, Page 6 of 20 Table 3.6.1D -Summary of Aging Management Evaluations Item Component Aging Aging Management Further Evaluation Discussion/Further Evaluation Number Effect/Mechanism Programs Recommended steel tanks in the repeater engine fuel supply system exposed to a soil environment.

The Buried Piping and Tanks Inspection

-Met Tower Repeater Engine Fuel Supply aging management program includes the periodic inspection of external surfaces for loss of material to manage the effects of corrosion on the pressure-retaining capacity of piping and tanks exposed to a soil (external) environment.

The external inspections of the buried piping and tank will occur opportunistically when excavated during maintenance or excavated and inspected for any other reason. Within 10 years prior to entering the period of extended operation, inspection of the buried piping and tank will be performed unless an opportunistic inspection occurs within this ten-year period. Following commencement of the period of extended operation, inspection of the buried piping and tank will again be performed within the next ten years, unless an opportunistic Inspection occurs during this ten-year period. Based on meteorological tower repeater engine fuel supply operating experience, there have been no leaks in the underground portion of the propane piping and tank. Therefore the frequency of inspection, at least once in the 10 years prior to the period of extended operation and at least once in the first 10 years of extended operation, is adequate.

The program also includes preventive measures in Appendix C, Page 7 of 20 Table 3.6.1D -Summary of Aging Management Evaluations Item Component Aging Aging Management Further Evaluation Discussion/Further Evaluation Number Effect/Mechanism Programs Recommended accordance with standard industry practices for the inspection and maintenance of external coatings and wrappings.

Exceptions apply to the NUREG-1 801 recommendations for Buried Piping and Tanks Inspection

-Met Tower Repeater Engine Fuel Supply aging management program implementation.

3.5.1-23 All Groups except Cracking, loss of bond, Structures Monitoring Yes, if not within the Group 6: interior and and loss of material Program scope of the applicant's Consistent with NUREG-1801.

The above grade exterior (spalling, scaling) due to structures monitoring Structures Monitoring Program, B.1.31, concrete corrosion of embedded program (See subsection will be used to manage the change in steel 3.5.2.2.2.1) material properties, loss of material, and cracking in precast concrete panels and reinforced concrete foundations exposed to an indoor air or outdoor air environment.

3.5.1-25 All Groups except Loss of material due to Structures Monitoring Yes, if not within the Group 6: steel corrosion Program. If protective scope of the applicant's Consistent with NUREG-1801.

The components:

all coatings are relied upon to structures monitoring Structures Monitoring Program, B.1.31, structural steel manage the effects of program (See subsection will be used to manage the loss of aging, the structures 3.5.2.2.2.1) material in carbon and low alloy steel monitoring program is to structural steel, panels and enclosures, Include provisions to cable trays, doors, and structural bolts address protective coating exposed to an indoor air or outdoor air monitoring and environment.

maintenance.

3.5.1-26 All Groups except Loss of material Structures Monitoring Yes, if not within the Group 6: accessible (spalling, scaling) and Program. Evaluation is scope of the applicant's Consistent with NUREG-1801.

The and inaccessible cracking due to freeze- needed for plants that are structures monitoring Structures Monitoring Program, B.1.31, concrete:

foundation thaw located in moderate to program (See subsection will be used to manage cracking and severe weathering 3.5.2.2.2.1) or for loss of material the loss of material in_ conditions (weathering inaccessible areas of precast concrete panels and reinforced Appendix C, Page 8 of 20 Table 3.6.1D -Summary of Aging Management Evaluations Item Component Aging Aging Management Further Evaluation Discussion/Further Evaluation Number EffectlMechanism Programs Recommended index >100 day-inch/yr) plants located in concrete foundations exposed to an (NUREG-1557).

moderate to severe outdoor air environment.

weathering conditions (See subsection 3.5.2.2.2.2.1) 3.5.1-27 All Groups except Cracking due to Structures Monitoring Yes, if not within the Group 6: accessible expansion due to Program. scope of the applicant's Consistent with NUREG-1801.

The and inaccessible reaction with aggregates None for inaccessible structures monitoring Structures Monitoring Program, B.1.31, interior/exterior areas if concrete was program (See subsection will be used to manage cracking in concrete constructed in accordance 3.5.2.2.2.1) or concrete precast concrete panels and reinforced with the recommendations was not constructed as concrete foundations exposed to an in ACI 201.2R-77.

stated for inaccessible outdoor air or indoor air environment.

areas (See subsection 3.5.2.2.2.2.2) 3.5.1-28 Groups 1-3, 5-9: All Cracks and distortion Structures Monitoring Yes, if not within the due to increased stress Program. If a de-watering scope of the applicant's Consistent with NUREG-1 801. The levels from settlement system is relied upon for structures monitoring Structures Monitoring Program, B.1.31, control of settlement, then program (See subsection will be used to manage cracking in the licensee is to ensure 3.5.2.2.2.1) or a de- reinforced concrete foundations proper functioning of the watering system is relied exposed to a soil environment.

de-watering system upon (See subsection through the period of 3.5.2.2.2.2.3) extended operation.

3.5.1-39 Support members; Loss of material due to Structures Monitoring Yes, if not within the welds; bolted general and pitting Program scope of the applicant's Consistent with NUREG-1801.

The connections; support corrosion structures monitoring Structures Monitoring Program, 8.1.31, anchorage to building program (See subsection will be used to manage the loss of structure 3.5.2.2.2.6) material in carbon and low alloy steel engine and conduit supports, concrete anchors, and racks exposed to an indoor air or outdoor air environment.

