ML060320211

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2006/01/31-Oyster Creek License Renewal - GALL Reconciliation Document
ML060320211
Person / Time
Site: Oyster Creek
Issue date: 01/31/2006
From: Beck G
Exelon Corp
To: Ashley D
NRC/NRR/ADRO/DLR
Ashley D, NRR/DLR/RLRA, 415-3191
References
%dam200604, NUREG-1801, NUREG-1801, Rev 1, TAC MC7624
Download: ML060320211 (79)
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Text

-OC LRA "Reconciliation Document" Paae ii SAshley- OC RA "Reconciliation Document"., :s ., f x ,.A b., L.AdA. ..........

a.Paae 1 ff From: <George.Beck exeloncorp.com>

To: <djal @nrc.gov>Date: 01/31/2006 10:35:12 AM

Subject:

OC LRA "Reconciliation Document" Mr. Ashley, Attached is a copy of the "Reconciliation Document".

This is a PDF of the hard copy you reviewed last week.George Beck<<<Reconciliation Doc Rev_0 01_22_06.pdf>>

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CC: <fred.polaski@exeloncorp.com>, <donald.warfel~exeloncorp.com>,<stu.getz1§exeloncorp.com>, <john.hufnagel

@exeloncorp.com>

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Subject:

Creation Date: From: OC LRA "Reconciliation Document" 01/31/2006 10:33:52 AM<George.Beck@exeloncorp.com>

Created By: George.Beck@exeloncorp.com Recipients nrc.gov OWGWPO01 .HQGWDO01 DJA1 (D. Ashley)exeloncorp.com john.hufnagel CC stu.getz CC donald.warfel CC fred.polaski CC Post Office OWGWPO01.HQGWDO01 Route nrc.gov exeloncorp.com Files Size MESSAGE 1071 TEXT.htm 1745 Reconciliation Doc Rev_0 01_22_06.pdf Mime.8,22 5514113 Date & Time 31 January, 2006 10:33:52 AM 4025459 Options Expiration Date: Priority: Reply Requested:

Return Notification:

Concealed

Subject:

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.:=S.: ..... .. .t .-£.. Shysp.B' .R U l Exelon Corporation Sheet 1 of 11 Reconciliation of Program and Line Item Differences Between January 2005 Draft NUREG-1 801 and September 2005 NUREG-1801 Revision 1 Oyster Creekh Generating Station License Renewal Ashiey -Reconciliation Doc Rev 0 012206.pdfPg aa-;;L q ; -l :r vxN^M. Vi,,, .. ,,,,,,,,, , ,.^ .... .Page I Exelon Corporation Sheet 2 of 11 Prepared by: Checked by: Checked by: Checked by: Checked by: Checked by: Checked by: Checked by: Checked by: Checked by: Approved by: Approval Pa!S. C. Getz M. J. Ma~y 4-7$ P. Muggiet 7 A. O~ua~o, 44 C.Micklo_G. JIeck_5,Rafty-C,, I M. A. Miller D. g. Wrfei U tge Date: Date: Date: Date: Date: Date: Date: Date: Date: Date: Date: ,Lu/2oo//g-L/QZW/a ( AC-/ zzez A , o [C)(,
.Ashley -Reconciliation Doc Rev 2 012?06.pdf P 3 1 Paet3 Sheet 3 of 11 REVISION

SUMMARY

Eqokh e Ae Revisio o N/A (Initial Issue)1 2 3 4 4 -_.. 5 I:

fl D ,shev, -Rcncilniaition lv PRev 0 01 !29 Orndf Page 41 Sn lv 1- -* 7Z Z- v-- v ,^W,-Y' ; r- .-..rA" x2,>= -.- ------. .... -^S<~, -i~>E~.:. ,tAAt= .... =... .79 -~..I: Sheet 4 of 11 TABLE OF CONTENTS Page ADDroval Page .............................................

2 Revision Summary ......... 3 Table of Contents.

4 1.0 Purpose .5 2.0 Scope .5 3.0 Methodology.5 4.0 Co.c.us.on.7 5.0 References

.10 6.0 Attachments

.10 I -,. no no ,, Pni R X3-I r Arhl-,- Mprnnnilintiqwn nnfl Pax, n ni 99 AfRndf UsagesU I -I I 7 -Sheet 5of 11 1.0 Purpose The Oyster Creek Generating Station License Renewal Application (LRA) was submitted to the NRC on July 22, 2005. The Aging Management Programs and activities contained in the LRA were structured to address the guidance provided in the Draft NUREG-1 800, 'Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", January 2005. Draft NUREG-1800 references Draft NUREG-1801, "Generic Aging Lessons Learned (GALL) Report', January 2005.Subsequently, NUREG-1800, Revision 1, 'Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" was published in September 2005, referencing NUREG-1801, Revision 1, 'Generic Aging Lessons Learned (GALL) Reporr, published September 2005.The purpose of this document is to identify and reconcile differences between the January 2005 Draft GALL Aging Management Programs and Aging Management Review (AMR) line items used in the Oyster Creek LRA, with those in tie September 2005 Revision 1 GALL. Differences that result in required changes to the LRA will be incorporated in updates to the application, in accordance with the requirements of 10 CFR 54.The Oyster Creek License Renewal Team reviewed the changes to NUREG-1800 and NUREG-1801, utilizing information provided by the NRC in NUREG-1832 and NUREG-1833.

The Team first evaluated these changes to determine their applicability to the Oyster Creek LRA, and then evaluated the applicable changes to determine their impact on the Oyster Creek LRA. This review included identification and evaluation of:* Changes and additions to NUREG-1801 Aging Management Programs* Changes to NUREG-1801 Aging Management Review line Items used in the Oyster Creek LRA-Deletions of Aging Management'Review line items from the Revision 1 NUREG-1801 that had been used in the Oyster Cre 9k LRA The specifics of this review and evaluation are presented in Section 2.0, Scope, below. It is the Oyster Creek License Renewal Team's understanding of the NRC's expectation of the scope of reconciliation that new line items added in September 2005 Revision 1 NUREG-1801 do not have to be considered in this reconciliation.

In addition, changes determined to be administrative in nature were deemed to not materially affect the contents of the LRA, and were not included in the scope of this document.2.0 Scope The scope of this document is as follows:* Summarize in tabular form changes or additions to the Aging Management Programs (AMPs) from the September 2005 Revision I GALL, with technical assessments of the differences and impact on the Oyster Creek LRA, if any.* Review new September 2005 Revision 1 GALL AMPs potentially applicable to the Oyster Creek LRA, and evaluate the ability of the AMPs used in the Oyster Creek LRA to satisfy the specifications of the new Revision 1 GALL AMPs.* Evaluate changes to GALL AMR line items found in the September 2005 Revision 1 GALL from those in the January 2005 Draft GALL, and determine whether those changes affect I I I I -I I 1'r) 4Qhlav -RIPnnnniliatir)n Dnr Rev 0 01 22 06.r)df Page 6 I=I fl A7hlcro -ernniitir nbc Re 0 0-7-111 2 0dfl'a Sheet6of 11 the Oyster Creek LRA's use of the GALL AMR line items. This activity contains three categories:

1. AMR line items used in the Oyster Creek LRA that require further evaluation in the September 2005 Revision 1 GALL, but did not require further evaluation in the January 2005 Draft GALL 2. AMR line items that were contained in the January 2005 Draft GALL and were used in the Oyster Creek LRA, but have since been deleted from the September 2005 Revision 1 GALL 3. Other AMR line items from the January 2005 Draft GALL used in the Oyster Creek LRA that contain non-administrative differences in the September 2005 Revision 1 GALL For line items used in the Oyster Creek LRA that invoked plant specific programs which require further evaluation in both the January 2005 Draft GALL and the September 2005 Revision 1 GALL, review the applicable referenced sections in both corresponding versions of NUREG-1800 (SRP) for changes, and determine any impact on the OC LRA.For line items used in the Oyster Creek LRA that invoked GALL programs (non-plant specific) which required further evaluation in both the January 2005 Draft SRP and September 2005 Revision 1 SRP, the applicable referenced sections of the SRP were spot-checked for changes to ascertain whether new or revised further evaluations of GALL program results were specified.

No changes to the SRP further evaluation sections that required change to Oyster Creek GALL-based aging management programs were noted in the spot-check.

It was concluded that changes associated with the SRP sections concerning further evaluation of GALL programs would be evident during the evaluation of changes to the GALL programs, and any effect on the OC LRA would be identified as part of that review. Consequently, comprehensive review of the SRP sections for further evaluation of GALL programs was not included in the scope of this evaluation.

3.0 Methodology The September 2005 Revision 1 GALL AMPs applicable to the Oyster Creek LRA were reviewed and compared with the January 2005 Draft GALL version. Applicable differences potentially significant to the CC LRA (i.e., did not consist solely of administrative changes) were identified and summarized in the table, along with a technical assessment of the significance of the change, and whether the O LRA was affected by the change. Reference Attachment 1.September 2005 Revision 1 GALL included six (6) new AMPs that were not contained in the January 2005 Draft GALL. Two of these new programs, XI.M1 1A, 'Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors," and XI.M37, 'Flux Thimble Tube Inspection,'

are applicable only to pressurized water reactors and therefore not applicable to Oyster Creek. The remaining four programs, XI.M35, 'One-Time Inspection of ASME Code Class 1 Small.Bore Piping,' XL.M36, "External Surfaces Monitoring," XL.M38, "Inspection of Intemal Surfaces in Miscellaneous Piping and Ducting Components,'

and XI.M39, "Lubricating Oil Analysis," were evaluated and compared with the corresponding AMPs used in the Oyster Creek LRA. The comparison was made on an element-by-element basis, with resulting conclusions as to the equivalency of the AMP used by the Oyster Creek LRA. These evaluations are found in Attachment 2.Note: Portions of the Oyster Creek Generating Station Ucense Renewal Application not submitted with the original application on July 22, 2005 (i.e., those concerning the Meteorological Tower and the Forked River Combustion Turbines) were developed using the applicable September 2005 Revision 1 GALL AMPs. Except for Structures Monitoring, the I D. As'hley -Reconciliation Doc Rev 0 01 06.pdf Page 7 ]I D.Ashlev -- , ---1---- I-Recocilatio Do Re 0 01 20.p Page ~nr'117-Sheet 7of 11 AMPs used for these portions of the LRA do not require reconciliation between the versions in the January 2005 Draft GALL and September 2005 Revision 1 GALL. The Oyster Creek B.1.31 Xl.S6 Structures Monitoring Program is used (in lieu of the Revision 1 GALL program External Surfaces Monitoring) for all portions of the Oyster Creek LRA. See Attachment 2.2.The AMRs defined in Volume 2 of GALL present acceptable methods of managing aging effects.Each AMR line item from the GALL report identifies the component, material, environment, and aging effect, along with the corresponding aging management program. A unique AMR line item may be used multiple times. The September 2005 Revision 1 GALL incorporated changes to some of the AMR line items. NUREG-1832, 'Analysis of Public Comments on the Revised License Renewal Guidance Documents", September 2005, Appendix E, "Aging Management Review Line-Item Comparison" provides a 'before and after' presentation of the AMR line items for evaluation.

Three categories of changes to AMR fine items used in the Oyster Creek LRA (from the January 2005 Draft GALL) were identified:

1. AMR line items used in the Oyster Creek LRA that require further evaluation in the September 2005 Revision 1 GALL, but did not require further evaluation in the January 2005 Draft GALL.Nineteen (19) line items used in the Oyster Creek LRA which did not require further evaluation in the January 2005 Draft GALL, now list a 'Yes" in the further evaluation column in the tables found in Volume 2 of the September2005 Revision 1 GALL These changes were evaluated for their effect on the OC LRA, if any. The results are included in Attachment 3.2. AMR line items that were contained in the January 2005 Draft GALL and were used in the Oyster Creek LRA, but have since been deleted from the September 2005 Revision 1 GALL.Twenty (20) line items used in the Oyster Creek LRA that were included in the January 2005 Draft GALL have been deleted from Volume 2 of the September 2005 Revision 1 GALL. For fifteen (1 5) of these line items, the GALL Master List addresses the reasoning behind the deletion and lists an equivalent or replacement line item. The twenty line item deletions were evaluated for their effect on the OC LRA, if any. The results are included in Attachment 4.3. Other AMR line items from the January 2005 Draft GALL used in the Oyster Creek LRA that contain non-administrative differences in the September 2005 Revision 1 GALL Forty-One (41) line items from the January 2005 Draft GALL that were used in the Oyster Creek LRA were identified to have had non-administrative changes made to them in the September 2005 Revision 1 GALL. These line items were not captured in the first category above (i.e.,'further evaluation" did not change). These changes typically contain a technical difference, e.g., address an additional aging effect or Invoke a new or different program. These changes were evaluated for their effect on the OC LFIA, if any. The results are included in Attachment 5.Eighteen (18) line items used in the Oystsr Creek LRA invoked plant specific programs which require further evaluation in both the January 2005 Draft NUREG-1800 (SRP) and the September 2005 Revision 1 SRP. The applicable referenced sections in both versions of the SRP were reviewed for changes that may have necessitated new evaluations of a plant specific aging management program to ensure that aging effects are adequately managed. This review concluded that there were no significant changes to the SRP sections, and that new evaluations were not required.

The results are included in Attachment

6.

DAshley -Reconciliation Doc Rev_0 01_2206.pdfP v r: 7 r C : z -A, g ( , .Page 8 S1----111, 1 -, -_'__ __ , _' __ " " ". " --__ -... .... --, , __"" -...... ......Sheet 8 of 11 4.0 Conclusion The following changes to the Oyster Creek LRA aging management programs were required due to reconciliation between the January 2005 draft GALL and the approved September 2005 Revision 1 GALL: Program B.1.7 (Xl.M7) BWR Stress Corrosion Cracking: The September 2005 Revision 1 GALL program deletes the specific reference to BWRVIP-29 for reactor coolant water chemistry.

An exception was taken in the Oyster Creek LRA to BWRVIP-29 for this program; due to the GALL change, this exception no longer applies.Program B.1.16 (XI.M23) Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems: The September 2005 Revision 1 GALL program deletes specifications for aging management of active components.

An exception was taken in the Oyster Creek LRA to tracking the number and magnitude of lifts by the crane. Due to the GALL change, this exception no longer applies.Program B.1.22 (XI.M30) Fuel Oil Chemistry:

The September 2005 Revision 1 GALL program states that the fuel oil aging management program is in part based on the fuel oil purity and testing requirements of the plant's Technical Specifications that are based on the Standard Technical Specifications of NUREG-1430 through NUREG-1433.

The January 2005 Draft did not invoke the Standard Technical Specifications.

Oyster Creek has not adopted the Standard Technical Specifications as described in NUREG-1430 through NUREG-1435; however, the Oyster Creek fuel oil specifications and procedures invoke similar requirements for fuel oil purity and fuel oil testing as described by the Standard Technical Specifications.

This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.Program B.1.24 (XI.M32) One-Time Inspection:

The September 2005 Revision 1 GALL program states that one-time inspection of Class 1 piping less than or equal to NPS 4 is addressed in Chapter XI.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping.

NUREG-1 801 aging management program XL.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping will not be used at Oyster Creek. The new Oyster Creek One-Time Inspection aging management program will include the one-time inspection of Class 1 piping less than or equal to NPS 4. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.The September 2005 Revision 1 GALL program specifies the 2001 ASME Section Xi B&PV Code, including the 2002 and 2003 Addenda for Subsections IWB, IWC, and IWD. The current Oyster Creek ISI Program Plan for the fourth ten-year inspection interval effective from October 15, 2002 through October 14, 2012, approved per 10CFR50.55a, is based on the 1995 ASME Section Xl B&PV Code, including 1996 addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

While this exception has already been taken in the Oyster Creek LRA for the B.1.1 (XI.M1) ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD program, this is a new exception for Oyster Creek program B.1.24 based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

Doc ReV-0 01 22 06 n D Page 9 Sheet9of 11 The September 2005 Revision 1 GALL program states that the guidelines of EPRI Report 1000701,'Interim Thermal Fatigue Management Guideline (MRP-24),7 January 2001 should be used for identifying piping susceptible to potential effects of thermal fatigue. EPRI Report 1000701 recommends specific locations for assessment and/or inspection where cracking and leakage has been identified in nominally stagnant non-isolable piping attached to reactor coolant systems in domestic and similar foreign PWRs. As Oyster Creek is a BWR, these inspection guidelines are not applicable.

This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.Program B.1.31 (XI.S6) Structures Monitoring Program: There are no changes for structures; however, Oyster Creek credits the Structures Monitoring Program for managing the aging effects of external surfaces of mechanical components, which are covered by new GALL program X.M36, External Surfaces: The September 2005 Revision 1 GALL program XI.M36 states that monitoring of external surfaces of mechanical components is performed every refueling cycle. Oyster Creek performs this monitoring every 4 years. Technical basis for this exception Is provided in Attachment 2.2. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.The September 2005 Revision 1 GALL program specifies monitoring for leakage. The Oyster Creek program wHil be enhanced to require visual inspection of external surfaces of mechanical steel components that are not covered by other programs for leakage from or onto external surfaces, worn, flaking, or oxide-coated surfaces, corrosion stains on thermal insulation, and protective coating degradation (cracking and flaking).