3.5.1-40 Building concrete at Reduction in concrete Structures Monitoring Yes, if not within the locations of anchor capacity due to Program scope of the applicant's Consistent with NUREG-1801.

The expansion and local concrete structures monitoring Structures Monitoring Program, B.1.31, Appendix C, Page 9 of 20 Table 3.6.1D -Summary of Aging Management Evaluations Item Component Aging Aging Management Further Evaluation Discusslon/Further Evaluation Number Effect/Mechanlsm Programs Recommended grouted anchors; degradation/

service program (See subsection will be used to manage reduction in grout pads for induced cracking or 3.5.2.2.2.6) concrete anchor capacity due to local support base plates other concrete aging concrete degradation for foundation mechanisms concrete around expansion and grouted anchors exposed to an indoor air or outdoor air environment.

3.5.1-41 Vibration isolation Reduction or loss of Structures Monitoring Yes, if not within the elements isolation function/

Program scope of the applicant's Consistent with NUREG-1801.

The radiation hardening, structures monitoring Structures Monitoring Program, B.1.31, temperature, humidity, program (See subsection will be used to manage the reduction sustained vibratory 3.5.2.2.2.6) or loss of isolation function in loading elastomer engine vibration isolators exposed to an outdoor air environment.

3.5.1-50 Groups B2, and B4: Loss of material due to Structures Monitoring No galvanized steel, pitting and crevice Program Consistent with NUREG-1801.

The aluminum, stainless corrosion Structures Monitoring Program, B.1.31, steel support will be used to manage loss of material members; welds; in galvanized steel, stainless steel, and bolted connections; aluminum conduits, conduit supports, support anchorage to cable trays, guy wires, roofing, building structure concrete anchors and miscellaneous steel (turnbuckles, pins, plate, shackles) exposed to an outdoor air environment.

Appendix C, Page 10 of 20 Table 3.5.2.1.20 Meteorological Tower Structures Summary of Aging Management Evaluation Table3.52.1 aee roogical Tow ir Structures

_____________

_____Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Cable Tray Structural Support Carbon and low Indoor Air Loss of Material Structures Monitoring IIL.A3-12 (T-1 1) 3.5.1-25 C alloy steel Program (B.1.31)Galvanized Steel Outdoor Air Loss of Material Structures Monitoring III.B2-7 (TP-6) 3.5.1-50 C Program (B.1.31)Concrete anchor Structural Support Carbon and low Concrete None None VIu.J-21 (AP-3) 3.3.1-96 C alloy steel Outdoor Air Loss of Material Structures Monitoring lll.B2-10 (T-30) 3.5.1-39 A Program (B.1.31)Galvanized Steel Concrete None None ViIJ-21 (AP-3) 3.3.1-96 C Outdoor Air Loss of Material Structures Monitoring llI.B2-7 (TP-6) 3.5.1-50 A Program (B.1.31)Conduits Enclosure Protection Elastomer Outdoor Air Change in Material Structures Monitoring VIL.G-2 (A-20) 3.3.1-61 E, 1 Properties Program (B. 1.31)Galvanized Steel Indoor Air None None VII.J-6 (AP-13) 3.3.1-92 C

-Appendix C, Page 11 of 20 Table 3.5.2.1.20 Meteorological Tower Structures Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Programs Vol. 2 Item Management Conduits Enclosure Protection Galvanized Steel Outdoor Air Loss of Material Structures Monitoring 1iI.B2-7 (TP-6) 3.5.1-50 C Program (6.1.31)Soil Loss of Material Structures Monitonng G Program (B.1.31)Polyvinyl Outdoor Air Change in Materiai Structures Monitoring J Chloride (PVC) Properties Program (B.1.31)Soil None None lStructural Support Galvanized Steel Indoor Air None None ViiJ-6 (AP-13) 3.3.1-92 C Outdoor Air Loss of Material Structures Monitoring 111.12-7 (TP-6) 3.5.1-50 C Program (B.1.31)Soil Loss of Material Structures Monitoring G Program (6.1.31)Polyvinyl Outdoor Air Change in Material Structures Monitoring J Chloride (PVC) Properties Program (B.1.31)Soil None None J Door Enclosure Protection Carbon and low Indoor Air Loss of Material Structures Monitoring III.A3-12 (T-1 1) 3.5.1-25 C alloy steel Program (B.1.31)

Appendix C, Page 12 of 20 Table 3.5.2.1.20 Meteorological Tower Structures Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Door Enclosure Protection Carbon and low Outdoor Air Loss of Material Structures Monitoring iIi.A3-12 (T-1 1) 3.5.1-25 C alloy steel Program (B.1.31)Engine supports Structural Support Carbon and low Outdoor Air Loss of Material Structures Monitoring lll.B4-10 (T-30) 3.5.1-39 A (support member) alloy steel Program (B.1.31)Engine Vibration Vibration Isolation Elastomer Outdoor Air Reduction or Loss of Structures Monitoring lll.B4-12 (T-31) 3.5.1-41 A isolators Isolation Function Program (B.1.31)Foundation Structural Support Concrete Indoor Air Reduction in Anchor Structures Monitoring il.B2-1 (T-29) 3.5.1-40 A concrete at Capacity Due to Local Program (B.1.31)locations of Concrete Degradation expansion and Outdoor Air Reduction In Anchor Structures Monitoring lll.B2-1 (T-29) 3.5.1-40 A grouted anchors Capacity Due to Local Program (B.1.31)Concrete Degradation Guy wires Structural Support Galvanized Steel Outdoor Air Loss of Material Structures Monitoring ill.B2-7 (TP-6) 3.5.1-50 C Program (B.1.31)Miscellaneous Structural Support Galvanized Steel Outdoor Air Loss of Material Structures Monitoring III.B2-7 (TP-6) 3.5.1-50 C steel Program (B.1.31)(turnbuckles, pins, plate, shackles)Panels and Enclosure Protection Carbon and low Indoor Air Loss of Material Structures Monitoring III.A3-12 (T-1 1) 3.5.1-25 A enclosures alloy steel Program (B.1.31)Structural Support Carbon and low Indoor Air Loss of Material Structures Monitoring III.A3-12 (T-1 1) 3.5.1-25 A alloy steel Program (B.1.31)