This is a new enhancement based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.Program B.1.36 (Xi.E3) Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements:

The September 2005 Revision 1 GALL.defines medium voltage as 2kV -35kV. The previous versions of GALL did not define medium voltage. The Oyster Creek LRA submitted a B.1.36 program that included 2.4 and 4.16kV cables. This scope was expanded to include 13.8kV cables with the 10/12/05 RAI response for the Forked River Combustion Turbine. OC is planning to include both 13.8 and 34.5kV cables in Hs existing cable test program that currently only includes 2.4 and 4.16kV cables. This is a new enhancement based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL Program B.2.2 (plant-specific)

Lubricating Oil Monitoring Activities:

The September 2005 Revision 1 GALL added new aging management program XI.M39, Lubricating Oil Analysis, which will not be used at Oyster Creek. The Oyster Creek aging management program B.2.2. Lubricating Oil Monitoring Activities will incorporate the specifications of GALL program Xi.M39 with the following exception and enhancement:

The new program in September 2005 GALL specifies that flash point be measured for all lubricating oils. Oyster creek will sample and measure flash point for lubricating oil for diesel engines only.Justification for this is provided in Attachment 2.4. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.The Oyster Creek program will be enhanced to include sampling and measurement of flash point of diesel engine lubricating oil to detect contamination of lubricating oil by fuel oil. This is a new I ii-iekinx, -Ppi-nnnilintirtnnnr-Pav n 01 99 pri-ndf ,Pa~ge 1,0], UtL!7 ~ -'~p ~ _tnf~ P,. 0 0 9 f n -fPae_0 Sheet 10 of 1 1 enhancement based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.Program B.2.4 (plant-specific)

Periodic Inspection of Ventilation Systems: The September 2005 Revision 1 GALL added new aging management program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, which will not be used at the Oyster Creek station, but is used for the Forked River Combustion Turbine site. The Oyster Creek aging management program B.2.4, Pedlodic Inspection of Ventilation Systems incorporates the specifications of GALL program XI.M3EI, with the exception of inspection of coatings.

The Oyster Creek B.2.4 program does not take credit for coatings of internal surfaces, but directly inspects for loss of material.

The Oyster Creek program is enhanced to provide specific guidance to inspect for Loss of Material by inspecting for corrosion, rust, pitting or wear, and for Change in Material Properties by inspecting for cracking, perforations, or other damage. These enhancements were part of the Oyster Creek LRA submitted in July 2005, and are not due to reconciliation of this aging management program from the Januanr 2005 draft GALL to the approved September 2005 Revision 1 GALL.The following change to the Oyster Creek LRA aging management review was required due to reconciliation of changes to line items that did not require further evaluation in the January 2005 draft GALL, but do require further evaluation in the approved September 2005 Revision 1 GALL: EP-34 (V.D2-10, 3.2.1) -This line item for stainless steel heat exchanger tubes in treated water, addressing reduction of heat transfer due to fouling, invoked the Water Chemistry program with'No" further evaluation required in the January 2005 draft GALL and has been changed in the September 2005 Revision 1 GALL to Water Chemistry and One-Time Inspection, with 'Yes" for evaluation of aging effects. There are 2 instances of this line item being used in the Oyster Creek License Renewal Application, both in the Isolation Condenser system, for heat exchanger tubes, internal and external.

The Oyster Creek LRA will add two line items for one-time inspection of the Internal and extemal surfaces of the Isolation condenser-tube forreduction of heat transfer due to fouling. These are new additions based on the reconciliation of the Oyster Creek LRA between the January 2005 draft GALL and the approved September 2005 Revision 1 GALL.The following change to the Oyster Creek LRA aging management review was required due to reconciliation of changes to line items that were not administrative changes: T-14 (III.A5-13)

-Oyster creek will commit to perform monitoring of any leakage from the spent fuel pool liner via the pool leak chase piping.5.0 References

1. Draft NUREG-1800, 'Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, January 2005;2. NUREG-1 800, Revision 1, 'Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, September 2005 3. Draft NUREG-1801, 'Generic Aging Lessons Leamed (GALL) Reporr, January 2005 4. NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report, September 2005 5. NUREG-1832, "Analysis of Public Comments on the Revised License Renewal Guidance Documents", September 2005 If D. Ashley -Reconciliation Doc Rev 0 01 22-06.pdf 0Page 11~--- -Sheet 11 of 1 1 6. NUREG-1833, Technical Bases for Revision to the Ucense Renewal Guidance Documents", October 2005 7. Oyster Creek Generating Station Ucense Renewal Application, July 2005 6.0 Attachments Attachment 1: Table 1 -Oyster Creek License Renewal GALL Program Comparison

-January 2005 Draft to September 2005 Revision 1 Attachment 2: New Aging Management Programs in September 2005 Revision 1 GALL vs.Corresponding Programs Used in the Oyster Creek LRA Attachment 3: AMR Une Items used in the Oyster Creek LRA for which 'Further Evaluation' changed from 'No' to "Yes" in the September 2005 Ravision 1 GALL Attachment 4: AMR Une Items used in the Oyster Creek LRA which were Deleted from the September 2005 Revision I GALL Attachment 5: AMR Line Items used in the Oyster Creek LRA for which Changes in the September 2005 Revision 1 GALL were not solely Administrative Attachment 6: AMR Une Items used in the Cyster Creek LRA which invoke Plant-Specific Programs Requiring Further Evaluation in both the January 2005 Draft and September 2005 Revision 1 SRP

.Ashley- Reconciiatin Doc Rev 0 01 22 06.pdf Page 12 I D. Ashley -Reconciliation Doc Rev_0 01 22-06.pdf Page 131.-~ I -~ 1 1 "I --~ .. I 11- , ,I II -, I -I I I ~ I~ ~ I ---11,1, 1-1 .. --K- --1111" ----I " I".-1 ------I I -.1111,1--" --

Oyster Creek License Renewal CALL P. ogrm Compo-r!-

n. .Januar-9y-20105 IDraft1- to-P nu 2005 Rn V. 1 Attachment 1 0 LII 0 iCD~,0 0 0)a Comparison of the January Draft and September Revision 1 of NUREG- 801 revealed both editorial and technical revisions, and that 6 new programs were added.0o GALL AMP AMP Identification of Applicable Dfrenes Technical Assessment of Significance LRA Impacted Progra mt No. _ _ _8.1.1 Xl.M1 ASME Section 1. Editorial changes. 1. Editorial changes do not affectthe No XI Inservice
2. Clarification of the GALL position on technical assessment performed for Inspection, acceptable date of ASME Code used, Oyster Creek for this program.Subsections relative to 1OCFR50.55a has been 2. Although NUREG-1i801 specifies the 2001 IWB, WC, provided.

edition including the 2002 and 2003 and iWD Addenda of the ASME Section Xi Code, Subsections IWB, NC, and IWO for Inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified.

Oyster Creeks current ISI program plan for the fourth ten-year Inspection interval, approved per 10 CFM 50.55a, Is based on the 1995 edition month Inspection interval for Oyster Creek will Incorporate the requirements specified in the version of the ASME Code Incorporated Into 10 CFfl 50.55a twelve months before the start of the Inspection Interval.B.1;2 X.M2 Wtar 1. EditorIal changes. 1. EditorIal changes do not affect the No Chemistry

2. Clarifications have been provided on technical assessment performed for Industry document revisions.

Oyster Creek for this program.2. Clarifications provided on industry document revisions do not affect BWRs and, therefore, have no effect on the technical assessment performed for Oyster Creek for this program.8.1.3 Reacior Hfead 1. Editorial changes. i. 1Editorial changes do not affect the No Closure Studs 2. Clarification of the GALL position on technical assessment performed for acceptable date of ASME Code used. Oyster Creek for this program.relative to 1 oCFR50.55a has been 2. Although NUREG-I B01 specifies the 2001 provided.

edition Including the 2002 and 2003 Addenda of the ASME Section Xi Code, Subsections IW. IWC, and IWD for Inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it Is justified.

Oyster Creek s current ISI program plan for the fourth ten-year Page 1 of 17 Oyster Creek License Renewal CALL P--g*^- -a panwvu v s au V r Ii. XV r. I Attachment I 00 GALL AMP AMP Identification of Applicable Differencee Technical Assessment of Significance LRA impacted Progri m No.inspection interval, approved per 10 CFR 50.55a. is based on the 1995 edition including 1996 Addenda. The next 120-month inspection Interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.B.t.4 Xi.M4 BWR Vessel 1. Editorial changes. 1. Editorial changes do not affect the No ID Attachment

2. Clarification of the GALL position on technical assessment performed for Welds acceptable date of ASME Code used, Oyster Creek for this program.relative to 10CFR50.55a has been 2. Although NUREG-1 801 specifies the 2001 provided.

edition including the 2002 and 2003 3. Added the specification that relief Addenda of the ASME Section Xi Code, requests must be submitted and Subsections IWB, [WC, and MID for approved.

Inspection, repair, and replacement, It allows an applicant to rely on a different version of the ASME Code providing It is justified.

Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.5a, is based on the 1995 edition Including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will Incorporate the requirements specified in the version of the ASME Code Incorporated Into 10 CFR 50.5ia twelve months before the start of the inspection Interval.3. No Inspection relief has been requested bv Oyster Creek.________

I.1 .5 Xi.M5 BWR 1. Editorial changes. I .Editorial changes do not affect the No Feedwater 2 Clarification of the GAiL position on technical assessment performed for Nozzle acceptable date of ASME Code used, Oyster Creek for this program.relative to I OCFRS.55a has been 2. Although NUREG-180O1 specifies the 2001 provided.

edition including the 2002 and 2003 Addenda of the ASME Section Xi Code, Subsections IWB, IWC, and iWD for Inspection, repair, and replacement, It allows an applicant to rely on a different version of the ASME Code providing R Is justified.

Oyster Creek's current ISI program plan for the fourth ten-year Inspection interval, approved per 10 CFR SO.Sa, is based on the 1995 edition Including 1996 Addenda. The next 120-CD I0 I0 0.20 0)K0~Page 2 of 17 Oyster Creek License Renewal GALL PrS--m --mp-r!^n

-Jn- 200-.Attachment 1 (cn CD 0 0 2 .i~3 0~CD 0 0~N N, 0c~' 9 Cl-OC GALL AMP AMP IdentifikatIon of Applicable Differences Technical Assmement ot Significance LRA Impacted Progra mNo.month Inspecion interval far Oyster Creek will Incorporate the requirements specified In the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the Inspection Interval.B.1.6 Xi.M6 BWR Controi 1. Editorialchanges.

1. EditorIal changes do not effect the No Rod Drive 2. Clarification of the GALL position on technical assessment performed far Return Une acceptable date of ASME Code used, Oyster Creek for this program.Nozzle relative to IOCFR50.55a has been 2. Although NUREG-I 601 specifies the 2001 provided.

edition Including the 2002 and 2003 Addenda of the ASME Section Xi Code, Subsections IWB, IWC, and IWO far inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it Is justifled.

Oyster Creek's current ISI program plan for the fourth ten-year Inspection interval, approved per 10 CFR 50.55a, is based on the 1995 editIon including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified In the version of the ASME Code Icorporated Into 10 CFR 50.55a twelve months before the start of the Inspection interval.B.1.7 XI.M7 iWR Stress 1. Editorial changes. 1. Editorial changes do not affect the Yes. An Corrosion

2. The program description and scope of technical assessment performed for exception was Cracking the program was revised to include Oyster Creek for this program, taken in the LRA nickel based alloy components.
2. Nickel based alloy structures andlor to iWRVIP-29 3. The specific reference to BWRViP-29 for components have been identified in the for program reactor coolant water chemistry control Oyster Creek LRA for the Reactor 8.1.7. This was deleted. Pressure Vessel (RP-03, R-04, R-64, R- exception no 68, R-69), Reactor Internals (R-53. R-96). longer applies to and Emergency Service Water System B. 1,7.(AP-16, AP-53) license renewal systems.The addition of nickel based alloy components to the scope of the BWR Stress Corrosion Cracking program does not affect the programs selected for these components as identified In the Oyster Creek LRA. The only GALL item referenced above invoking the BWR Stress Corrosion Cracking program In the September 2005 version of GALL is R-63.Page 3 of 17 Oyster Creek License Renewal GALL Pr. rap. C^mp-ar'on

= ra,.. .-00 e--- 1 P W016F.% 'Mjuaimm AL~ji ntV.Attachment 1 00 GALL AMP AMP IdentificatIon of Applicable Differences Technical Assessment of Significance LRA Impacted Progre m No.GALL item R-68 included the reference to the BWR Stress Corrosion Cracking program In the Draft January 2005 version of GALL Therefore, this change to Xl.M7 has no effect on the Oyster Creek LRA.3. The specific reference to BWRVIP-29 was deleted from Xl.M7 but the reference to Water Chemistry program Xl.M2 which specifies BWRVIP-29, remained.B.1.8 Xa.M8 BWR 1. Editorial changes. 1. EditorIal changes do not affect the No Penetrations

2. Clarification of the GALL position on technical assessment performed for acceptable date of ASME Code used, Oyster Creek for this program.relative to 1OCFR50.56a has been 2. Although NUREG-I 801 specifies the 2001 provided.

edition including the 2002 and 2003 Addenda of the ASME Section )a Code, Subsections IWB. IWC, and IWO for inspection, repair, and replacement, It allows an applicant to rely on a different version of the ASME Code providing It is justified.

Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.55a, is based on the 1995 edition Including 1996 Addenda. The next 120-month Inspection interval for Oyster Creek witl incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the Inspection Interval.B.1.9 )XI.M9 BWR Vessel 1 .Added the specification that ior plants 1 .No new specifications.

OC has already No Internals that have not yet reached a fluence of reached the threshold and has committed SE+20 threshold for IASCC prior to to these inspection requirements in the POE, that the 5% & 10% inspection LRA.requirement is to begin once threshold Is Z Although NUREG-1801 specifies the 2001 reached. Additionally.

cdarification edition including the 2002 and 2003 added that the extent of the examination Addenda of the ASME Section Xi Code.and its frequency would be based on a Subsections iWB, IWC and IWO for ten percent sample of the total inspection, repair, and replacement, It population, which Includes at grid beam allows an applicant to rely on a different and beam-to-beam crevice slots. version of the ASME Code providing it is 2. Clarification of the GALL positIon on justified.

Oyster Creeks current ISI acceptable date of ASME Code usmed, program plan for the fourth ten-year relative to I0CFR50.55a has been inspectin interval, approved per 10 CFR provided.

50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-00'CD C, Y 0 ICD 0 03 0 0.Page 4 of 17 Oyster Creek License Renewal-ALL Pro^g"r-a.

Cmpadn -i.-u-marl 2005 Drft t^ S-p-.er* b r 0 Re:. 'Attachment 1 0o GALL AMP AMP Identification ot Applicable Dilterences Technical Assessment of Significance LRA Impactecd m No. _month Inspection interval for Oyster Creek will Incorporate the requirements specified in the version of the ASME Code incorporated Into 1(0 CFR 50.55a twelve months before the start of the inspection I I interval.N/A XI.M10 BorcsAcid Program not used at Oyster Creek. N/A No Corrosion

__ _ _ _ _ _ _ _ _ _ _ _ _ _ _N/A XI.M1 t Nidke-Alloy Program not used at Oyster Creek. N/A No Nozzles and Penetrations NtA XI.M1 IA Nickel-Alloy Program not used at Oyster Creek. N/A No Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors N/A Xi.M12 Thermai Aging Program not used at Oyster Creek. NWA No Emoritftlemrent Of cast Austenktic Stainless Steel (CASS)3.1.10 Xi.M13 Thermal Aging Editorial changes. Editorial changes do not aflect the technical No and Neutron assessment performed tor Oyster Creek for this Irradiation program.Embrittlement of Cast Austenitb Stainless__ _ _ _ Steal (CASSI__ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _N/A XI.M14 Loose Part Program not used at Oyster Creek. N/A No N/A Xi.M15 Neutron Noise Program not used at Oyster Creek. N/A No Monitornn NA Xi.M16 PWR Vessel Program not used at Oyster Creek. N/A No_ _ _ _ Internals

_ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _B.1.11 XJ.M17 Flw Editorial Changes. Editorial changes do not affect the technical No Accelerated assessment performed for Oyster Creek for this_ _ _ __ _ _ _ _ Corrosion I _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ pr g a ._ _ _ _ _ _ _B.1.12 Xi.M18 Boltn 1. Editorial Changes. 1. Editorial changes do not affect the No_ ______ 1 2. Element 1- added non-safety-relsted technical assessment performed for (DI CD)C)CD 0 0 D\0 0)0.Page 5 of 17 Oyster Creek License Renewal C -S 7 DAJ rE.IL _.. .. .. n -aIKII I OM i flv. I Attachment 1 OC GALL AMP AMP Identification of Applicable Differenee Technical Assessment of Significance LRA Impacted Prog" m o. No.boitig. O yster Creek for this program.a. Added descriptor to 2. No impact.structural bolting 3. No impact.b. Added pointer to Xa.M3 for 4. Already Included -No Impact.reactor head closure bolts. 5. Already included -No Impact c. Added reference to 1995 6. Already Included -No Impact.edition of ASME Code 7. No impact.Section Xt.3. Element 2 -deleted reference to Hot Torqulngf.