Appendix C, Page 13 of 20 Table 3.5.2.1.20 Meteorological Tower Structures (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Precast concrete Enclosure Protection Concrete Indoor Air Change In Material Structures Monitoring III.A3-9 (T-04) 3.5.1-23 A panel walls, slabs Properties Program (B.1.31)Cracking Structures Monitoring IIL.A3-2 (T-03) 3.5.1-27 A Program (B.1.31)lII .A3-9 (T-04) 3.5.1-23 A Loss of Material Structures Monitoring IIL.A3-9 (T-04) 3.5.1-23 A Program (B.1.31)Outdoor Air Change in Material Structures Monitoring III.A3-9 (T-04) 3.5.1-23 A Properties Program (B.1.31)Cracking Structures Monitoring II .A3-2 (T-03) 3.5.1-27 A Program (B.1.31)III.A3-6 (T-01) 3.5.1-26 A III.A3-9 (T-04) 3.5.1-23 A Loss of Material Structures Monitoring III.A3-6 (T-01) 3.5.1-26 A Program (B.1.31)IlLA3-9 (T-04) 3.5.1-23 A Appendix C, Page 14 of 20 Table 3.5.2.1.20 Meteorological Tower Structures Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Precast concrete Structural Support Concrete Indoor Air Change in Material Structures Monitoring III.A3-9 (T-04) 3.5.1-23 A panel walls, slabs Properties Program (B.1.31)Cracking Structures Monitoring III.A3-2 (T-03) 3.5.1-27 A Program (B.1.31)IIl.A3-9 (T-04) 3.5.1-23 A Loss of Material Structures Monitoring IIl.A3-9 (T-04) 3.5.1-23 A Program (B.1.31)Racks for Structural Support Carbon and low Indoor Air Loss of Material Structures Monitoring 1113.2-10 (T-30) 3.5.1-39 A repeater, alloy steel Program (B.1.31)batteries Structural Support Concrete Outdoor Air Change in Material Structures Monitoring III.A3-9 (T-04) 3.5.1-23 A Reinforced Properties Program (B.1.31)concrete foundations (above and Cracking Structures Monitoring III.A3-2 (T-03) 3.5.1-27 A below grade) Program (B.1.31)III.A3-6 (T-01) 3.5.1-26 A III.A3-9 (T-04) 3.5.1-23 A Appendix C, Page 15 of 20 Table 3.5.2.1.20 Meteorological Tower Structures (Continued)

__Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Reinforced Structural Support Concrete Outdoor Air Loss of Material Structures Monitoring III.A3-6 (T-01) 3.5.1-26 A concrete Program (B.1.31)foundations (above and ______ 3_5__23_below grade) ill.A3-9 (T-04) 3.5.1-23 A Soil Cracking Structures Monitoring III.A3-3 (T-08) 3.5.1-28 A Program (B.1.31)Roofing Enclosure Protection Aluminum Outdoor Air Loss of Material Structures Monitoring III.84-7 (TP-6) 3.5.1-50 C Program (B.1.31)Elastomer Outdoor Air Change in Material Structures Monitoring Vii.G-2 (A-20) 3.3.1-61 E, 1 Properties Program (B.1.31)Seals Enclosure Protection Elastomer Outdoor Air Change in Material Structures Monitoring Vli.G-2 (A-20) 3.3.1-61 E, 1 Properties Program (B.1.31)Structural Bolts Structural Support Carbon and low Outdoor Air Loss of Material Structures Monitoring III.A3-12 (T-11) 3.5.1-25 A alloy steel Program (B.1.31)Loss Of Preload Structures Monitoring G Program (B.1.31)Structural Steel Structural Support Carbon and low Indoor Air Loss of Material Structures Monitoring III.A3-12 (T-1 1) 3.5.1-25 A alloy steel Program (B.1.31)

Appendix C, Page 16 of 20 Table 3.5.2.1.20 Meteorological Tower Structures (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Structural steel Structural Support Carbon and low Outdoor Air Loss of Material Structures Monitoring III.A3-12 (T-1 1) 3.5.1-25 A (Tower) alloy steel Program (B.1.31)Supports for Structural Support Carbon and low Indoor Air Loss of Material Structures Monitoring 1ll.B2-10 (T-30) 3.5.1-39 A conduits and alloy steel Program (B.1.31)cable Galvanized Steel Outdoor Air Loss of Material Structures Monitoring lll.B2-7 (TP-6) 3.5.1-50 A Program (B.1.31)Soil Loss of Material Structures Monitoring G Program (B.1.31)Stainless Steel Outdoor Air Loss of Material Structures Monitoring 111.12-7 (TP-6) 3.5.1-50 A Program (B.1.31)

Appendix C, Page 17 of 20 Notes Definition of Note A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.C Component is different, but consistent with NUREG-1 801 Item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.D Component Is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited.F Material not in NUREG-1801 for this component.

G Environment not in NUREG-1801 for this component and material.H Aging effect not In NUREG-1 801 for this component, material and environment combination.

I Aging effect in NUREG-1 801 for this component, material and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-1 801.Plant Specific Notes: 1. Structures Monitoring Program is the applicable aging management program for this component.

Appendix C, Page 18 of 20 Table 3.6.2.1.3 Radio Communications System Summary of Aging Management Evaluation Table 3.6.2.1.3 Radio Communications System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Piping and fittings Pressure Boundary Carbon and low Soil (External)

Loss of Material Buried Piping and Tanks VIII.E-1 (S-01) 3.4.1-11 B alloy steel Inspection

-Met Tower Repeater Engine Fuel Supply (B.1.26B)Outdoor Air (External)

Loss of Material Structures Monitoring VII.l-9 (A-78) 3.3.1-58 E, I Program (B.1.31)Propane (Internal)

None None VII.J-23 (AP-6) 3.3.1-97 A, 2 Copper Soil (External)

Loss of Material Buried Piping and Tanks G Inspection

-Met Tower Repeater Engine Fuel Supply (B.1.26B)Outdoor Air (External)

Loss of Material Structures Monitoring G Program (B.1.31)Propane (Internal)

None None VII.J-4 (AP-9) 3.3.1-97 A, 2 Tanks Pressure Boundary Carbon and low Soil (External)

Loss of Material Buried Piping and Tanks VIII.E-1 (S-01) 3.4.1-11 B alloy steel Inspection

-Met Tower Repeater Engine Fuel Supply (B.1.26B)Propane (Internal)

None None VII.J-23 (AP-6) 3.3.1-97 A, 2 Appendix C, Page 19 of 20 Table 3.6.2.1.3 Radio Communications System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Item Notes Type Function Requiring Programs Vol. 2 Item Management Valve Body Pressure Boundary Brass Outdoor Air (External)

Loss of Material Structures Monitoring G Program (B.1.31)Propane (Internal)

None None VII.J-4 (AP-9) 3.3.1-97 A, 2 Carbon and low OutdoorAir (Extemal)

Loss of Material Structures Monitoring VIl.l-9 (A-78) 3.3.1-58 E, I alloy steel Program (B.1.31)Propane (Internal)

None None VII.J-23 (AP-6) 3.3.1-97 A, 2 Appendix C, Page 20 of 20 Notes Definition of Note A Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.D Component is different, but consistent with NUREG-I801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1 801 AMP.E Consistent with NUREG-1 801 for material, environment, and aging effect, but a different aging management program is credited.F Material not in NUREG-1801 for this component.

G Environment not in NUREG-1 801 for this component and material.H Aging effect not in NUREG-1 801 for this component, material and environment combination.

I Aging effect in NUREG-1 801 for this component, material and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-1 801.Plant Specific Notes: 1. The Structures Monitoring Program, B.1.31, is the same program as is used for aging management of external surfaces at the Oyster Creek Nuclear Generating Station, and as such will adequately manage aging of external surfaces for the Radio Communications System components located at the Met Tower.2. Propane is a non-reactive gas and is therefore equivalent to the environment of "Gas" as defined in NUREG-1801 Section IX.D.

Enclosure Appendix D Replacement and new text for Oyster Creek LRA, Appendix A, Final Safety Analysis Report Supplement:

-A.1.26B, Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply-A.1.31, Structures Monitoring Program Replacement and new text for Oyster Creek LRA, Appendix A, Table A.5, License Renewal Commitment List, line items:-31, Structures Monitoring Program-61, Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply Replacement and new text for Oyster Creek LRA, Appendix B, Aging Management Programs:-B.1.26B, Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply-B.1.31, Structures Monitoring Program Appendix D, Page 2 of 18 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Appendix D, Page 3 of 18 A.1.26B BURIED PIPING AND TANK INSPECTION

-MET TOWER REPEATER ENGINE FUEL SUPPLY The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply aging management program is a new program that manages the external surface aging effects of loss of material for carbon steel and copper piping and fittings, and carbon steel tank, in a soil (external) environment.

The program activities consist of preventive and condition-monitoring measures to manage the loss of material due to external corrosion for the piping, fittings, and tank in the scope of license renewal that are in a soil (external) environment.

The program scope includes buried portions of the meteorological tower repeater engine fuel supply (propane) piping and tank located at the Forked River meteorological tower.External inspections of buried components will occur opportunistically when they are excavated during maintenance.

Within 10 years prior to entering the period of extended operation, inspection of buried piping components will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of buried piping components will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period. This program will be implemented prior to entering the period of extended operation.

A.1.31 STRUCTURES MONITORING PROGRAM The Structures Monitoring Program is an existing program that was developed to implement the requirements of 10 CFR 50.65 and is based on NUMARC 93-01, 'Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,* Revision 2 and Regulatory Guide 1.160, 'Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 2. The program includes elements of the Masonry Wall Program and the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants aging management program.The program relies on periodic visual inspections to monitor the condition of structures and structural components, structural bolting, component supports, masonry block walls, water-control structures, the Fire Pond Dam, exterior surfaces of mechanical components that are not covered by other programs, and HVAC ducts, damper housings, and HVAC closure bolting. The program relies on procurement controls and installation practices, defined in plant procedures, to ensure that only approved lubricants and proper torque are applied to bolting in scope of the program.