Added reference to EPRI documents for maintenance practices 4. Element 3 -Added additional mornitoring for safety related pressue retaining components such as leakage and toss of prestress a. Added os of material and crackingto high strength bolts.5. Element 4 -Removed reference to Section Xi 1995 edition through 1996 addenda and added rendorsed In 1OCFR50.55a(b)(2),.

a. Added reference to Category*D-B and C-ass 3.b. For high strength structural bolting added reference to stress corrosion cracking (SCC).6. Element 7 -Dropped reference to Repair.a. For NSSS component support 0ofting added replacement lAW EPRI NP-5789 7. Element 10- Added statement about downcomer teequencher bolting and reactor building closed cooling system boiting leakage.NtA Xl.M19 Steam Program not used at Oyster Creetc N/A No Generator B.1.13 X.M20 TuOe Intery Added elastomers tothe list of items The elastomers identified in the ESW and SW No Cooing Water periodically Inspected, monitored, or tested. systems that are exposed to Raw Water-Salt System Water are periodically Inspected as part of the_B___ X.M_ Periodic Inspection Program (. 2.5).8.1.14 X.tM21 e 1. Editorial changes. 1. Editorialchanges do not affctthe No.-,'D 0 0_.CD 0 0 ro O 0^0 Page 6 of 17-- ._. ... ,..__ ..,._...

Oyster Creek License Renewal 11- -7 6.-VV go as al V10 .0U 443Uiwi5.D ZUU~ f EV. I Attachment 1 OC GALL AMP AMP IdentflIcation of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.Cooling Water 2. Added SOC as an aging mechanism to technical assessment performed for System be managed by the Program. Oyster Creek for this program.3. In "Monitoring and Trending' added 2. Oyster Creek chemistry controt and heat'"ets to evaluate heat removal exchanger design precludes cracking.capability of the system and degradation

3. The COCW program performs Internal of system components may also be inspections and other tests to evaluate used' AND 'intemal Inspections to heat removal capability.

demonstrate system operability and 4. No technical inpact as a resuft of the confirm the effectiveness of the removal of the reference.

The exception program. taken i the LRA still applies to the 4. Deleted the specification to comply program.epecfically with T-i 07306.B. 1.15 Xi.M22 Boratlex Editorial changes. Editorial changes do not affect the technical No Monitoring assessment performed for Oyster Creek for this_______program.

B.1.16 Xi.M23 Inspection of 1. All specifications and references to (1-5) These changes appropriately eliminate Yes. The Overhead testing of active components were specllications for aging management of active exception to item Heavy Load removed L.e. deleted from Program components thereby restoring the passive, 2. regarding the and Light

Description:

"These cranes comply with long-lived criterion for components and number and Load (Related the Maintenance Rule requirements commodities within the scooe of this nrooram. maanitude of Sits to Reueing) provided in 10 CFR 50.65. The Nuclear An exception had been taken to Hem 2. in the by the crane is Handing Regulatory Commission Regulatory OC LRA; the number and magnitude of ifts by no longer Systems Guide (RG) 1.160 provides guidance for the crane are not tracked. Due to the GALL applicable.

monitoring the effectiveness of change, this exception Is no longer required.maintenance at nuclear power plants." 2. Deleted from Parameters Monitored/Inspected:

'The number and magnitude of lifts made by the crane are also reviewed.'

-3. Deleted from Detection of Aging Effect: "Functional teats are also performed to assure their Integrity." 4. Deleted from Acceptance Criteria:

'EOCI Specification

  1. 61 (or later revisions)," 5. Deleted from Operating Experience: "Because of the requirements for monitoring the effectiveness of maintenance at nuclear power plants_provided In 10 CFR 50.65" B.1.17 Xi.M24 Compressed Added an emphasis on stainless steel The Oyster Creek program precludes aging No Air Mornl!orkul components.

effects on at component materials.

B.1.18 Xi.M25 BWR Reactor I. Editorialchanges.

1.Edorialchanges do not affect the No Water 2. ClarIficaton of the GALL position on technical assessment performed for Cleanup acceptable date of ASME Code used, Oyster Creek for this program.System relative to I OCFR50.55a has been 2. Although NUREG-1 801 specifies the 2001 provided.

edition Including the 2002 and 2003__ _ ._ Addenda of the ASME Section Xl Code, 01 0 0 0~Page 7 of 17 Oyster Creek License Renewal fll D~sgvm a.i~s ~'*.s,'~lf~

lb~55, ..4,..ok.~.

M~~ ..CAL r-,amCm-0--n 07 *s*r O...rs2fl.

-as Attachment 1 DC GALL AMP AMP Identiflcation of Applicable Differences Technical Assessment of Significance LRA Impacted m No. __Subsections IWB, iWC, and NvD for Inspection, repair, and replacement, It allows an applicant to rely on a different version of the ASME Code providing it Is ustified.

Oyster CreeKs current ISI program plan for the fourth ten-year Inspection interval, approved per IO CFR 50.55a. is based on the 1995 edition including 1996 Addenda. The next 120-month Inspection Interval for Oyster Creek will Incorporate the requirements specified In the version of the ASME Code incorporated Into 10 CFR 50.56a twelve months before the start of the Inspection

____ ___ __ ____ ___ ___interval.

B.1.19 Xi.M26 Fire Protection

1. Editorialchanges 1 .Editorial changes donot affect the No 2. Added specification that visual technical assessment performed for Inspections be performed by fire Oyster Creek for this program.protection qualified inspectors'
2. No significant effect -OC uses qualified 3. Deleted specifications for VT-1/VT-3 or personnel for these inspections equivalent inspections
3. No significant effect.4. Deleted GALL Industry OE discussion
4. No effect on iRA.that said no corrosion-retated problems have been reported for the fuel supply line, pumrp casing of diesel fire pump, or halon C02 systems. and no aging-related problems found with fire protection systems, emergency breathing and auxiary equipment and_ _____communication equipment.

B.1.20 Xi.M27 Fire Water 1. Added specific reference to the edition 1. Change Is not technically significant.

No System of NFPA 25 used, as well as the specific 2. Change is not technically significant sections.

3. Change Is not technicalty significant.
2. Flow testing specifications are tess prescriptive.
3. Monitoring and trending Is now vas specified by the associated plant oommitrnents pertaining to NFPA codes and standards

.N/A Xti.f28 Buried Piping Program not used at Oyster Creek. N/A No and Tanks Surveilance 8.1.21 Xi.M29 Aboveground Editorial changes. Editorial changes do not affect the technicFal No Steel Tanks assessment performed for Oyster Creek for this B.1.22 Xl.U30 FuelO1i 1. NUiREG-180tstatesinXI.M30thatthe

1. Oster Creek has not adopted the Yes. This isa Fia CD I I0 0 2.O5'0 01 0 1 0 )0.Page 8 of 17 Oyster Creek License Renewal Q A L L P. W --. C I. .nuan I I.5.. OrlA -ftl11 Sc .Cm 4 C 55, Rfl Cv.~ 4 Attachment 1 OC GALL AMP AMP identification of Applicable Differencs Technical Assessment of Significance LRA impacted Progra m No. I Chemistry fuel oil aging management program is in Standard Technical Specifications as new exception part based on the fuel oil purity and described in these NUREG's, however, (item 1).testing requirements of the plants the Oyster Creek fuel oil specifications Technical Specifications that are based and procedures invoke similar on the Standard Technical requirements for fuel oil purity and fuel oil Specificatrins of NUREG-1430 through testing as described by the Standard NUREG-1433.

The January 2005 Draft Technical Specifications.

These inciude did not Invoke the Standard Technical testing requirements for new fuel oil (API Specfications.

gravity, kinematic viscosity, water and 2. A new standard is invoked for fuel oil, sediment) prior to adding the new fuel to ASTM D6217. as an acceptable the storage tank to ensure that the oil has alternative to ASTM D2276 for not been contaminated with substances particulate.

that would have an immediate detrimental impact on diesel engine combustion, and.testing of new fuel after adding i to the storage tank to confirm that the remaining fuel oil properties are within specification requirements.

Oyster Creek fuel oil activities also provide for the trending of particuiate contamination In new and stored fuel oil. Water and Sediment is drained periodically (quarterly) from the Emergency Diesel Generator Fuel Storage Tank. This periodiity exceeds the Standard Technical Specifications requirements of 'once every 131] days,.however, It is aligned with the requirements of Regulatory Guide 1.137 which states that a quarterly basis is sufficient unless accumulated condensation is suspected (in which case a monthly basis is appropriate).

2. Fuel oil will be routinely sampled and analyzed for particulate contamination in accordance with modified ASTM Standard D 227-00, Method A. The alternative methods of ASTM D 6217 will not be____ ____ ___ ____ ___ ____ ___ ____ ___ Used.B.1.23 Xt.M31 Reactor 1. Only untested capsules must be 1 Change is not technically significant.

No Vessel maintained for future use. 2. Change is not technically significant.

Surveltance

2. Deleted specification that changes to storage requirements must be approved__2_4 ____. -M32 _____ _ by the NRC. ______I Xi.M32 OeTime 1. Excludee Cass 1 piping less than or 1 .(a) NUREG-1 81 states in XL.M32 that Yes. These are Inspection equal to NPS 4 in favor of new M35 one-tirne Inspection of Class 1 piping less new exceptions Program, than or equal to NPS 4 is addressed in (item 1). See_ 2. Deleted specification that Inspection be Chapter XI.M35. One Time inspection of also document 0 i ,QD , Cr!0 0 CD 0 0) .r\3 A I0 0)0-a ,.1)e._I: I Page 9 of 17 Oyster Creek License Renewal CALL PI- -y-'- a _ a--' tn n ptir tflnl; Rev. t___. ._ .. ., ~~-*-.. --.--___ _r _-Attachment 1 OC GALL AMP AMP IdentIfication of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.in strict accordance with App B, Instead ASME Coe Class 1 Small Bore-Piping.

FReconcitiatbn of permitting qualifled' personnel to follow NUREGA- 801 aging management Program and'procedures consistent with It. program Xl.M35. One Time Inspection of Une Item 3. Now permits *equivalent VT ASME Code Class 1 Small Bore-Piping Differences Inspections.

will not be used at Oyster Creek. The new Between January 4. Added a clear specification that Oyster Creek One-Time inspection aging 2005 Draft Inspections occur no earlier than 10 management program will include the NUREG-1t801 years before the PEO. one-time Inspection of Class 1 piping less and September S. Deleted provision for remote visual than or equal to NPS 4. 2005 NUREG-inspections. (b) NUREG-1801 specifies (in Xl.M1, 1801 Revision 1-, 6. Included new guidelines for establishing XJ.M32, and XI.M35) the 2001 ASME Attachment 2.sample sizes, such as materiais of Section Xt S&PV Code, including the fabrication, envIromMent, plausible aging 2002 and 2003 Addenda for Subsections effects, and operating experience.

IWB, IWC, and IWD. The current Oyster Creek ISI Program Plan for the fourth ten-year inspection Interval effective from October 1i, 2002 through October 14.2012, approved per IOCFR50.Sfa, is based on the 199S ASME Section Xl B&PV Code, Including 1996 addenda.I ne next zbu-montn inspection interval ior Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CtR S0.55a twelve months before the start of the inspection interval.(c) NUREG-1801 states In Xt.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping, that the guidelines of EPRI Report 1000701, Interim Thermal Fatigue Management Guideline (MRP-24), January 2001 shouid be used for identifying piping susceptibte to potential effects of thermal fatigue. EPRI Report 1000701 recommends specific locations for assessment anrI/or inspection where cracking and leakage has been identified in nominally stagnant non-isolable piping attached to reactor coolant systems in domestic and simiar foreign PWRs. As Oyster Creek is a BWR, these Inspection guidelines are not applicable.(d) See aiso document "Reconciliation of Program and Une Item Differences Between January 2005 Draft NUREG-1801 and September 2005 NUREG-1i801

._ ...Revision 1. Attachment 2.Cn ,CD ,0 I0 2.~0 0 O.)CD I 0 0 0)-o 0-'Page 10 of 17 Oyster Creek License Renewal GALL PrIirom rn -tonl,'rr _lnraft ,t^ ortrnnir OiEX Rav 1 Attachment 1 CD,'-b 0::=o p, ID i I OC GALL AMP A11P Identification of Appli<abhe Differences Technical Assessment of Significance LRA Impacted Progra m No.2. This is less restrictive than the previous specification for inspection quality.3. One-Trne inspections ftor Oyster Creek will consist ot voivsnetric exam inations.4. Oyster Creek is already within 10 years of the PEO (2009).5. Remote visual inspections are not ptanned for One-Time inspections.

6. The One-Time Inspection Sample Basis Document addresses the following: (a) determination of the sample size based on an assessment of materials of fabricaticn, environment plausible aging effects, and operating experience: (b) Identification of the Inspection locations in the system or component based on the aging effect (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect tMr wnicn me component is examined:

and (d) evaluation of the need for followup examinations to monitor the progression of aging If age-reiated degradation is found that could Jeopardize an intended function before the end of the_ _________

.. __________period ol extended operation._

B.1.25 )U.M33 Selective

1. Editorial changes. 1. Editorial changes do not afIct the No Leaching of 2. Added visual inspections to discussion technical assessment performed tor Materiais of inspection techniques.

Oyster Creek for this program.2. No technical effeet Visual examinations were already included In other program________ ______________elem ents. _ _ _ _ _ _ _ _B.1.26 XIM34 Buriea Piping 1. Added that gray cast Iron should be (1-3) No technical effect. These differences No and Tanks managed under Chapter XI.M33. are already addressed In tihe LRA.Inspection Selective Leaching of Materisis." 2. New specification thaf opportunistic inspections be perfonrned In highly susceptible areas or those with a history of corrosion.

3. Verification will nowm be required that at least one focused or opportunistic inspection In historically or suspected to be susceptible areas was performed prior to the PEO but within the past 10 N/A Xl.M35 One-time Neworam. not appitcable to OC. See One-Time Inspection program B.1.24 Yes. See One-Page 11 of 17 Oyster Creek License Renewal GALL Program Comparison

-January 2005 Draft to September 2005 Rev. 1 Attachment 1 OC GALL AMP AMP Identification of Appicable Differences Technical Assessment of Significance LRA Impacted Progra m No.__ __Inspection of [Specifiations incorporated into One-Time (XI.M32).

Time Inspection ASME Code Inspection.]

program 5.1.24 Class 1 Small (XI.M32)._____ ore-Piping N/A XI.M36 External New Program. Program not used at Oyster See Structures Monitoring Program B.1.31 Yes. See Surfaces Creek. [Specifications Incorporated into (Xl.56). Structures Monitoring Structures Monitoring Program] Monitoring Program B.1.31_____ ____(XI.561.

N/A Xl .M37 Flux Thimble New Program. Program not used at Oyster N/A No Tube Creek.N/A XI.M38 Inspection of New Program. Program not used at Oyster See Periodic Inspection of Ventilation Systems Yes. See Internal Creek. [Specifications incorporated Into B.2.4. Periodic Surfaces in Periodic Inspection of Ventilation Systems] Inspection ot Miscellaneous Ventilation Piping and Systems 8.2.4.Ductiag Compcnenbs N/A Xi.M39 Lubricating Oil New Program. Program not used at Oyster See Lubricating Oi Monitoring Activities Yes. See Analysis Creek. [Specilications Incorporated into program B2.2. Lubricatig Oil Lutricating ui monitoring AcTiviTies program.j M Activities program 8.2.2.B.1.27 XL.St ASME Section No changes. N/A No Xi, Subsection iWE N/A Xi.S2 ASME Section Program not used at Oyster Creek. N/A No Xi. Subsection ivWL B.1.28 Xl.53 ASME Section No changes. N/A No X1, Subsection iWF B.1.29 Xi.S4 10 CFR 50 No changes. N/A No Part 50, Apndra J B.1.30 Xi.SS MasonryIWai No changes. N/A No B.1.31 XI.S6 Structures There are no changes for structures.

1 .Oyster Creek takes exception to the Yes Monitoring However, Oyster Creek credits the Structures frequency of every refueling cycle Program Monitoring Program for managing aging specified in XI.M36. Technical basis for effects of external surfaces of mechanical the exception is, components, whtch are covered by new a) The frequency of 4 years specified for GALL Program Xl.M36, Extemal Surfaces.

monitoring of exterior surfaces of 1 .Monitoring of external surfaces of mechanical components is consistent with mechanical components under the the frequency specified for exterior Oyster Creek Structures Monitoring surfaces of supporting structures.

The 4-0 i-.~ (.0I ,.'0 CO 0 1_.0 0 0 CD 1'iN N)I;: 9)Page 12of 17 Oyster Creek License Renewal-Ab I n_____ ---po. 10rf hISS. S5405 7 S t S%_ fl 05' RCm: V=r F ou us, Vl w wvswa Vl~S4V-VRp.-.y MUV -w-* -wal-_--- _V_-lw Attachment 1 OC GALL AMP AMP Identification of Applicable D ifferencee Technical Assessment of Significance LRA Impacted m No.Program Is every 4 years; whereas year frequency Is consistent with industry Xl.M36 is every refueling cycle. guidelines and has proven effective In 2. XI.M36 also specifies monitoring for detecting lass of material due to corrosion, leakage and the Structures Monitoring and change in material properties of does not. structural elastomer on exterior surfaces of structures.