Appendix D, Page 4 of 18 The scope of the program will be enhanced to include structures and structural components that are not currently monitored, including Station Blackout System structures and phase bus enclosure assemblies, and Meteorological Tower Structures; but determined to be in the scope of license renewal, submerged structures, component supports not covered by other programs, the Fire Pond Dam, exterior surfaces of Oyster Creek and Forked River Combustion Turbine mechanical components that are not covered by other programs, including exterior surfaces of HVAC ducts, damper housings, and closure bolting. The program will also be enhanced to require removal of piping and component insulation on a sampling basis to allow visual inspection of insulated surfaces.

The program will also be enhanced to require sampling and testing of groundwater every 4 years to confirm that the soil environment is non-aggressive to below-grade concrete structures.

Other program scope enhancements include inspection of piping and piping components associated with the Radio Communications system located at the meteorological tower site. The enhancements will be made prior to entering the period of extended operation.

Inspection criteria will be enhanced to provide reasonable assurance that change In material properties, cracking, loss of material, loss of form, reduction or loss of isolation function, reduction in anchor capacity due local degradation, and loss of preload are adequately managed so that the intended functions of structures and components within the scope of the program are maintained consistent with the current licensing basis during the period of extended operation.

Inspection frequency is every four (4) years; except for submerged portions of the water- control structures, which will be inspected when dewatered or on a frequency not to exceed ten (10) years. The program contains provisions for more frequent inspections to ensure that observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process.

Appendix D, Page 5 of 18 LICENSE RENEWAL COMMITMENT LIST Appendix D, Page 6 of 18 A.5 LICENSE RENEWAL COMMITMENT LIST The items in the table below include a revision to item 31 and new item 61.UFSAR ENHANCEMENT Item Number COMMITMENT SUPPLEMENT OR SOURCE LOCATION IMPLEMENTATION SUC (LRA APP. A) SCHEDULE 31) Structures Monitoring Program Existing program is credited.

The program includes elements of the A.1.31 Prior to the period of Section B.1.31 Masonry Wall Program and the RG 1.127, Inspection of Water- extended operation.

Control Structures Associated With Nuclear Power Plants aging management program. The Structures Monitoring Program will be enhanced to include: 1. Buildings, structural components and commodities that are not in scope of maintenance rule but have been determined to be in the scope of license renewal. These include miscellaneous platforms, flood and secondary containment doors, penetration seals, sump liners, structural seals, and anchors and embedment.

2. Component supports, other than those in scope of ASME Xl, 31) Structures Monitoring Subsection IWF.Program 3. Inspection of Oyster Creek external surfaces of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bolting. Inspection and acceptance criteria of the external surfaces will be the same as those specified for structural steel components and structural bolting.4. The visual inspection of insulated surfaces will require the removal of Insulation.

Removal of insulation will be on a sampling basis that bounds insulation material type, susceptibility of Insulated piping or component material to potential degradations that could result from being in contact with insulation, and system operating temperature.

Appendix D, Page 7 of 18 UFSAR ENHANCEMENT Item Number COMMITMENT SUPPLEMENT IOOR SOURCE LOCATION IMPLEMENTATION (LRA APP. A) SCHEDULE I 5. Inspection of electrical panels and racks, junction boxes, instrument racks and panels, cable trays, offsite power structural components and their foundations, and anchorage.

6. Periodic sampling, testing, and analysis of ground water to confirm that the environment remains non-aggressive for buried reinforced concrete.7. Periodic inspection of components submerged in salt water (Intake Structure and Canal, Dilution structure) and in the water of the fire pond dam, including trash racks at the Intake Structure and Canal.8. Inspection of penetration seals, structural seals, and other elastomers for change in material properties.

9. Inspection of vibration isolators, associated with component supports other than those covered by ASME Xi, Subsection IWF, for reduction or loss of isolation function.10. The current inspection criteria will be revised to add loss of material, due to corrosion for steel components, and change in material properties, due to leaching of calcium hydroxide and aggressive chemical attack for reinforced concrete.

Wooden piles and sheeting will be inspected for loss of material and change in material properties.

11. Periodic inspection of the Fire Pond Dam for loss of material and loss of form.12. Inspection of Station Blackout System structures, structural components, and phase bus enclosure assemblies.

13. Inspection of Forked River Combustion Turbine power plant external surfaces of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bolting. Inspection and acceptance criteria of the external surfaces will be the same as those specified for structural steel components and structural bolting.14. The program will be enhanced to Include Inspection of Meteorological Tower Structures.

Inspection and acceptance criteria will be the same as those specified for other structures In the scope of the program.I I L 1,

--Appendix D, Page 8 of 18 UFSAR ENHANCEMENT Item Number COMMITMENT SUPPLEMENT OR SOURCE LOCATION IMPLEMENTATION SUC (LRA APP. A) SCHEDULE 15. The program will be enhanced to include Inspection of exterior surfaces of piping and piping components associated with the Radio Communications system, located at the meteorological tower site, for loss of material due to corrosion.

inspection and acceptance criteria will be the same as those specified for other external surfaces of mechanical components.