Consequently this frequency will also be effective for detecting loss of material and change In material properties on exterior surfaces of mechanical components before an Intended function is impacted.b) Industry and pbant-specifc operating experience review has not identified any instances of significant loss of material or change in material properties of external surfaces of mechanical components subject to indoor air environment.

c) Mechanical components subject to outdoor air are constructed from stainless steel, aluminum, which are not susceptible ro acceterarea corrosron.

or caroon steet components protected by protective coatings such as gaivankzing.

or painting.Plant operating experience indicates that monitoring of exterior surfaces of components made of these materials and protective coatings on a frequency of 4 years provides reasonable assurance that loss of material will be detected before an intended function is affected.d) Studies by EPRt (

Reference:

TR-103840. fig. 4.1-1) provides corrosion rate curve for carbon steels. This curve was constructed from 5i individual tests representing at least five different steels and six different test locations and environments.

The curve shows 0.926 mils per year thickness loss during the first 1 1/2 years, decreasing to 0.21 mils per year after t5 l years. EPRI also conducted corrosion tests of ASTM A-36 structural steel at four nuclear plants located In Elma and Richiand, Washington; and Midland, Michigan.

The tests were conducted for up to 24 months.EPRI concluded that based on the test__ _results the corrosion rate is 0.5 mils per CD ,0 ko CD N3 0 0), 0-Page 13of 17 Oyster Creek License Renewal P--- VI ,v II W1,015pa.URmlO

-wal .uaiNy 00m LPN OiL Lu PWeJU1IIWi5i

£uuJ "Wv. I Attachment 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LilA tmpacted Progra mn N__year. H the corrosion rate is conservatively taken as 0.926 mils per year, then the loss of material projected for 4 years is ess than 4 mil. This ioss of material Is insignificant and will not impact the intended function of mechanical components.

2. The program will be enhanced to require visual inspection of extemal surfaces of mechanical steel components that are not covered by other programs for leakage from or onto extemal surfaces, wom, flaking, or oxide-coated surfaces.corrosion stains on thermal insulation, and protective coating degradation (cracking and faking).See also document 'Reconciliation of Program and Une item Diflerences Between January 2005 Draft NUREG-1 801 and September 2005 NUREG-180i Revision 1, Attachment 2.B.1.32 Xl.S7 Rt 1.127. No changes, N/A No Inspection of Water-Control Structures Associated with Nuclear Power Plants B.1.33 XJ.S8 Protective
1. Editorial changes- 1. Editorial changes do not affect the No Coating 2. Added 'or during the general visual technical assessment performed for Monitoring inspection' to element 4 to allow the Oyster Creek for this program.and thorough Inspections to be done during 2. Minor clarification.

it really makes no Maintenance the general visual Inspection as opposed difference whether the thorough Program to afterwards.

inspections are done during the general 3. ASTM D 51t63-05 has replaced GALL inspection or as a different activity after References to A$TM D 51 63-96. the general inspections.

3. No impact since the Oyster Creek response to 6L 98-04 is the program that Is used to satisfy the requirement for an acceptable coatings maintenance aging management program (AMP) for license renewar as Identified In the 'Program DescriptionW paragraph of NUREG-1801 Chapter Xl program XI.S8, Protective Coating Monitoring and Maintenance

_ _ _ ._ Program. The Oyster Creek commitments ,CD I0 j0 I0 N, I0 9), Page 14 of 17 Oyster Creek License Renewal f-lAIl fl..I.-. n--.-----

C- ---- --- -u WAhLb r-i lvIaiui %# 11padisoo

-,,nuu 2005 Draft to Septemb~er 2U05 R1ev. I Attachment 1 CD 0 0 0 0.GALL AMP AMP Idektoftin of Applicable Differences Technical Assessment of Signifcance LRA Impacted Progr m No. .from the GL 98-04 response do not include ASTM D 5183 so this change is not relevanL B.134 Xi.Et Eleal Editorial changes. Editorial changes do not afect the technical No Cables and assessment performed for Oyster Creek for this Connections program.not Suilect to 10 CF1 50.49 Envkeronental Qualfltlon

_R Fequirements B.1,35 XI.E2 Electi Editorial changes. Editorial changes do not affect the technical No Cabes and assessment performed for Oyster Creek for this Connections program, not Subject to 10 CFA 50.49 Envbronmental Ouaslifcatkon Ftequemnents used In Instrnuentatlo

__ _ _ _ _ n Circuits B.1.36 XI.E3 Inaccibl 1. Editorial changes. 1. Ediorial changes do not affect the Yes Meditt- 2. The previous versions of GALL did not technical assessment performed for Revsion required Voltage define medlim voltage. The September Oyster Creek for this program. to reflect the Cables not 2006 revision to GAtLl defines medium 2. OC is planning to Include both 13.8 and inclusion of 34.5 Subpjct to 10 voltage as 2kV -35hV. OC's LRA 34.5kV cables In Its eristing cable test kV cables.CFR 50.49 subenitted a B. 1.36 program that program, that curenity only Includes 2.4 Envronmenital included 2.4 and 4.16V cables. This and 4.16kVcables Quatflcation scope was epanded to Include 13.8kV Requirements cables with the 10G12/00 RAI response for the Forked River Combustion Turbilne.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _NtA Xi.E4 Metal Program not used at Oyster Creek N/A No Enclosed u N/A Xi.ES Fuse Holders Program not usedc at Oyster Creek N/A No N/A Xi.E Elcrka Program not used at Oyster Creek N/A No Cable Connections not Su*bct to 10 CFR 50.49 Envirnmental Qusification

_ FlRequirements B.2.2 WA Lubnr ting Oil Plant specific program that Incorporates the See document ^Reconciliation of Program and Yes. See Monitoring speciiations f GALL progra .Xi.M39 Line Item Differences Between January 2005 document Activities Lubrlcatinm Oil Analysis.

Draft NUREG-1 801 and September 2005 "Reconciliatlon Of Page 15 of 17 Oyster Creek License Renewal GALL Program Comparison

-January 2005 iraft to September 2w05 Rev. 1 Attachment 1 0 a GALL AMP AMAllP Idmntlicon of App1liab Differences Technkialm ent ot Slgnificance LRA Impacted Prognt m No. __ __NUREG-180t Revision 1". Attachment

2. Program and Une Item Differences Between January 2005 Draft NUFIEG-1 801 and September 2005 NUREG-1801 Revision V,_______ Attachment 2 B.2.4 N/A Peridc Plant specific program that incorporates the See document *Reconclliatlon of Program and No. See Inspection of specifIcatIons of GALL program Xl.M38 Line Item Differences Between January 2005 document Ventilation Inspection od Internal Surfaces In Draft NUREG-1 801 and September 2005 'Reconciliatlon of Systems Miscelanesous Ptlng and Durcing NUREG-1i801 Revision 1, Attachment
2. Program and Components.

Line Item Differences Between January 2005 Draft NUREG-1801 2005 NUREG-1801 Revision 1,____ ___ __ ____ ___ ___ ____ ___ ___ ___Attachm ent ?-B.3.1 X.Mt Metal Fatigue The specification that the rnhinum Ilst of high The change alows the use of alternative No of Reactor fatigue usage locations include those locations in lieu of those specified in Coolant locations In NUREGWC01-6M0 and any NUREGtCR4e280.

To adtress the effects of Pressure additional critical components in the plant the coolant environment on component fatigue BoWy was revised. GALL now specifies high lffe at Oyster Creek plant-speclflc calcutations fatigue usage locations to include the have been perofommed for the locations locations kdentified in NUREG/CR-620, as a identified in NUREGtCR4260 tor okder-vintage mainimur or proposed alternatives based on GE BWR plants. The six locations are: piant configuration.

1. Reactor Vessel (Lower Head to Shet TransItion)
2. Feedwater Nozzle 3. Recirculation System (SDC Return Line Tee), Isnluding the RPV recireulation inlet and outlet nozzles 4. Core Spray System (Nozzle and Safe End)5. Isolatin Condenser Return to Shutdown Cooling 6. Limiting Feedwater Line Location These locations are the same as those identified In NUREG1CR-280.

exerpt that the Isolation Condenser Return to Shutdown Cooling was analyzed Instead of the RCIC_ _ _ _ _. return to the feedwater system, since Oyster HDI CD I0 0~0~0 N 0)C)Page 16 of 17 Oyst* Creek License Renewal_A__ ..ornparhon

-4,... M wauary C2005 Draft to Sepiember 2005 Rev. I Attachment 1 OC ALL AMP AP Identifcation of Appicab le Dffences Technical A nt of Signeifince LRA Impacted Progro m No.Creek does not have a RCIC system. The resultant fatigue usage factoji from these environmental fatigue analyzes are less than acceptance tmts for the perod of extended operation; thefore, It was not necessary to analyze addItional locations in the RCPS.NIA X.Si Cocrete Program not used at Oyster Creek N/A No Contaihnent Tendon Prestreess

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _8.3.2 X.EI Envirnmental No dcangas. N/A No Quatlillcation (E0) ot Electrical Components IjD CD 0 0: 2S e v',,, 0 0 0 0 0 0);~0.)Page 17 of 17 F _ ,. -, -_ 1 -" -II., 1 I I u .Asnhey -Reconciliation uoc Kev_0 0122_06.pdf Pnrum -'1 Is Attachment 2 New Aging Management Programs in September 2005 Revision 1 GALL Vs.Corresponding Programs Used in the Oyster Creek LRA Attachment 2.1 Attachment 2.2 Attachment 2.3 Attachment 2.4 OC LRA Use of E3.1.24 XL.M32 One-Time Inspection program vs. XLIV.35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping program OC LRA Use of E3.1.31 XL.S6 Structures Monitoring Program vs. XL.M36 External Surfaces Monitoring program OC LRA Use of [3.2.04 Periodic Inspection of Ventilation Systems program vs. XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program OC LRA Use of [3.2.2 Lubricating Oil Monitoring Activities program vs. XI.M39 Lubricating Oil Analysis program D. Ashy- Reconciliation Doc Rev_0 01 22_06.pdf Page 32 1 Attachment 2.1 OC LRA Use of B.1.24 XL.M32 ONE-TIME INSPECTION Program vs. XI.M35 ONE-TIME INSPECTION OF ASME CODE CLASS 1 SMALL-BORE PIPING P ROGRAM Proaram

Description:

The NUREG-1801, Revision 1 aging management program XI.M35, One-Time Inspection of ASME Code Class 1 Small Bore-Piping will not be used at Oyster Creek. The Oyster Creek XL.M32 One-Time Inspection aging management program B.1.24 will use volumetric examinations to provide additional assurance that aging that has not yet manifested itself is not occurring, or that the evidence of aging shows that the aging is so insignificant that an aging management program is not warranted for Class 1 piping less than or equal to NPS 4 (which does not receive volumetric examination during inservice inspection).

Summary of Exceptions to NUREG-1801:

The Oyster Creek One-Time Inspection aging management program B.1.24 will include the one-time inspection of Class 1 piping less than or equal to NPS 4.NUREG-1801 references in XI.M35 the 2001 ASME Section Xl B&PV Code, including the 2002 and 2003 Addenda for Subsections IWB, IWC, and IWD. The current Oyster Creek ISI Program Plan for the fourth ten-year inspection interval effective from October 15, 2002 through October 14, 2012, approved per 1 OCFR50.55a, is based on the 1995 ASME Section XI B&PV Code, including 1996 addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated Into 10 CFR 50.55a twelve months before the start of the inspection interval.NUREG-1 801 states in XL.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping, that the guidelines of EPRI Report 1000701, "Interim Thermal Fatigue Management Guideline (MR '-24)," January 2001 should be used for identifying piping susceptible to potential effects of thermal fatigue. EPRI Report 1000701 recommends specific locatfins for assessment and/or inspection where cracking and leakage has been identified in nominally stagnant non-isolable piping attached to reactor coolant systems in domestic and similar foreign PWRs.As Oyster Creek is a BWR, these inspection guidelines are not applicable.

1. Scope of Prooram: The Oyster Creek One-Time Inspection aging management program will confirm that cracking initiation and growth dug to stress corrosion cracking (SCC), intergranular stress corrosion cracking (IGSCC), or thermal and mechanical loading is not occurring in Class 1 piping less than four-inch NPS, and includes measures to verify that unacceptable degradation is not occurring, thereby validating the effectiveness of existing aging management programs or confirming that there is no need to manage aging-related degradation for the period of extended operation.

Page 1 of 4

-D. Ashley -Reconciliation boc, Rev 0 01 22 06.pdf Page 33__ --1 I -11,11, -I ---__ --III ----"- '- --7-:7,7"I Attachment 2.1 Systems in the scope of the One-Time Inspection program for ASME Code Class 1 Small-Bore Piping Include: Class 1 Piping Less than 4 inch in diameter NPS* Control Rod Drive System* Core Spray System* Feedwater System* Isolation Condenser System* Main Steam System* Nuclear Boiler Instrumentation

  • Post-Accident Sampling System* Reactor Head Cooling System* Reactor Recirculation System* Reactor Water Cleanup System* Shutdown Cooling System* Standby Liquid Control System (Uquid Poison System)Crack Initiation and Growth I Result: This element of the Oyster Creek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping, wiMM the exceptions identified above.2. Preventive Actions: The Oyster Creek One-Time Inspection aging management program is an inspection program to provide assurance that aging that has not yet manifested itself is not occurring, or that the evidence of aging shows that the aging is so insignificant that an aging management program is not warranted for Class 1 piping less than or equal to NPS 4.Result: This element of the Oyster C'reek Xl.M32 One-Time Inspection aging management program is consistent vvith recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping, with the exceptions identified above.Page 2 of 4 I -, , ....I I I I II -Y II -II Z I I l I D. As'hlev -Reco'nciliatiDn Doc Rev 0 01 22_06.pdf P~age' 34 ], D. .Ashl -__econci-atkn Doc RO 0 6.,.d , f a, , ,G 3 Attachment 2.1 3. Parameters Monitored/Inspected:

To confirm crack initiation and growth is not occurring in Class 1 piping with a diameter less than or equal to NPS 4, the One-Time Inspection program will utilize volumetric examination to inspect areas susceptible to stress corrosion cracking, intergranular stress corrosion cracking, or thermal and mechanical loading.Result: This element of the Oyster ('reek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management progiam, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping, with the exceptions identified above.4. Detection of Aging Effects: To confirm crack initiation and growth is not occurring in Class 1 piping with a diameter less than or equal to NPS 4, the One-Time Inspection program will inspect areas susceptible to stress corrosion cracking, intergranular stress corrosion cracking, or thermal and mechanical loading.Result: This element of the Oyster C'reek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XL.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping, wih the exceptions identified above.5. Monitoring and Trending: The One-Time Inspection aging management program provides for the evaluation of the need for follow-up examinations and increased inspection sample size to monitor the progression of aging if age-related degradation is found that could jeopardize an Intended function before the end of the period of extended operation.

The determination of the sample size of ASME Code Class 1 small-bore piping will be based on susceptibility, inspectability, dose considerations, and operating experience.

Should aging effects be detected, the corrective action program triggers actions to characterize the nature and extent of the aging effect and determines what subsequent monitoring is needed to ensure intended functions are maintained during the period of extended operation.

Result: This element of the Oyster CreekXI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-180I Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping, witM the exceptions identified above.6. Acceotance Criteria: For Class 1 piping, the Oyster Creek program directs evaluation of examination results in accordance with the 1995 ASME Section Xl Code, 1996 addenda.Examination results are evaluated in accordance with IWB-3131 by comparing the results with the acceptance standards of IWB-3400.

Additional examinations are performed in accordance with IWB-2430.Page 3 of 4 D.Ashley -Reconciliation Doc RevO0 01_2 06.Ddf PnPanre QF I 11 I I I I I "I I I I 11 y _1 11- -1""' " _ --, I -I -1. I .--I Attachment

2.1 Result

This element of the Oyster Creek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG- 1801 Revision I aging managementprogram, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping, wits the exceptions identified above.7. Corrective Actions: Evaluations will be performed for inspection results that do not satisfy established criteria and a Issue Report (IR) will be initiated to document the concern in accordance with the Oyster Creek 1(1 CFR Part 50, Appendix B corrective action program. The 10 CFR Part 50, Appendix B corrective action program ensures that the conditions adverse to quality are promptly corrected.

If the deficiency is assessed to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude repetition.

Result: This element of the Oyster Creek Xl.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XL.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping.8. Confirmation Process: See Item 7 above.Result: This element of the Oyster C'reek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG- 1801 Revision l aging management program, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping.9. Administrative Controls: See item 7 above.Result: This element of the Oyster Creek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XL.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping.10. Operatina Experience:

For objective evidence of the effectiveness of the ASME Section Xl program (e.g., scope of the inspections and inspection techniques), see Program Basis Document PBD-AMP-B.1.01, "ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD." Result: This element of the Oyster Creek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XIM35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping.Page 4 of 4 I 0. Ashley- Reconciliation DOC Rev_0 0L2206.pdf Page 36 1 X D Ashley -ReconciliatioDn Doc Rev_0 01 _22-06.pdf Page 361 Attachment 2.2 OC LRA Use of B.1.31 XI.S6 STRUCTURES MONITORING Program vs.XL.M36 EXTERNAL SURFACES MONITORING Program Program

Description:

The NUREG-1801, Revision 1 aging management program XI.M36, External Surfaces Monitoring will not be used at Oyster Creek. The Oyster Creek Xl.S6 Structures Monitoring aging management program B.1.31 will be enhanced to include the specifications of NUREG-1801 Rev. 1 XI.M36, Exterior Surfaces Monitoring.