61) The Buried Piping and Tank Inspection

-Met Tower Repeater A.1 .26B Prior to the period of Section B.1 .26B Engine Fuel Supply aging management program Is a new program extended operation.

that manages the external surface aging effects of loss of material for copper and carbon steel piping, and carbon steel tanks in a soii (external) environment.

The program activities consist of preventive and condition-monitoring measures to manage the loss of material due to external corrosion for piping and piping system components in the scope of license renewal that are in a soil (external) environment.

The program scope includes buried portions of the Met Tower based 61) Buried Piping and radio communications system repeater backup engine generator fuel Tank Inspection

-Met (propane) supply piping and the associated buried fuel supply tank, Tower Repeater Engine located at the Forked River Meteorological Tower.Fuel Supply External inspections of buried components will occur opportunistically when they are excavated during maintenance.

Within 10 years prior to entering the period of extended operation, inspection of buried piping will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of buried piping will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period. This program will be Implemented prior to entering the period of extended operation.

Appendix D, Page 9 of 18 AGING MANAGEMENT PROGRAMS Appendix D, Page 10 of 18 B.1.26B BURIED PIPING AND TANK INSPECTION

-MET TOWER REPEATER ENGINE FUEL SUPPLY Program Description The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply aging management program is a new aging management program that relies on coating, wrapping and periodic inspection as a preventive measure, and to mitigate and manage the effects of corrosion on the pressure-retaining capacity of carbon steel and copper piping and fittings, and carbon steel tank, in a soil (external) environment.

External coatings and wrappings are maintained in accordance with standard industry practices.

External inspections of buried piping components will occur opportunistically when excavated during maintenance.

Within 10 years prior to entering the period of extended operation, inspection of buried piping components will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of buried piping components will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period. The aging management program activities described below as well as in Section A.1.26B will be coordinated with First Energy, as necessary, pursuant to an Easement, License, and Restrictive Covenant Agreement.

NUREG-1801 Consistency The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply aging management program is consistent with the ten elements of aging management program XI.M.34, "Buried Piping and Tanks Inspection," specified in NUREG-1801, with exceptions.

Exceptions to NUREG-1801

• NUREG-1801, Section X1.M.34 Buried Piping and Tanks Inspection AMP relies on preventive measures such as coatings and wrappings, however portions of this piping may not be coated or wrapped.Inspections of buried piping that is not wrapped will inspect for loss of material due to general, pitting, crevice, and microbiologically influenced corrosion.

• The Corrective Actions (Element 7), Confirmation Process (Element 8), and Administrative Controls (Element 9) are not accomplished in accordance with the AmerGen quality assurance (QA) program and are not in accordance with the requirements of 10 CFR Part 50, Appendix B, but do meet the guidance in Branch Technical Position IQMB-1, Quality Assurance for Aging Management Programs.

Appendix D, Page 11 of 18 Enhancements The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply aging management program is a new program to be implemented for the buried piping and tank located at the meteorological tower.Evaluation and Technical Basis 1. Scope of Program This program relies on coating, wrapping and periodic inspection as a preventive measure, and to mitigate and manage loss of material caused by corrosion of the external surface of the buried piping and tank. These activities will be used to manage external aging effects of the underground steel and copper piping, fittings, and tank. The buried components are exposed to a soil environment that may be sufficiently aggressive to result in loss of material caused by general, pitting, and crevice corrosion, and microbiologically-influenced corrosion (MIC). Periodic inspections are performed when the components are excavated for maintenance or for any other reason. The scope of the program covers buried carbon steel and copper portions of the meteorological tower repeater engine fuel supply (propane) piping and tank at the meteorological tower that is within the scope of license renewal.2. Preventive Actions In accordance with industry practice, portions of the underground piping and tank at the meteorological tower were either procured with coating or coated during installation with a protective coating system to protect the piping and tank from contacting the potentially aggressive soil environment.

Portions of the piping may not be coated or wrapped.3. Parameters Monitored/lnspected This program monitors parameters such as coating and wrapping integrity directly related to corrosion damage of the external surface of buried steel piping and tanks. The program also directly monitors, for indications of corrosion, the external surfaces of buried steel and copper piping that are not coated or wrapped. Coatings and wrappings, and the external surface of buried piping components that are not coated or wrapped, are inspected by visual techniques.

Coatings and wrappings will be inspected for any evidence of damaged wrapping or coating defects, such as coating perforation, holidays, or other damage, that is an indicator of possible corrosion damage to the external surface of the piping or tank. The external surfaces of buried piping components that are not coated or wrapped will be inspected directly for any evidence of corrosion.

Appendix D, Page 12 of 18 4. Detection of Aging Effects Inspections will be performed to confirm that coating and wrapping are intact, and to determine the extent of potential corrosion of buried piping components that are not coated or wrapped. These inspections are an effective method to ensure that corrosion of external surfaces has not occurred and the intended function is maintained.

The buried piping and tank will be opportunistically inspected whenever excavated for maintenance.

The inspections will be performed on all of the areas made accessible to support the maintenance activity.It is anticipated that one or more opportunistic inspections may occur within a ten-year period. Within 10 years prior to entering the period of extended operation, inspection of the buried piping and tank will be performed unless an opportunistic inspection occurs within this ten-year period. Upon entering the period of extended operation, inspection of the buried piping and tank will again be performed within the next ten years, unless an opportunistic inspection occurs during this ten-year period. Inspections will be performed in areas with the highest likelihood of corrosion problems, and in areas with a history of corrosion problems, if any. The meteorological tower repeater engine fuel supply has not had a history of corrosion problems on the exterior surfaces of buried piping or the tank to date.5. Monitoring and Trending Results of any previous inspections will be used to identify susceptible locations for future inspections.