The specifications of this new AMP apply to exterior surfaces of mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site that have been determined to be in scope of license renewal and are not covered by other programs.Exception to NUREG-1801:

The program takes exception to the frequency specified in NUREG-1 801 Rev. 1 XI.M36, External Surfaces Monitoring, for monitoring external surfaces of Oyster Creek and FRCT mechanical components.

The frequency specified by Oyster Creek Structures Monitoring Program is every 4 years; whereas the frequency specified in XI.M36 is at least once per refueling cycle. Technical basis for this exception is that, based on plant specific operating experience and industry experience, the 4-year frequency is adequate to provide reasonable assurance that aging effects will be detected and corrected before a loss of an intended function.

See the discussion of this technical basis in Section 4, Detection of Aging Effects.The Oyster Creek Structures .Monitoring Program implementing procedure will be enhanced to incorporate the specifications of the NUREG-1801 Rev. 1 XI.M36, Exterior Surfaces Monitoring program as follows: The program will be enhanced to require visual inspection of external surfaces of mechanical steel components that an) not covered by other programs for leakage from or onto external surfaces; worn, flaking, or oxide-coated surfaces; corrosion stains on thermal insulation, and protective coating degradation (cracking and flaking).

These enhanced requirements are applicable to mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site.1. Scooe of Proaram: In order to include the specifications of the XI.M36 External Surfaces Monitoring program, the scope of the OC Structures Monitoring Program will be enhanced to include inspection of exterior surfaces of mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site that are not covered by other programs, including exterior surfaces of HVAC ducts, damper housings and duct closure bolting within the scope of license renewal. Components that will be added to scope of the program include piping components, valves, tanks, vessels, etc. located in indoor or outdoor air environments.

The scope of the Page 1 of 5

[E shley -Reconciliation Doc Rev_0 01_2216.pdf P 37 Attachment 2.2 program is limited to components whose exterior surfaces are not monitored by other programs such as ASME Section Xl, ISI Programs and fire protection activities.

Result: This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, Xl. M36 External Surfaces Monitoring, with the exception and enhancement identified above.2. Preventive Actions: The program specifies no preventive actions. The program is a condition monitoring program that utilizes inspections to Identify aging effects prior to loss of intended function.Result: This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring, with the exception and enhancement identified above.3. Parameters Monitored/Inspected:

The enhanced Oyster Creek Structures Monitoring Program contains sufficient detail on parameters monitored or inspected to conclude with reasonable assurance that the XL.M36 External Surfaces Monitoring Program attributes are satisfied.

The program will be enhanced to require visual inspection of external surfaces of mechanical components lthat are not covered by other programs for leakage from or onto external surfaces; worn, flaking, or oxide-coated surfaces;corrosion stains on thermal insulation; and protective coating degradation (cracking and flaking).

These enhanced requirements are applicable to mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site.Result: This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XL.M36 External Surfaces Monitoring, with the exception and enhancement identified above.4. Detection of Aging Effects: The OC Structures Monitoring Program requires monitoring of each structure/aging effects by qualified Individuals every 4 years to ensure age related degradations would be detected and quantified before there is a loss of intended function.Result: This element of the Oyster Creek Xl.S6 Structures Monitoring Program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring, with the exception and enhancement identified above.Page 2 of 5

.Ashley -Reconciliation Doc Rev 0 01 22__ 6.pdf Paqe 38--, '. --"- --, , -, , , " _ _ _ , ...... -,, -----, -----, -, ,- I- ----Attachment 2.2 Inspection methods, inspection schedule, and inspector qualification are consistent with industry guidelines and NRC guidance for implementing the requirements of 10 CFR 50.65, the Maintenance Rule. Inspection methods consist of visual inspections conducted on a frequency of every 4 years in accessible areas of the plant. 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. Inaccessible areas, such as buried structures are inspected when they become uncovered.

External surfaces of Oyster Creek and FRCT mechanical components, including HVAC ducts, damper housings, and bolting will be inspected on a frequency of every 4 years consistent with inspection frequency for structures.

This constitutes an exception to NUREG-1801 Rev. 1 AMP XI.M36, External surfaces Monitoring, which specifies these inspections be performed at least once per refueling outage. Technical basis for this exception is as follows:* The frequency of 4 years specified for monitoring of exterior surfaces of mechanical components is consistent with the frequency specified for exterior surfaces of supporting structures.

The 4-year frequency is consistent with industry guidelines and has proven effective in detecting loss of material due to corrosion, and change in material properties of structural elastomer on exterior surfaces of structures.

Consequently this frequency will also be effective for detecting loss of material and change in material properties on exterior surfaces of mechanical components before an intended function is impacted.* Industry and plant-specific operating experience review has not identified any Instances of significant loss of material or change in material properties of external surfaces.;

of mechanical components subject to indoor air environment (see section 10 below).* Mechanical components subject to outdoor air are constructed from stainless steel and aluminum, which are not susceptible to accelerated corrosion, or carbon steel components protected by protective coatings such as galvanizing or painting.

Plant operating experience indicates that monitoring of exterior surfaces of components made of these materials and protective coatings on a frequency of 4 years provides reasonable assurance that loss of material will be detected before an intended function is affected.Studies by EPRI provide corrosion rate curve for carbon steels. This curve was constructed from 55 individual tests representing at least five different steels and six different test locations and environments.

The curve shows 0.926 mils per year thickness loss during the first 1 1/2 years, decreasing to 0.21 mils per year after 15 Y2 years. EPRI also conducted corrosion tests of ASTM A-36 structural steel at four nuclear plants located in Elma and Richland, Washington; and Midland, Michigan.

The tests were conducted for up to 24 months. EPRI concluded that based on the Page 3 of 5 D. Ashley -Reconciliation Doc Rev 0 01_22_06.pdf Page 39 l 1', D. --ReconciliatiDn Doc Rey-O 01.22-q6.pqt

--- -I"--, -11"' -I 1- I- I , 111,1111

--, , ,, --- -DI --" -""" -11 I , X I I r I I I , " Attachment 2.2 test results the corrosion rate is 0.5 mils per year. If the corrosion rate is conservatively taken as 0.926. mils per year, then the loss of material projected for 4 years is less than 4 mils. This loss of material is insignificant and will not impact the intended function of mechanical components.

Result: This element of the Oyster Creek Xl.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision I aging management program, Xi.M36 External Surfaces Monitoring, with the exception and enhancement identified above.5. Monitoring and Trending: Inspection methods, Inspection schedule, and inspector qualification are consistent with industry guidelines and NRC guidance for implementing the requirements of 10 CFR 50.65, the Maintenance Rule. Inspection methods consist of visual inspections conducted on a frequency of every 4 years in accessible areas of the plant. The program contains provisions for increased inspection frequency and trending of structures and components, consistent with 1 OCFRSO.65 (a)(1), if the degradation is such that the structure or component may not meet its design basis, or, if allowed to continue uncorrected until the next normally scheduled assessment:, may not meet its design basis.Result: This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring, with the exception and enhancement identified above.6. Accetance Criteria: The enhanced Oyster Creek Structures Monitoring Program requires that identified degradations be assessed and evaluated by qualified engineering personnel, considering the extent of the degradation using design basis codes and standards that include ASME/ANSI.

The program implementing procedure provides sufficient details on acceptance criteria for structures and exterior surfaces of mechanical components lo ensure that significant degradations are identified and corrected before a loss of an intended function.Result: This element of the Oyster CreekXI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring, with the exception and enhancement identified above.7. Corrective Actions: Evaluations are performed for inspection results that do not satisfy established criteria and an Issue Report (IR) is initiated to document the concern in accordance with 10 CFR 50, AppendiX B, Corrective Action Program. The corrective action process ensures that the conditions adverse to quality are promptly corrected.

If the deficiency is assessed to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude repetition.

Page 4 of 5 D. Ashley -Reconciliation Doc Rev 0 01 2206.pdf Page 40 Attachment

2.2 Result

This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring.

8. Confirmation Process: See Item 7, above.Result: This element of the Oyster Creek XL.S6 Structures Monitoring Program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring.
9. Administrative Controls: See Item 7, above.Result: This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring.
10. Operating Experience:

Searches of Oyster Creek corrective action process (CAP) database identified 217 instances of corrosion cases on exterior surfaces of mechanical components and structures.

For 216 cases, engineering evaluation concluded that the observed corrosion is limited to surface rust and does not impact the intended function of the component or structure.

For the remaining one case, a unistrut support member for,3/8 "diameter tubing, corrosion was more extensive but the unistrut was evaluated and determined capable of performing its intended function.

These examples provide objective evidence that deficiencies are entered into the corrective action process and that engineering evaluations are performed to determine what if any corrective actions need to be taken prior to loss of intended function.The operating experience of the Oysler Creek Structures Monitoring Program did not show any adverse trend In performance.

Problems identified would not cause significant impact to the safe operation of the plant, and adequate corrective actions were taken to prevent recurrence.

There is sufficient confidence that the implementation of the Structures Monitoring Program as described in the implementing procedures will effectively manage aging effects through the period of extended operation.

Result: This element of the Oyster Creek XI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M36 External Surfaces Monitoring.

Page 5 of 5 1, -

Reconciliation Doc Rev 0 01 0 Al RPage41 I--- = X ---, --- I I- --I'll, I'll, I 11 11 I I ---7, -1, -.1- 1 ... ..... .... .- -I I I --11 I --Attachment 2.3 OC LRA Use of B.2.04 PERIODIC INSPECTION OF VENTILATION SYSTEMS Program vs. XI.M38 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS Program Program Descriotion:

The NUREG-1801, Revision 1 aging management program XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components will not be used at the Oyster Creek station, but is used for the Forked River Combustion Turbine site, see note below. The Oyster Creek Periodic Inspection of Ventilation Systems aging managem nt program B.2.04, enhanced to include specific guidance for inspection for loss of material by corrosion, rust, pitting or wear, and for change in material properties by inspecting for cracking, perforations or other damage, will be used to satisfy the specifications of the NUREG-1801 Rev. 1 XL.M38 program. The specifications of this new AMP apply to internal (and external) surfaces of the Oyster Creek Generating Station piping and ducting components that have been determined to be in scope of license renewal and that are not covered by other programs.Note: The portion of the Oyster Creek License Renewal Application applicable to the Forked River Combustion Turbine (FRCT) was developed in accordance with the September 2005 Revision 1 NUREG-1801 XL.M38 program, and this reconciliation does not apply to that portion of the LRA.The Oyster Creek Periodic Inspection of Ventilation Systems aging management program preventive maintenance procedures is enhanced to provide specific guidance to inspect for the following aging effects: Loss of Material by inspecting forcorrosion, rust, pitting or wear, and;Change in Material Properties by inspecting for cracking, perforations, or other damage.These enhancements were part of the Oyster Creek LRA submitted in July 2005, and are not due to reconciliation to the September 2005 Revision 1 NUREG-1801.An exception due to reconciliation with September 2005 Revision 1 NUREG-1801 is inspection of coatings -the Cyster Creek Periodic Inspection of Ventilation Systems aging management program B.2.04 does not take credit for coatings for internal surfaces, but directly inspects for loss of material.1. Scope of Program: September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, addresses visual inspections to include internal surfaces of steel piping, piping elements, ducting, and components in an internal environment (such as indoor uncontrolled air, condensation, and steam) that are not included in other aging management programs for loss of material.

The Inspections are to be performed when the internal surfaces are accessible during the performance of periodic surveillances, during maintenance activities or during scheduled outages. These specifications are satisfied by the OC Periodic Inspection of Ventilation Systems aging Page 1 of 7

-, , , I I -I ID. Ashley -Reconciliation Doc Rev-0 01-22 06.pdf a -1 Pa a 42 F61-shlI I eco cilitio Doc ------- .. -~ ~ -- I, -,,," ~X 1 '111 Re O- 2 06 pd PI 42 ---: Attachment 2.3 management program, which manages the aging effects of loss of material, reduction of heat transfer, and change in material properties through visual inspections of ventilation systems in the scope of license renewal. The scope of existing inspections includes flexible connections, fan and filter housings, and access door seals. The program is enhanced to include ducts exposed to soil, instrument piping and valves, restricting orifices and flow elements, and thermowells.

Inspections of carbon steel fan and filter housings are considered representative of the internal surfaces of the carbon steel damper housings in the system. If aging degradation is identified on the fan or filter housing internal carbon steel surfaces, the condition will be evaluated to determine if the carbon steel damper housings will require internal inspection.

Result. This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-18i1 Revision 1 aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

2. Preventive Actions: The OC Periodic Inspection of Ventilation Systems aging management program specifies no preventive actions. The program is a condition monitoring program that utilizes visual inspections to identify aging effects prior to loss of intended function.Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
3. Parameters Monitored/inspected:

September 2005 Revision 1 NUREG- 1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, addresses visual inspections of internal surfaces of plant components to be performed during maintenance or surveillance activities.

Parameters monitored or inspected include visible evidence of corrosion to indicate possible loss of materials.

These specifications are satisfied by the OC Periodic Inspection of Ventilation Systems aging management program, which provides for visual inspections of the ventilation system ductwork and components to determine if penetrating corrosion indicating a los5 of material aging degradation is occurring.

Heat transfer surfaces are also inspe.,ted for fouling. Flexible connections are inspected to ensure they are free of cracking, damage and loss of material.

Door seals are inspected for cracking or damage when the associated access door is opened, or are inspected for leakage when the door in closed and the system is in service. The flexible connections and door seals are evaluated if cracking, damage or leakage is identified.

For the Standby Gas Treatment, Reactor Building Ventilation and Control Room Ventilation Systems, the results of the Page 2 of 7

0. Ashley.- Reconciliation Doc Rev_0 01_22 06.pdf aD 4 Attachment 2.3 inspections are verified by the performance of system leakage tests and filter efficiency tests.These inspections and tests manage the aging effects that could impact system and component pressure boundary integrity, providing reasonable assurance that ventilation system intended functions will be maintained consistent with the current licensing basis, for the period of extended operation Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
4. Detection of Aoina Effects: September 2005 Revision 1 NUREG -1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, addresses periodic inspections to provide for detection of aging effects prior to the loss of component function.

For painted or coated surfaces, degradation of steel surfaces cannot occur without the degradation of the paint or coating.Confirmation of the integrity of the paint or coating is an effective method for managing the effects of corrosion on the steel surface. Inspection intervals are established such that they provide timely detection of degradation.

The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications as follows: Ventilation system components are s abject to the following aging effects: Loss of Material Change in Material Properties (Elastomer materials)

  • Reduction of Heat Transfer The preventive maintenance procedures will be enhanced to provide the following specific guidance to inspect for aging effects:* Loss of Material:

Inspect for corrosion, rust, pitting or wear* Change in Material Properties:

inspect for cracking, perforations or other damage Aging effects are detected by periodic visual inspections and system tests.These Inspections and tests are performed on a frequency not to exceed five years, to detect aging prior to loss of system function.

The visual inspections are performed by qualified and experienced maintenance personnel.

An exception due to reconciliation with September 2005 Revision 1 NUREG-1801 is inspection of coatings -the Oyster Creek Periodic Inspection of Ventilation Systems aging management program B.2.04 does not take credit for coatings for internal surfaces, but directly inspects for loss of material.Page 3 of 7 III,.Ashley -Reconciliatic)n Doc Rey_0 01 22 06.r)df e TZ, ......Z, ..... .... , I Page 441 D.Ashley -Reconciliation Doc Rev_0 012206.pdf Page 44 Attachment

2.3 Result

This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-180 1 Revision 1 aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

An exception associated with reconciliation to the September2005 Revision I NUREG- 1801 document concerns inspection of coatings, the Oyster Creek Periodic Inspection of Ventilat'on Systems aging management program B.2.04 does not take credit for coatings for internal surfaces, but directly inspects for loss of material.5. Monitoring and Trending: September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components directs that visual inspection activities are perfonned and associated personnel are qualified in accordance with site controlled procedures and processes.

Maintenance and surveillance activities provide for monitoring and trending of aging degradation.

Inspection intervals are dependent on component material and environment, and take into consideration industry and plant-specific operating experience.

Results of the periodic inspections are monitored for indications of various corrosion mechanisms and fouling. The extent and schedule of inspections and testing assure detection of component degradation prior to loss of intended functions.

The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by addressing periodic visual examinations which are used to provide assurance that penetrating corrosion of ventilation system duct and components are not occurring or are occurring at an acceptable rate.The condition of the elastomers used in ventilation systems are monitored and the results of the inspections are revi awed to assure intended functions are maintained.

Flexible connections and access door seals are repaired or replaced if damage or deterioration is detected Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging managementprogram is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

6. Acceptance Criteria: September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components directs that indications of various corrosion mechanisms or fouling that would impact component intended function are reported and require further evaluation.

The acceptance criteria are to be established in the maintenance and surveillance procedures or other established plant procedures.

If the results are not acceptable, the corrective action program is implemented to assess the material condition and determine whether the component intended function is affected.The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by inspecting ventilation duct and components for signs of loss of material.

Elastomers are inspected for cracking, damage and Page 4 of 7 g I 1 1 .. e < ic== s D. Ashley -Reconciliation Doc Rev_0 01_22_06.pdf D. Ashley = Reconciliation Doc Rev_0 012206IpIf Page 451...; ...E i I = = .= ._ = c -.. .. = = -== -.-.--- =i=- -. X -.-i ..A. ............

, ..- ._ ..Attachment 2.3 loss of material.

Elastomers are repaired or replaced if a degraded condition is found. Heat transfer surfaces are inspected for corrosion and fouling. Identified aging effects are evaluated by engineering to determine a) if penetrating corrosion indicating a loss of material aging is occurring, and if so, b) the rate at which the material is being lost. Engineering evaluations will also c) determine the need for follow-up examinations

o monitor the progression of aging degradation, and d) identify appropriate corrective actions to mitigate any excessive rates of degradation discovered.

Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XL.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

7. Corrective Actions: September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components specifies that the site corrective actions program, duality assurance (QA) procedures, site review and approval process, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions, confirmation process, and administrative controls.

The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by requiring that evaluations are performed for inspection results that identify penetrating corrosion or elastomer degradation, or test results that do not satisfy established criteria, and an issue report is initiated to document the concern in accordance with plant administrative procedures and the requirements of 10 CFR Part 50, Appendix B. The corrective actions program ensures that the conditions adverse to quality are promptly corrected.

If the deficiency is assessed to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude recurrence.

Result: This element of the enhanced Oyster Creek 8.2.4 Periodic Inspection of Ventilation Systems aging managem 9nt program is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, Xl.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

8. Confirmation Process: See Item 7, above.Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging managementprogram is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XL.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

Page 5 of 7 D. Ashley -Reconciliation Doc RevO 01 22-06.pdf Pa 'a"e 46 1 I P-Ishle. -R--on--lat-on ,bo Rev_0 0___ 20_ .pdf Paae 46-- .....___ __ _ ,_1 I~-11__ -~I- _ -1111-1 Attachment 2.3 9. Administrative Controls: See Item 7, above.Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

10. Oeratina Experience:

September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components states that inspection of internal surfaces during the performance of periodic surveillances and maintenance activities have been in effect at many utilities in support of plant components reliability programs.

These activities have proven effective in maintaining the material condition of plant systems, structures, and components.

The applicant is to evaluate recent operating experience and provide objective evidence to support the conclusion that the effects of aging are adequately managed.The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by demonstrating that the effects of aging are effectively managed is achieved through presentation of objective evidence that shows that loss of material, change in material properties and reduction of heat transfer is being adequately managed in Ventilation Systems. The following examples of operating-experience provide objective evidence that the OC Periodic Inspection of Ventilation Systems program is effective in assuring that intended function(s) will be maintained consistent with the CLB for the period of extended operation:

1. Oyster Creek has experienced surface corrosion of outdoor equipment housings and duct, and damage to elastomers and deterioration of flexible connections that resulted in leakage of ventilation systems. These conditions were identified and corrected prior to loss of function of the systems.Maintenance procedures were revised to include steps to inspect for corrosion of outdoor equipment housings.

Periodic preventive maintenance inspections of ventilation system components, including specific guidance to identify applicable aging effects, will effectively monitor the condition of system components such that degradation will continue to be identified prior to loss of intended functions.(fan housing -CAPs 02001-0162, 0 l998-0737; elastomers

-CAP 02003-1281)

2. A buried section of Standby Gas Treatment system duct failed due to external corrosion of the aluminum duct exposed to a soil environment.

The failure occurred after approximately thirty years in service. The failed section was repaired with a sleeve. Periodic inspections of the buried duct section will be performed. (SE-000822-023, CAP 0.2005-2288)

Page 6 of 7 D. Ashley -Reconciliation Doc Rev_0 01_22 06.pdf Page,47 1 Attachment 2.3 The operating experience of the Periodic Inspection of Ventilation Systems program did not show any adverse trend in performance.

Problems identified would not cause significant impact to the safe operation of the plant, and adequate corrective actions were taken to prevent recurrence.

There is sufficient confidence that the implementation of the Periodic Inspection of Ventilation Systems program will effectively determine loss of material, change in material properties, and reduction of heat transfer, with appropriate guidance for reevaluation, repair or replacement provided for locations where the aging effects occur. Periodic self-assessments of the Periodic Inspection of Ventilation Systems program are performed to identify the areas that need improvement to maintain the quality performance of the program.Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1821 Revision 1 aging management program, XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

Page 7 of 7 rji'Ashley

-Reconciliation Doc ReV__O 01-22-06.pdf-1111, I -Page 4Ashley- Reconciliation Doc Rev_0 01j206.pdf Page 48 1 Attachment 2.4 OC LRA Use of B.2.2 LUBRICATING OIL MONITORING ACTIVITIES Program vs. XI.M39 LUBRICATING OIL ANALYSIS PROGRAM Prooram

Description:

The NUREG-1801, Revision 1 aging management program Xl.M39, Lubricating Oil Analysis Program, will not be used at Oyster Creek. The Oyster Creek Lubricating Oil Monitoring Activities aging management program B.2.2 manages loss of material, cracking, and fouling in lubricating oil coolers, systems and components in the scope of license renewal. These activities include measures to minimize corrosion and to mitigate loss of material and cracking in lubricating oil heat exchangers by monitoring lubricating oil properties.

Specifications of the XL.M39, Lubricating Oil Analysis Program are included through sampling, testing, and trending verify lubricating oil properties and ensure that the intended functions of the coolers are not lost. Oil analysis permits identification of specific wear mechanisms, contamination, and oil degradation within operating machinery and components.

The activities manage physical and chemical properties in lubricating oil. The OC Lubricating Monitoring Activities aging management program performs sampling and analysis of lubricating oil for the presence of water, as well as particulates and contaminants for the purpose of detecting the presence of inleakage and corrosion product buildup. This program is augmented by the One-Time Inspection aging management program, B.1.24, to verify the effectiveness of the Lubricating Oil Monitoring Activities Program, B.2.2.New exception to NUREG-1801, required due to incorporation of specifications from September 2005 Revision 1 GALL program XI.M39: Parameters Monitored/inspected (Element 3) specifies the flash point be measured for the lubricating oils. Flash Point is not measured for all lubricating oils in service, since this is a quality control measurement when purchasing new oil. It is not a primary measurement to determine the presence of water or contaminants, which are the parameters for assessing the environment of concem. Measurement of flash point is a measure to detect the contamination of lubricating oils by fuel oil, as is the case for diesel engines lubricating oil.Therefore, flash point is measured for diesel engine lubricating oils only.New enhancement to Incorporate specification from XI.M39, Lubricating Oil Analysis Program: The Oyster Creek Lubricating Oil Monitoring Activities aging management program B.2.2 will be enhanced to include sampling for and measurement of Flash Point for diesel engine lubricating oil.1. Scope of Proaram: The Oyster Creek Lubricating Oil Monitoring Activities Program samples lubricating oil from plant components subject to aging management review on a periodic basis.Result: This element of the Oyster Cieek aging managementprogram Lubricating Oil Monitoring Activities is consistent with recommendations of the Page 1 of 5 h ev -Reconciliation ocI' ' ' b' 01 22 06.pdf-11 I e ' "I Paa 49 -, D. Ashley -Reconciliation Doc Rev_0 0L2206.pdf Paae 49 Attachment 2.4 NUREG-1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.2. Preventive Actions: The Oyster Creek Lubricating Oil Monitoring Activities Program maintains oil systems contaminants (primarily water and particulates) within acceptable limits.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, Xl.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.3. Parameters Monitored/Inspected:

The Oyster Creek Lubricating Oil Analysis program includes specifications for known oil degradation indicators and degradation characteristics, sampling and analysis frequencies, and corrective actions for control of lubricating oil properties.

Lubricating oil physical properties are tested to standard ASTM and ISO methods, for the applicable oil type, to provide accurate quantitative numbers with repeatable results. Samples are taken and analyzed for indications of degraded chemical and physical properties depending on oil type and type of service. Analyses include: chemical parameters and viscosity, total acid number, total base number, rotating pressure vessel oxidation test, water demulsibility, particle count, fuel and combustion byproducts, sediment, water, anti-foaming characteristics, whole particle counting, air release and emission spectrum.

Normal, alert, and fault levels for oil chemical and physical properties, wear metals, contaminants,-and addilives are established for the specific oil type and application.

Exception:

The NUREG 1801 Rev. 1 XL.M39 Lubricating Oil Analysis program specifies that flash point be determined.

The Oyster Creek Lubricating Oil Monitoring Activities Program does not measure flash point for all lubricating oils in service, since this is a quality control measurement when purchasing new oil. It is not a primary measurement to determine the presence of water or contaminants, which are the parameters for assessing the environment of concern. Measurement of flash point can be a measure to detect the contamination of lubricating oils by fuel oil, as is the case for diesel engine lubricating oil. Therefore, flash point will be measured for diesel engine lubricating oils only.Enhancement:

The Oyster Creek Lubricating Oil Monitoring Activities Program will be enhanced to include sampling for and measurement of Flash Point for diesel engine lubricating oil.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.Page 2 of 5 D. Ashley- ReconciliatiDn Doc Rev_0 0122 06.pdf Pace 50A ---I Attachment 2.4 4. Detection of Aaina Effects: Monitoring activities maintain lubricating oil properties within predefined limits to both mitigate and detect the effects of aging. Oil analysis has become an accurate method for identifying specific wear mechanisms, contamination, and oil degradation characteristics within operating machinery.

The program includes normal, alert, and fault action levels for oil chemical and physical properties, wear metals, contaminants, and additives, for the specific oil type and application.

Increased impurities and degradation of oil properties indicate degradation of materials in lubricating oil systems. Monitoring of the diagnostic parameters indicates degradation due to aging effects prior to loss of intended function.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.5. Monitoring and Trending: Lubricating oil analysis results are monitored and trended to allow for the detection and identification of adverse trends prior to the occurrence of a loss of function event.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XL.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.6. Atcebtance Criteria: Normal, alert, and fault levels have been established for the various chemical and physical properties, wear metals, additives, and contaminant levels based on information from oil manufacturers, equipment manufacturers, and Industry guidelines, for the specific oil type and application.

The program maintains contaminant and parameter limits within the application-specific limits. Plant procedures outline potential actions to be taken at alert and fault levels, and actions can be chosen based on the level of deviation.

Aging effects or unacceptable results are evaluated and appropriate corrective actions are taken.Particle concentration Is determined in accordance with ISO 4406.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, Xi.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.7. Corrective Actions: Lubricating oil chemical and physical test results or contaminants outside the allowable limits are returned to the acceptable range within reasonable time periods as identified in industry guidelines.

Evaluations are performed for test results that do not satisfy established criteria and an Issue Report is initiated to Page 3 of 5 HI D. Ashley -Recniiton Dc Rev0 0t206?.p*$i I D. Ashley -Reconciliation Doc Rev_0 0L2206.pdf Paae 51 Attachment 2.4 document the concern in accordance with plant administrative procedures.

The corrective actions program ensures that conditions adverse to quality are promptly corrected.

If the deficiency is found to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude recurrence.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis.8. Confirmation Process: Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis.9. Administrative Controls: See item 8 above.Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities i; consistent with recommendations of the NUREG- 1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis.10. Operating Experience:

The overall effectiveness of lubricating oil monitoring activities is indicated by the Oyster Creek operating experience.

Lubricating oil sampling and analysis have detected particulate or water contamination (or both) in lubricating oil systems. In some cases these events resulted in systems being declared inoperable until repaired, and until the oil was flushed or replaced.

Operating experience has produced procedure and program changes, which have improved the effectiveness of lubricating oil testing and inspection activities.

In 2001, a Core Spray Pump oil analysis detected a high ratio of large to small particles after an oil change. Further investigation determined there had been no increase in pump vibration levels for an extended period, and that source of the particles in the changed oil was contamination from the reservoir when the oil change occurred.

The condition did riot render the pump inoperable, but continued operation with contaminated oil could have caused accelerated bearing wear, which would be indicated by increasing vibration levels. The reservoir was flushed to remove particles and new oil was added. An increased Page 4 of 5 I,` b ---, " --" -

Reconciliation Doc Rev-0 01 06.pdf -1 -11 .... I I I -__ -111,11"i"", I'Page 11------- -- ----... ., --~ I -I -- -,11 'll --I -I _ _ _ " , , , -]D. AshleyI -Reconciliation" Doc Rev_0"I 012206-.pdf--P-ae 52ll Attachment 2.4 oil surveillance frequency was established to confirm oil condition, and vibration data monitoring was performed as part of the scheduled preventive maintenance for the pump.In 2002, while performing the fire pump operability test, the oil temperature stabilized two degrees higher than the allowed maximum temperature from the procedure.

The system manager consulted with the vendor, and it was determined the procedure was too restrictive.

The procedure was revised to conform with the vendor specifications.

In 2005, the potential for introducing improper bearing grease during motor refurbishing was recognized.

Immediate action included cleaning and re-greasing.

Follow-up actions included investigating improved vendor controls and updating of work instructions.

The operating experience of the Lubricating Oil Monitoring Activities program did not show any adverse trend in performance.

Problems identified would not cause significant impact to the safe operation of the plant, and adequate corrective actions were taken to prevent recurrence.

There is sufficient confidence that the implementation of the Lubricating Oil Monitoring Activities program will effectively maintain oil systems contaminants within acceptable limits, thereby preserving an environment that is not conducive to loss of material, cracking, or reduction of heat transfer.

Periodic self-assessments of the Lubricating Oil Monitoring Activities program are performed to identify the areas that need improvement to maintain the quality performance of the program.The Oyster Creek Lubricating Oil Monitoring Activities aging management program will provide assurance that the oil environment in the mechanical systems is maintained to the required quality. The program will provide reasonable assurance that system in tended functions are maintained consistent with the current licensing basis during the period of extended operation.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis.Page 5 of 5

[ D As hley -Reconciliat on Doc Rev 0 01 22 06.rpdfDA y e l o o v 1 6 f-', Attachment 3 AMR Line Items Used in the Oyster Creek LRA for which"Further Evaluation" changed from "No" to "Yes" in the September 2005 Revision 1 GALL LD. Ashley -Reconciliation Doc Rev 0 01 2206.pdf Page 54 Attachment 3 AMR Line Items Used in the Oyster Creek LRA for which "Further Evaluation" changed from "No" to "Yes" EP-34 V.D2-10, 3.2.1-24:

Two new line items invoking One-Time Inspection for Reduction of Heat Transfer due to fouling will be added to the Oyster Creek LRA as a result of this change to the GALL.This line item for stainless steel heat exchanger tubes in treated water, addressing reduction of heat transfer due to fouling, invoked the Water Chemistry program with 'No'further evaluation required in January 2C(5 and has been changed in September 2005 to Water Chemistry and One-Time Inspection, with 'Yes" for evaluation of aging effects.There are 2 instances of this line item being used in the Oyster Creek License Renewal Application, both in the Isolation Condenser system, for heat exchanger tubes, internal and external.In the Oyster Creek LRA, there are 132 line item instances of One-Time Inspection of stainless steel components in a treated water environment.

While these instances are applied to aging effects of loss of material or cracking, they provide ample inspection opportunity for the condition of the components

-observed conditions that have the potential for impacting an intended function are evaluated and corrected as necessary in accordance with the corrective action process. Since one of the functions of the Water Chemistry program is to prevent or mitigate reduction of heat transfer due to fouling, a detected fouling condition on any of the components inspected for loss of material or cracking would also be identified and entered into the corrective action process. Thus there is high confidence that any instance of the Water Chemistry Program's failure to prevent fouling would be identified during the inspections for loss of material due to corrosion and cracking.

However, since the Isolation Condenser tubes specifically will undergo eddy current testing during the first ten years of the period of extended operation, a One-Time Inspection for fouling of the internal surface of the tubes can be performed at that time. The Isolation Condenser shell side components undergo inspection for loss of material under the One-Time Inspection program; an inspection of the external surface of the tubes for reduction of heat transfer due to fouling will also be performed.

AP-54 VII.H1-6, 3.3.1-54:

There is no change required to the Oyster Creek LRA due to this item change.This fine item for stainless steel piping elements in fuel oil, addressing loss of material due to corrosion, invoked the Fuel Oil Chemistry program with "No" further evaluation required in the January 2005 draft GALL. It has been changed in September 2005 to Fuel Oil Chemistry and One-Time Inspection, with "Yes" for evaluation of detected aging effects, to be consistent with other line items applicable to fuel oil environments.