6. Acceptance Criteria Any coating and wrapping degradations, and any associated or other piping or tank degradation, will be reported and evaluated in accordance with corrective actions procedures.

External component degradation is reported and evaluated whenever buried commodities are uncovered during yard excavation activities.

Leakage detected through periodic testing and visual inspections will be evaluated in accordance with the corrective actions procedures.

Evaluations will consider system and component ability to perform their intended functions.

The extent of surface corrosion and meteorological tower repeater engine fuel supply operating experience will determine corrective actions and the need and scope for extent of condition and future inspections.

Appendix D, Page 13 of 18 7. Corrective Actions The meteorological tower repeater and supporting systems are non-safety related and are not subject to 10 CFR 50 Appendix B requirements in the current licensing basis (CLB). AmerGen has elected not to include this program under the Oyster Creek 10 CFR 50 Appendix B Program. Instead, processes and procedures will be established to assure that conditions adverse to quality are promptly identified and corrected.

Identified conditions that do not satisfy acceptance criteria will be documented, evaluated, and corrected as required to maintain the intended function of the meteorological tower repeater engine fuel supply during the period of extended operation.

In the case of significant conditions adverse to quality, the procedures will require that the cause of the condition be determined, actions to preclude repetition be taken, and the condition be reported to the appropriate level of management.

8. Confirmation Process The confirmation process for the meteorological tower repeater engine fuel supply will focus on follow-up actions that must be taken to verify effective implementation of corrective actions and preclude repetition of significant conditions adverse to quality. The process and procedures established will include the requirements that measures be taken to preclude repetition of significant conditions adverse to quality. These measures will include actions to verify effective implementation of the proposed corrective actions, determination of root cause, tracking open corrective actions to completion, and reviews of corrective action effectiveness.

9. Administrative Controls The meteorological tower repeater engine fuel supply procedures will include administrative controls that provide for formal review and approval of aging management activities.

10. Operating Experience The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply aging management program is a new program that will be effective in managing aging degradation for the period of extended operation by providing timely detection of aging effects and implementation of appropriate corrective actions prior to loss of system or component intended functions.

The buried piping and tank at the meteorological tower that is included in the scope of license renewal is the below grade propane filled piping and tank next to the meteorological tower.

Appendix D, Page 14 of 18 Conclusion The Buried Piping and Tank Inspection

-Met Tower Repeater Engine Fuel Supply aging management program will provide reasonable assurance that the aging effects on the external surfaces of buried piping components are adequately managed so that the intended functions of components within the scope of license renewal are maintained consistent with the current licensing basis during the period of extended operation.

Appendix D, Page 15 of 18 B.1.31 STRUCTURES MONITORING PROGRAM Program Description The Structures Monitoring Program provides for aging management of structures and structural components, including structural bolting, within the scope of license renewal. The program was developed based on guidance in Regulatory Guide 1.160 Revision 2, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and NUMARC 93-01 Revision 2, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," to satisfy the requirement of 10 CFR 50.65, 'Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," The scope of the program also includes condition monitoring of masonry walls and water-control structures as described in the Masonry Wall Program and in the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants, aging management program. As a result, the program elements incorporate the requirements of NRC IEB 80-11, 'Masonry Wall Design", the guidance in NRC IN 87-67, 'Lessons learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11", and the requirements of NRC Regulatory Guide 1.127, "Inspection of Water-Control Structures Associated with Nuclear Power Plants." The program relies on periodic visual inspections by qualified personnel to monitor structures and components for applicable aging effects. Specifically, concrete structures are inspected for loss of material, cracking, and a change in material properties.

Steel components are inspected for loss of material due to corrosion.

Masonry walls are inspected for cracking, and elastomers will be monitored for a change in material properties.

Earthen structures associated with water-control structures and the Fire Pond Dam will be inspected for loss of material and loss of form. Component supports will be inspected for loss of material, reduction or loss of isolation function, and reduction In anchor capacity due to local concrete degradation.

Exposed surfaces of bolting are monitored for loss of material, due to corrosion, loose nuts, missing bolts, or other indications of loss of preload. The program relies on procurement controls and installation practices, defined in plant procedures, to ensure that only approved lubricants and proper torque are applied consistent with the NUREG-1801 bolting integrity program.The scope of the program will be enhanced to include structures that are not monitored under the current term but require monitoring during the period of extended operation.

Details of the enhancements are discussed below.Inspection frequency is every four (4) years; except for submerged portions of water- control structures, which will be inspected when the structures are dewatered, or on a frequency not to exceed 10 years. The program contains provisions for more frequent inspections to ensure that observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process Appendix D, Page 16 of 18 NUREG-1801 Consistency The Structures Monitoring Program is consistent with the ten elements of aging management program XI.S6,"Structures Monitoring Program," specified in NUREG-1801.

Exceptions to NUREG-1801 None.Enhancements The scope of the program will be increased to add buildings, structural components and commodities that are not in scope of maintenance rule but have been determined to be in the scope of license renewal. These include miscellaneous platforms, flood and secondary containment doors, penetration seals, liner for sumps, structural seals, and anchors and embedment.

The scope of the program will be enhanced to include Station Blackout System Structures, structural components, and phase bus enclosure assemblies.