There are 6 instances of this line item being used, in the EDG and Auxiliary systems, and in Main F.O. Storage and Transfer system.In the Oyster Creek LRA, four other Table 1 line items also specify the Fuel Oil Chemistry program to address loss of material due to corrosion in a fuel oil environment Page 1 of 8 I D. Ashley -Reconciliation oc Rev 0 012206.pdf pnngl real-- ...Attachment 3* A-30, 3.3.1-20 (with One-Time), for steel material, 49 instances in the EDG and Aux, Fire Protection, Main F.O. Storage, and SBO systems, Further Evaluation is 'Yes" for evaluation of aging effects* AP-44, 3.3.1-26 (with One-Time), for copper alloy material, 6 instances in the EDG and Aux, F.P., and Main F.O. Storage systems, Further Evaluation is'Yes" for evaluation of aging effects* AP-35, 3.3.1-25 (with One-Time), for aluminum material, 6 instances in the EDG and Aux, and SBO systems, Further Evaluation is "Yes" for evaluation of aging effects* A-28, 3.3.1-48 (with Fire Protection), for steel material, 6 instances in the F.P.and SBO systems, Further Evaluation is "No" Numerous items in the EDG and Aux systems and Main F.O. Storage Systems are already subject to both the F.O. Chemis:ry and One-Time Inspection requirements for determination of loss of material due to corrosion.

The basis for sample size for the One-Time Inspection program would not be significantly affected by the addition of the (comparatively few) AP-54 line items. Evaluations of any detected aging effects from inspections of those components, with observed conditions that have the potential for impacting an intended function evaluated and corrected as necessary in accordance with the corrective action process, provide ample opportunity for verification of the effectiveness of the F.O. Chemistry program with the One-Time Inspection program in these two systems.AP-62 VI.A4-4 and V.1E3-6, 3.3.1-69:

There is no change required to the Oyster Creek LRA due to this item change.This line item for stainless steel heat exchanger tubes in treated water, addressing reduction of heat transfer due to fouling, invoked the Water Chemistry program with "No" further evaluation required in-January 2C05 and has been changed in September 2005 to the Water Chemistry and One-Time Inspection programs, with 'Yes" for evaluation of aging effects. There are 2 instances of this line item being used, applicable to the treated water side of heat exchanger components in the Reactor Building Closed Cooling Water System (RBCCW).In the Oyster Creek LRA, there are 229 line item instances of One-Time Inspection of stainless steel components in a treated water environment.

While these instances are applied to aging effects of loss of material or cracking, they provide ample inspection opportunity for the condition of the components

-observed conditions that have the potential for impacting an intended function are evaluated and corrected as necessary in accordance with the corrective action process. Since one of the functions of the Water Chemistry program is to prevent reduction of heat transfer due to fouling, a noted fouling condition on any of the inspected items would be identified and entered into the corrective action process. Thus there is high confidence that any instance of the Water Chemistry Program's failure to prevent fouling would be identified during the inspections for loss of material due to corrosion and cracking.Page 2 of 8 D. Ashley- Reconciliation Doc Rev 0 012206.pdf Page 56 Attachment 3 AP-64 VIL.C2-5, 3.3.1-38:

There is no change required to the Oyster Creek LRA due to this item change.This line item for copper alloy piping elements in treated water, addressing loss of material due to corrosion, invoked the Closed-Cycle Cooling Water System program with"No' further evaluation required in January 2005 and has been changed in September 2005 to Water Chemistry and One-Time Inspection, with "Yes" for evaluation of detected aging effects. There are 4 instances of this line item being used, in the Condensate Transfer and Reactor Building Closed CDoling Water systems. In the Oyster Creek LRA, these 4 instances already specify the Water Chemistry and One-Time Inspection programs (with a standard 'EX note stating that a different aging management program than was specified in January 2005 GALL was credited).

Therefore, the Oyster Creek LRA implements the One-Time Inspection program and is consistent with GALL. Since observed conditions that have the potential for impacting an Intended function are evaluated or corrected in accordance with the corrective action process, there is high confidence that the aging effect will be adequately managed.T-01 3.5.1-21:

There is no change required to the Oyster Creek LRA due to this item change.For Inaccessible areas: As described in the UFSAR Section 3.8.4.6, 'Materials, Quality Control and Special Construction Techniques, concrete is designed consistent with ACI 318 requirements to provide workable concrete of homogeneous structure which, when hardened, will have durability, impermeability and the specified strength.

Testing of concrete was performed in accordance with ASTM Standards specified in ACI 318 to ensure the desired quality of concrete is furnished.

The strength quality of the concrete was established by tests made in advance of the beginning of operations using a maximum slump of four inches. Specimens were tested and cured in accordance with ASTM C39.The review of design and construction documents indicated that the specified air content is 4 to 6 percent. Water-to-cement ratio was based on the strength required by the design considering the maximum slump of four inches. Curves representing the relation between the water content and the average 28-day compressive strength were established for a range of values including the compressive strengths specified.

The curves were established by at least three points, each point represented average values from at least four test specimens.

The maximum allowable water content for each class of concrete was determined from the curves and corresponded to a compressive strength of 15 percent greater than that specified for that class of concrete.

A review of documentation for a sample of class 4Ut (4000 psi) concrete cylinder tests shows that the 28-day strength meets or exceeds the specified 4000 psi compressive strength.Inspections conducted in accordance wi:h the Structures Monitoring Program have identified minor loss of material (spalling, scaling) and cracking which could be attributed to freeze-thaw in accessible areas. Engineering evaluation of the identified loss of material and cracking concluded it is not significant to impact the intended function of the affected structure.

Page 3 of 8 D. Ashley -Reconciliat on Doc Rev0 012206.pdf P 57 Attachment 3 Based on above evaluation, we concluded that loss of material and cracking due to freeze-thaw is not significant for inaccessible areas. Thus a plant-specific aging management program is not required.T-02 3.5.1-23:

There is no change required to the Oyster Creek LRA due to this item change.Further evaluation is only required for inaccessible areas if concrete was not constructed as stated (in accordance with the recommendations in ACI 201.2R). In the Oyster Creek LRA, the uses of this line item are not for inaccessible areas. Accessible areas inspections are performed in accordance with the Structures Monitoring Program, per September 2005 GALL.T-03 3.5.1-21:

There is no change required to the Oyster Creek LRA due to this item change.The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program and stated conditions are satisfied for inaccessible areas, to required if not within the scope of the applicant's structures monitoring program, or concrete was not constructed as stated for inaccessible areas.This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.T-04 3.5.1-21:

There is no change required to the Oyster Creek LRA due to this item change.The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.T-06 3.5.1-21:

There is no change required to the Oyster Creek LRA due to this item change.The environment for this item, concrete:

interior and above grade exterior, changed from'aggressive environment" to 'air -indoor uncontrolled or air -outdoor".

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. Each instance of use of this item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.T-08 3.5.1-27:

There is no change required to the Oyster Creek LRA due to this iem change.Oyster Creek does not rely on a de-wate ring system for control of settlement.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This iem is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.Page 4 of 8 I ----2 Ashley -Reconciliation Doc Rev_0 01L22 06.pdf Page58 X Attachment 3 T-11 3.5.1-21:

There is no change required to the Oyster Creek LRA due to this item change.The wording for further evaluation was changed from not required if within the scope of the applicants structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.T-1 5 3.5.1-24:

There is no change required to the Oyster Creek LRA due to this item change.For inaccessible areas: As described in the UFSAR Section 3.8.4.6, 'Materials, Quality Control and Special Construction Technques", concrete is designed consistent with ACI 318 requirements to provide workable concrete of homogeneous structure which, when hardened, will have durability, impermeability and the specified strength.

Testing of concrete was performed in accordance with ASTM Standards specified in ACI 318 to ensure the desired quality of concrete is furnished.

The strength quality of the concrete was established by tests made in advance of the beginning of operations using a maximum slump of four inches. Specimens were tested and cured in accordance with ASTM C39.The review of design and construction documents indicated that the specified air content is 4 to 6 percent. Water-to-cement ratio was based on the strength required by the design considering the maximum slump of four Inches. Curves representing the relation between the water content and the average 28-day compressive strength were established for a range of values including the compressive strengths specified.

The curves were established by at least three points, each point represented average values from at least four test specimens.

The maximum allowable water content for each class of concrete was determined from the curves and corresponded to a compressive strength of 15 percent greater than that specified for that class of concrete.

A review of documentation for a sample of class 4UL (4000 psi) concrete cylinder tests shows that the 28-day strength meets or exceeds the specified 4000 psi compressive strength.Inspections conducted in accordance with the Oyster Creek RG. 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants have identified loss of material (spalling, scaling) and cracking Nhich could be attributed to freeze-thaw in accessible areas. Engineering evaluation of the identified loss of material and cracking concluded it is not significant to impact the intended function of the affected structure.

Based on above evaluation, we concluded that loss of material and cracking due to freeze-thaw is not significant for inaccessible areas. Thus a plant-specific aging management program is not required.T-16 3.5.1-24:

There is no change required to the Oyster Creek LRA due to this item change.The Oyster Creek LRA's commitment to perform inspections in accordance with Reg.Guide 1.127 does not change. This line item is not applied to inaccessible areas;therefore further evaluation is not required.Page 5 of 8

[D. Ashley -'Reconciliation Doc Rev-0 01-22 06'.ldf I I I Page 59,."I P. Ahle -ecocilitio Do Re_0 0220.pd Pae 5 Attachment 3 T-1 7 3.5.1-24:

There is no change required to the Oyster Creek LRA due to this item change.As described in the UFSAR Section 3.8.4.6, 'Materials, Quality Control and Special Construction Techniques", the cement used for Oyster Creek was an approved brand of Portland Cement conforming to ASTM Specification C-150; Type II, low alkali. Alkali content is limited to 0.6 percent total alkali. The low alkali requirement for the cement was waived provided petrographic tests conducted in accordance with ASTM C295 and C227 demonstrated no potential alkali reactivity for all aggregates proposed for use.This provides reasonable assurance that aggregates do not react with reinforced concrete.Additionally, the aggregate used on the project was from approved sources and consisted of clean, hard, durable particles conforming to the requirements of concrete specifications.

Tests were performed as necessary to determine that the proposed aggregate would produce concrete of acceptable quality and durability, meeting ACI requirements.

T-18 3.5.1-24:

There is no change required to the Oyster Creek LRA due to this item change.Oyster Creek has committed to inspecting inaccessible areas of structures in the scope of license renewal that are exposed by excavation for any reason, and to sample and test groundwater periodically during the period of extended operation (Ref: AMP-1 68).This line item has been invoked for water control structures.

Oyster Creek has committed to performing a baseline inspection of submerged water control structures prior to entering the period of extended operation.

A second inspection will be performed 6 years after the baseline inspection.

A third inspection will be performed 8 years after the second inspection.

Following each inspection, the identified degradations will be evaluated to determine if more frequent inspections are warranted or there is a need for corrective actions to ensure that age related degradations are adequately managed (Ref: AMP-077).

Inspections will be conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.The review of design and construction documents indicated that the specified air content is 4 to 6 percent. Water-to-cement ratio was based on the strength required by the design considering the maximum slump of four inches. Curves representing the relation between the water content and the average 28-day compressive strength were established for a range of values includirg the compressive strengths specified.

The curves were established by at least three! points, each point represented average values from at least four test specimens.

The mr aximum allowable water content for each class of concrete was determined from the curses and corresponded to a compressive strength of 15 percent greater than that specified for that class of concrete.

A review of documentation for a sample of class 4LA (4000 psi) concrete cylinder tests shows that the 28-day strength meets or exceeds the specified 4000 psi compressive strength.Inspections conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants have identified cracking, change in material properties, and loss of material (spalling, scaling), which could be attributed to corrosion of embedded steel in accessible areas. Engineering evaluation of the Page 6 of 8 Ffl A .LI_.. _ _ -I I -.- I I -- 1 v D. Ail iiey -Fleconciiai onl Doc Rey 0 U1 22 ub~rdt P:>ncs Rn l 1--_ _ ---_ _- -, F1 '-o Attachment 3 identified cracking, change in material properties, and loss of material concluded it is not significant to impact the intended functicn of the affected structure.

Based on above evaluation, we concluded that cracking, change in material properties, and loss of material due to corrosion of embedded steel is not significant for accessible and inaccessible areas, and RG. 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants vill adequately manage the aging effect. Thus a plant-specific aging management program is not required.T-19 3.5.1-24:

There is no change required to the Oyster Creek LRA due to this item change.Oyster Creek has committed to inspecting inaccessible areas of structures in the scope of license renewal that are exposed by excavation for any reason, and to sample and test groundwater periodically during the period of extended operation (Ref: AMP-168).This line item has been invoked for water control structures.

Oyster Creek has committed to performing a baseline inspection of submerged water control structures prior to entering the period of extended operation.

A second inspection will be performed 6 years after the baseline inspection.

A third inspection will be performed 8 years after the second inspection.

Following each Inspection, the identified degradations will be evaluated to determine if more frequent inspections are warranted or there is a need for corrective actions to ensure that age related degradations are adequately managed (Ref: AMP-077).

Inspections will be conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.Inspections conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants have identified concrete degradation, which could be attributed to aggressive chemical attack in accessible areas.Engineering evaluation of the identified identified increase in porosity and permeability, cracking, and loss of material concluded it is not significant to impact the intended function of the affected structure.

Based on above evaluation, we concluded that change in material properties, cracking, and loss of material (spalling, scaling) due to aggressive chemical attack is not significant for accessible and inaccessible areas, and RG. 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants will adequately manage the aging effect. Thus a plant-specific aging management program is not required.T-29 3.5.1-33:

There is no change required to the Oyster Creek LRA due to this item change.The wording for further evaluation was changed from not required If within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicants structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.T-30 3.6.1-33:

There is no change required to the Oyster Creek LRA due to this iem change.The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the Page 7 of 8

[E Ashley- Reconciliation Doc Rev_0 01_22_06.pdf

..;. P" Attachment 3 applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.T-31 3.5.1-33:

There is no change required to the Oyster Creek LRA due to this item change.The wording for further evaluation was c hanged from not required if within the scope of the applicant's structures monitoring prcgram, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.Page 8 of 8

[D. Ashley -Reconciliation Doc Rev_0 01-22_06.pdf Paqne 62 I ",11 II ",',"" 11-- -I 11 1 ~ -~ I ' -_. _ _ -Attachment 4 AMR Line Items Used in the Oyster Creek LRA which were Deleted from the September 2005 Revision 1 GALL Ashley- Reconciliation DOC Rev_ 01_22_0 ...pdf -P 63 Attachment 4 20 Line Items used in OC LRA Now Deleted from September 2005 Revision 1 GALL Twenty (20) Line Items used in the OCLR LRA have been deleted from September 2005 GALL.Note: In the listings below, following the line item alphanumeric number and number of times the line item appears in the OC LFIA, is a shortened description of the line item's content (structure and component description, material, environment, aging effect and mechanism, and GALL recommended program) for information.

For the complete description, reference GALL.1.) R-22 -(IV.C1-9; 35 line item occurrences):

piping, components, elements > 4NPS;stainless steel; reactor coolant; cracking/SCC/lGSCC; programs:

BWR SCC, Water Chemistry 9/05 GALL Master list replacement.

R-20 9/05 GALL states that CASS and SS share aging effects and mechanisms with the exception of CASS loss of fracture toughness due to thermal and neutron irradiation embrittlement; therefore CASS only needs to be listed when embrittlement is an issue.Consequently, 9/05 GALL R-20 deletes "CASS" (evidently intending that 'SS" includes it when necessary), and concludes that R-22 is identical to R-20, therefore R-22 was deleted.OC LRA effect: No changes required.

The OC LRA line items using R-22 for SS have the same aging effects and mechanisms, and are covered by the same programs (BWR SCC and Water Chemistry), as R-20.2.) R-55 -(IV.C1 -2; 90 line item occurrences):

Class 1 piping, branch connections

< 4 NPS; SS, steel; reactor coolant; crackinc/thermal and mechanical loading; programs: Section Xl ISI, One-Time Inspection 9/05 GALL Master list replacement:

R-03 9/05 GALL states that NRC staff requested that R-03 and R-55 be managed identically.

Consequently, thermalmechanical loading from R-55 was added to R-03. IGSCC was noted to apply to SS only (implying that 8CC still applies to CS, which is not the position taken in the OC LRA, based on input from the peer review), and new program 'One-Time Inspection of Class 1 Small-Bore Piping' was added to R-03's Section Xl ISI and Water Chemistry, in lieu of a 'plant specific (for which the OC LRA uses One-Time Inspection as an equivalent inspection piogram).OC LRA effect: No changes required.

For SS piping, the OC LRA invoked R-03 and R-55 together, so for SS, the OC LRA is in compliance with the 9/05 GALL changes. For CS piping, the OC LRA invoked R-55 for cracking due to thermal and mechanical loading, but did not call out R-03, based on the peer review information that the January draft of GALL would be changed to not specify SCC to be considered for CS (and Page 1 of 7

[X Ashley -Reconciliation Doc Rev_0 01_22 06.pdf P 6 Attachment 4 chrome-moly).

SCC was not deleted from CS material in the 9/05 GALL; therefore 9/05 GALL would specify Water Chemistry to be invoked via R-03 to manage stress corrosion cracking for CS (and chrome-moly) pipirg. However, in the OC LRA, for each environment of each component listing of piping, fittings, and valves where R-55 was invoked for cracking in CS and chrome-moly material, the Water Chemistry program is also invoked, to manage loss of material.

Therefore, the programs specified by 9/05 GALL to manage SCC are invoked, and the OC LRA is equivalent to the specifications of 9/05 GALL.3.) RP-02 -(V.E-1; 9 line item occurrences):

piping, components, elements; CASS; air indoor uncontrolled; None-None 9/05 GALL Master list replacement:

No recommendation OC LRA effect: No changes required.