Inspection frequency, inspection methods, and acceptance criteria will be the same as those specified for other structures in scope of the program.The scope of the program will be increased to include component supports, other than those in scope of ASME Xl, Subsection IWF.The scope of the program will be enhanced to include inspection of external surfaces of Oyster Creek and Forked River Combustion Turbine mechanical components that are not covered by other programs, including exterior surfaces of HVAC duct, damper housings, and HVAC closure bolting. Inspection and acceptance criteria of the exterior surfaces will be the same as those specified for structural steel components and structural bolting.The program will be enhanced to require removal of piping and component insulation to permit visual inspection of insulated surfaces.

Removal of insulation will be on a sampling basis that bounds insulation material type, susceptibility of insulated piping or component material to potential degradations that could result from being in contact with insulation, and system operating temperature.

The program will provide for inspections of, electrical panels and racks, junction boxes, instrument racks and panels, cable trays, offsite power structural components and their foundations, and anchorage.

The program will provide for periodic sampling and testing of ground water and review its chemistry data to confirm that the environment remains non-aggressive for buried reinforced concrete.The program will provide for periodic inspection of components submerged in salt water (Intake Structure and Canal, Dilution structure) and in the water of the fire pond dam, including trash racks at the Intake Structure and Canal.

Appendix D, Page 17 of 18 The program will require inspection of penetration seals, structural seals, and other elastomers for change in material properties by inspecting the elastomers for cracking and hardening.

The program will require inspection of vibration isolators, associated with component supports other than those covered by ASME Xl, Subsection IWF, for reduction or loss of isolation function by inspecting the isolators for cracking and hardening.

The current inspection criteria will be enhanced to add loss of material, due to corrosion for steel components, and change in material properties, due to leaching of calcium hydroxide and aggressive chemical attack for reinforced concrete.

Accessible wooden piles and sheeting will be inspected for loss of material and a change in material properties.

Concrete foundations for Station Blackout System structures will be inspected for cracking and distortion due to increased stress level from settlement that may result from degradation of the inaccessible wooden piles.The program will be enhanced to include periodic inspection of the Fire Pond Dam for loss of material and loss of form.The program will be enhanced to include Inspection of Meteorological Tower Structures.

Inspection and acceptance criteria will be the same as those specified for other structures in the scope of the program.The program will be enhanced to include inspection of exterior surfaces of piping and piping components associated with the Radio Communications system, located at the meteorological tower site, for loss of material due to corrosion.

Inspection and acceptance criteria will be the same as those specified for other external surfaces of mechanical components.

Enhancements will be implemented prior to the period of extended operation.

Operating Experience The review of program documentation, and other plant operating experience before the program was implemented, identified cracking of reinforced of exterior walls of the reactor building, drywell shield wall above elevation 95', and the spent fuel pool support beam. Cracking of the reactor building exterior walls was generally minor and attributed to early shrinkage of concrete and temperature changes. Engineering evaluation concluded that the structural integrity of the walls is unaffected by the cracks. Repairs to areas of concern were made to prevent water intrusion and corrosion of concrete rebar. The cracks and repaired areas are monitored under the program to detect any changes that would require further evaluation and corrective action.Cracking of the drywell shield wall was attributed to high temperature in the upper elevation of the containment drywell. Engineering analysis concluded that stresses are well below allowable limits taking into consideration the existing cracked condition.

The shield wall cracking was addressed in NRC SEP review of the plant under Topic 111-7B. The cracks have been mapped and inspected Appendix D, Page 18 of 18 periodically under the program. Recent inspections identified no significant change in the cracked area.Cracking of the spent fuel storage pool concrete support beams was identified in mid-1980.

Subsequently crack monitors were installed to monitor crack growth and an engineering evaluation was performed.

Based on the evaluation results and additional non-destructive testing to determine the depth of the cracks, it was concluded that the beams would perform their intended function, and that continued monitoring with crack monitors is not required.

The cracks are examined periodically under the program and have shown little change.Inspection of the intake canal, performed in 2001, identified cracks and fissures, voids, holes, and localized washout of coatings that protect embankment slopes from erosion. The degradations were evaluated and determined not to impact the intended function of the intake canal (UHS). However the inspector recommended repair of the degradations to prevent further deterioration.

A project to repair the canal banks has been initiated.

Inspections conducted in 2002, concluded that degradations discussed above have not become worse and remains essentially the same as identified in previous inspections.

In addition minor cracking, rust stains, water stains, localized exposed rebars and rebar corrosion, and damage to siding were observed.

The degradations were evaluated and determined not to have an impact on the structural integrity of affected structures.

Operating experience review concluded that the program is effective for managing aging effects of structures, structural components, and water-control structures.

Conclusion The Structures Monitoring Program was developed to implement the requirements of 10 CFR 50.65, 'Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.' The program relies on periodic visual inspections to monitor the condition of structures and structural components.

Inspection frequency is every four (4) years (except for water-control structures) with provisions for more frequent inspections to ensure that observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process. Submerged portions of water-control structures will be inspected when dewatered or on a frequency not to exceed ten (10) years.The scope of the program will be enhanced to include all structures, and component supports not covered by other programs, the Fire Pond Dam, and exterior surfaces of mechanical components in the scope of license renewal that are not covered by other programs.

Inspection criteria will also be enhanced to provide reasonable assurance that the aging effects are adequately managed so that the intended functions of structures and components within the scope of license renewal are maintained consistent with the current licensing basis during the period of extended operation.