9/05 GALL says nothing specifically about the deletion of RP-02, but does say elsewhere (in R-20) that CASS and SS are to be treated equivalently except where thermal or ne tron irradiation embrittlement is an issue. RP-04 is identical to RP-02 but lists only SS, not specifically CASS. As in the discussion in R-20, GALL apparently expects RP-04 to cover CASS as well as SS, and eliminated RP-02 as redundant.

The OC LRA is equivalent.

4.) E-16 -(V.D2-22; 4 line item occurrences):

piping, components, elements; SS, treated water; cumulative fatigue; TLAA 9/05 GALL Master list replacement:

E-10 9/05 GALL states that E-10 is identical lo E-16, so E-16 was deleted.'

However, E-10 is for 'steer, E-1 6 was for 'stainless steel." OC LRA effect: No changes required.

ihe 00 LRA use of E-16 for SS invokes TLAA, just as E-10 does for "steer. The OC LFIA is equivalent.

5.) E-32 -(V.C-8; 2 line item occurrences):

Containment isolation piping and component internal surfaces; steel; untreated water; loss of material/corrosion/MIC; plant specific program 9/05 GALL Master list replacement:

E-22 9/05 GALL states that changing E-32's Entreated water" to "raw water" made it a duplicate of E-22; therefore GALL deleted E-32. E-22's program is Open-Cycle Cooling Water, which GALL says manages steel In a raw water environment.

The OC LRA used One-Time Inspection for E-32's "plant specific" program.OC LRA effect: No changes required.

The One-Time Inspection program the OC LRA invoked corresponds to inspections applied through the use of Open-Cycle Cooling.Open-Cycle Cooing addresses use of biocides to prevent MIC -the OC LRA's use of One-Time Inspection does not address this, however, the OC LRA invokes E-32 only in the Drywell Floor and Equipment Drain System, and addition of a blocide would not apply, because water In this portion of th e drain system is treated water that has leaked out of its original system. MIC would not be a credible aging mechanism for this type of water environment.

The OC LRA is equivalent.

Page 2 of 7 y.Ashley -Reconciliation Doc Rev_0 0122_06pdf Page 65 Attachment 4 6.) EP-21 -(V.F-1 8; 1 occurrence

-Service Water system): piping, piping components, and piping elements; SS; lubricating oil; None-none 9/05 GALL Master list replacement:

EP-51 9/05 GALL states that GALL now assumes water pooling in lubricating oil, which would create a potential for a plausible aging effect in SS. GALL now calls out the new Lubricating Oil Analysis program and One-Time Inspection for this line item.OC LRA effect: No change required.

The OC LRA's only use of this line item is in the lubricating oil system for the service waler pumps, which are in continuous use -therefore pooling of any contamination water in the lubricating oil system is not credible, and a pooled water aging effect on the S'S piping is not postulated to occur.7.) A-11 -(VII.F3-6; 19 occurrences):

clucting/piping internal surfaces; steel; air indoor uncontrolled; loss of materialcorrosion; plant specific program 9/05 GALL Master list replacement:

A-03 9/05 GALL states that changing the environment of A-08 from 'air indoor uncontrolled" to"condensation internal", adding MIC to the aging mechanisms, and adding the new program "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components' to this line item in lieu of the 'plant specific" program made it a duplicate of A-11, so A-I1 was deleted.OC LRA effect: No change required.

The OC LRA used A-11I in 7 different systems, with 5 different plant specific programs depending on the application, including:

None;Fire Protection; Fire Water; One-Time; Periodic Inspection; and Appendix J. The various inspections resulting from these programs provide a corresponding level of scrutiny as the new program. The "None" instances where no OC program was applied were for the Containment Inerting System and the Reactor Building Ventilation System, where past precedence was cited that said loss of material due to corrosion of carbon steel in a containment environment was not a credible aging effect due to the negligible amounts of free oxygen in a containment nitroger environment.

8.) A-12 -(VII.F3-5; 15 occurrences):

ducting, piping, component internal surfaces; SS;condensation internal; loss of materia/corrosion; plant specific program 9/05 GALL Master list replacement:

A-t}9/05 GALL states that removing "external" from the structure/component description and environment of A-09 made it a duplicate of A-12, so GALL deleted A-12.OC LRA effect: No change required.

The OC LRA used One-Time Inspection as the plant specific program which would be no different had it Invoked A-09. The OC LRA is equivalent.

9.) A-13 -(VII.F3-3, 1 occurrence; VII.F4-3, 2 occurrences):

ducting/piping internal surfaces; steel; condensation internal; loss of materialcorrosion and MIC; plant specific program Page 3 of 7 E Ashley -Reconciliation Doc Rev_0 01 22 06.pdf Pg Attachment 4 9/05 GALL Master list replacement:

A-Oi 9/05 GALL stated that changing the environment of A-08 from "air indoor uncontrolled" to'condensation internal", adding MIC to the aging mechanisms, and adding the new program "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components' to this vs. 'plant specific" program made it a duplicate of A-13, so A-13 was deleted.OC LRA effect: No change required.

The OC LRA used A-13 in 2 different systems, with periodic inspection called out as the! plant specific program. The periodic inspection is equivalent to the inspections of opportunity described in the new GALL program.10.) A31 -(VII.C3-10; 2 occurrences);

piping, components, elements; steel; raw water;loss of material/corrosion and MIC; open-cycle cooling 9/05 GALL Master list replacement:

A-38 9/05 GALL states that A-38 encompasses A-31 and therefore A-31 is not needed. A-38 also applies to lined or unlined piping, and includes fouling and lining degradation.

O LRA effect: No change required.

The OC LRA's two instances of A-31 both used an'E" alternate program (Structures Monitoring for the intake structure, and One-Time Inspection, in conjunction with the Selective Leaching of Materials program for the Raw Water-Fresh Water environment in Sanitary Waste). These programs' inspections correspond to those of the Open-Cycle Cooling Water program, and are more appropriate for these two applications.

The OC LRA is equivalent.

1 1.) A-32 -(VII.C1 -18; 28 occurrences);

piping, components, elements; steel; raw water;loss of material/corrosion, fouling, and IV IC; open-cycle cooling 9/05 GALL Master list replacement:

A-38 9/05 GALL states that A-38 encompasses A-32 and therefore A-32 is not needed. A-38 also applies to lined or unlined piping, and includes lining degradation.

OC LRA effect: No change required.

The OC LRA's instances of invoking A-32 either use Open-Cycle Cooling, or they use One-Time Inspection (to confirm absence of aging effects in pooled or stagnant areas of drain piping) or Periodic Inspections with an 'E" standard note and plant specific note. Their use is justified for the application and environment, and results in equivalent scrutiny.12. A-36 -(VII.F2-7, 6 occurrences; VIL.F3-7, 4 occurrences; VIL.F1-8, 3 occurrences):

elastomer seals and components; elastomers; air indoor uncontrolled (extemal);

hardening

-loss of strength/degradation; plant specific program 9/05 GALL Master list replacement:

A-17 9/05 GALL changed the environment of A-17 to be both internal and extemal, therefore A-36 was redundant and deleted.Page 4 of 7 Ashley -Reconciliation c Rev-0 01-22 06.pdf 11 -, __111 I I 11 11-11111 I Do Page 67,]D.A hly R cnclato D cRe_ 01 2206.Ipdf11-_

-1111I- _ _--- --_ X_ 'l --I1 ~ Il Pag 67 -11 Attachment 4 OC LRA effect: No change required.

The OC LRA invokes various plant specific programs depending on the application and they remain valid. The OC LRA is equivalent.

13. A-37 -(VII.E4-18; 1 line item occurrence):

piping, components, elements; steel, treated water; cumulative fatigue; TLAA 9/05 GALL Master list replacement:

A-62 9/05 GALL states that A-62 is the same as A-37, so A-37 was deleted. However, A-62 is for 'stainless steel", A-37 was for 'steel.'OC LRA effect: No changes required.

The OC LRA's use of A-37 for steel invokes TLAA, just as A-62 does for 'stainless steer. The OC LRA is equivalent.

14. AP-29 -(VII.G-14, 6 occurrences; VII.C11-12, 1 occurrence):

piping, components, elements; gray C.1.; untreated water; loss of material/selective leaching; Selective Leaching 9/05 GALL Master list replacement:

A-51 9/05 GALL changed 'untreated water" to 'raw water"; AP-29 was a duplicate to A-51 after this change so AP-29 was deleted.OC LRA effect: No changes required.

The OC LRA invokes Selective Leaching for AP-29, so it is equivalent to A-51.15. AP-57 -(VII.K-7, 12 occurrences; Vll.E3-17, 46 occurrences):

piping, components, elements; SS; treated water; loss of matorial/corrosion, plant specific program 9/05 GALL Master list replacement:

A-58 9/05 GALL states that AP-57 was modified to transfer Related Item 'E3" to A-58, however 9/05 GALL deleted AP-57 entirely, apparently intending that A-58 be used.OC LRA effect: No change required.

The OC LRA's use of AP-57 invokes water Chemistry and One-Time inspection as the plant specific programs in every case except one, where Generator Stator Water Chemistry is used equivalently to Water Chemistry.

The actions for AP-57 are equivalent to those of A-58.16. AP-69 -(VII.K-5, 20 line item occurrences):

piping, components, elements; steel;treated water; loss of material/corrosion; plant specific program 9S05 GALL Master list replacement:

No recommendation OC LRA effect: No changes required.

GALL items A-35, S-09, and E-08 are all similar, and each specifies Water Chemistry and One-Time Inspection programs.

The OC LRA's only use of AP-69 is in the Main Ganerator and Auxiliaries system, and the programs specified are Generator Stator Water Chemistry and One-Time Inspection.

These supply equivalent inspection requirements.

Page 5 of 7 hley -Reconciliation Doc Rev 0 01 22 06.pdf ID'., As' " --__ 1 ---I I'll", "I J Paqe I D.Ashey -Recncilatin Do Re_0 0220.pdfPag 681 Attachment 4 17. AP-7 -(VII.J-3, 1 line item occurrence):

piping, components, elements; CASS; air indoor uncontrolled (external);

None-none 9/05 GALL Master list replacement:

No recommendation OC LRA effect: No changes required.

9/05 GALL says nothing specifically about the deletion of AP-7, but does say elsewhere (in R-20) that CASS and SS are to be treated equivalently except where thermal or neutron irradiation embrittlement is an issue. AP-17 is identical to AP-7 but lists only SS, not specifically CASS. As in the discussion in R-20, GALL apparently expects AP-1 7 to cover CASS as well as SS, and eliminated AP-7 as redundant.

The action taken is equivalent.

18. AP-70 -(VIL.K-1, 1 1 line item occurrences):

piping, components, elements; copper alloy, treated water, loss of material/corrosion; plant specific program 9/05 GALL Master list replacement:

AP-32 9/05 GALL states that AP-32 is a "countar-part to AP-70"; AP-70 has been deleted from GALL.OC LRA effect: No change required.

AP-32 is not a replacement for AP-70. AP-32 addresses loss of material through selective leaching by invoking Selective Leaching for copper alloys with > 15% zinc. AP-70 addresses loss of material through pitting and crevice corrosion for copper alloys by invoking a 'plant specific" program. The OC LRA's use of AP-70 invoked One-Time Inspection and, where applicable, Water Chemistry, and also specified AP-32 for each instance where the copper alloy was subject to selective leaching.

The OC LRA is therefore in compliance with GALL.19. SP-51 -(VIII.J-2,20 line item occurrences):

piping, components, elements; steel;raw water; loss of material/general, pitting, crevice corrosion and MIC; plant specific program 9/05 GALL Master list replacement:

No recommendation OC LRA effect: No changes required.

No GALL explanation is given for deletion of SP-51. Similar GALL line items (all address steel in raw water) include A-31, A-32, A-33, A-38, and E-22, which specify Open Cycle Cooling, Fire Water System, or plant specific programs.

All instances of line item SP-51's use in the OC LRA are in floor drain systems, and the OC LRA specifies the One-Time Inspection program as the plant specific program for detecting the loss of material aging effect due to corrosion (to confirm absence of aging effects in pooled or stagnant areas of drain piping). The One-Time Inspection program provides an equivalent level of scrutiny as the programs used in the similar line items listed above.20. SP-52 -(VIII.J-1, 13 line item occurrences):

piping, components, elements; SS; raw water; loss of material/pitting and crevice corrosion; plant specific program 9/05 GALL Master list replacement:

No recommendation OC LRA effect: No changes required.

No GALL explanation is given for deletion of SP-52. Similar GALL line items (all address SS in raw water) include A-53, A-54, A-55, AP-Page 6 of 7

Doc Rev 0 01 22 06.r)df__- 1-111111111111-1-1---

--, -11"111111-1--

-11 ", ... I 'll I --Paae 690:: D.Ashiey -Reconciliation Doc Rev_0 0122...06.pdf Paae 69 Attachment 4 55, and SP-36, which specify Open Cycle Cooling or Fire Water System programs.

All instances of line item SP-52's use in the OC LRA are in floor drain systems, and the OC LRA specifies the One-Time Inspection program as the plant specific program for detecting the loss of material aging effect due to corrosion (to confirm absence of aging effects in pooled or stagnant areas of drain piping). The One-Time Inspection program provides an equivalent level of scrutiny as the programs used in the similar line items listed above.Page 7 of 7 Io: n -eis n-;_;A na -A -.............

.--*-r -- I M- ..... .a .v -.,, --.. O O .s Ug;S{A0gsnNyv OZ I Li. Ashley- iReconciliation Doc Rev U 01_22_ub.pdt Paqne 70 Attachment 5 AMR Line Items used in the Oyster Creek LRA for which Changes in the September 2005 Revision 1 GALL were not solely Administrative

-_Reconciliation Doc Rev 0 01 22 06.pdf--- ---> av r D. A hle"I ecInil'tio Do Re_ 'l 0tI2206.pdf P- l~ ,--, -.I ,- -- 1I- -X n- -.. 71 Attachment 5"Non-Administrative" Changes to Line Items from January 2005 Draft GALL to September 2005 Revision 1 GALL (Items Not Previously Identified by Further Evaluation Changing from No to Yes)1. A-1 04: Program was Plant Specific, now Bolting Integrity (VII.E1 -1, 1 occurrence)

OC LRA effect: None -OC LRA used Bolling Integrity for this occurrence of A-1 04 2. A-50: Programs were Closed Cycle Cooling Water and Selective Leaching; now just Selective Leaching (CCCW removed) (VII.C2-7, 14 occurrences)

OC LRA effect: None -OC LRA is conservative in specifying both CCCW and SL 3. A-63: Galvanic Corrosion added as aging mechanism to general, pitting, and crevice corrosion for steel heat exchanger components (VII.C2-1, 15 occurrences)

OC LRA effect: None -CCCW is used for A-63 to identify corrosion as recommended by GALL and would identify the effects of galvanic corrosion 4. A-64: Galvanic Corrosion added as aging mechanism to general, pitting, crevice corrosion, and MIC for steel heat exchanger components (VIL.C2-3, 2 occurrences)

OC LRA effect None -OCCW is used for A-64 to identify corrosion as recommended by GALL and would identify the effects of galvanic corrosion 5. A-65: Galvanic Corrosion added as aging mechanism to pitting and crevice corrosion, MIC, and fouling for copper alloy heat exchanger components (VIL.C1 -1. 2 occurrences)

OC LRA effect: None -The Fire Water System program is used for A-65 to identify corrosion and would identify the effects of galvanic corrosion 6. AP-30: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VII.E4-17, 24 occurrences; H2-20, 30 occurrences.;

C2-13, 4 occurrences.;

G-20, 4 occurrences.;

F4-14, 1 occurrence.)

OC LRA effect: None -OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs for all occurrences except the one F4-14 occurrence, which is in the EDG system and subject to the Periodic Inspection program. Use of the Periodic Inspection program for the EDG system, in conjunction with the large number of existing samples of components subject to the OC Lubricating Oil Monitoring and One-Time Inspection programs support the conclusion that the programs adequately manage the subject aging effect of loss of material due to corrosion.

7. AP-39: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (Vl.1H2-3, 6 occurrences)

OC LRA effect: None -OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs.

This Is in compliance with September 2005 GALL.8. AP-47: Deleted Galvanic Corrosion aging mechanism; program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VII.H2-10, 10 occurrences; C1-6, 6 occurrences)

OC LRA effect: None -OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs.

This is in compliance with September 2005 GALL.9. AP-59: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VIL.I2-17, 14 occurrences)

OC LRA effect: None -OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs.

This is in compliance with September 2005 GALL.10. C-12: Programs were ASME Section Xl IVIE, Appendix J, and Protective Coating Monitoring and Maintenance if credited, now Protective Coating program is deleted (11.34-1, 19 occurrences)

Page 1 of 5

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S .. = .Ashley -Reconciliation Doc Rev_0 01 2206.pdf Paae 72 Attachment 5 OC LRA effect: None -OC LRA uses IWE and Appendix J programs in each occurrence, and the Protective Coatings program where credited; this matches the September 2005 GALL and use of the Protective Coatings program is conservative

11. C-15: Not a significant change (environment adds outdoor") (II.B4-2,12 occurrences)

OC LRA effect: None -OC LRA applications of this line item are for indoor air or containment atmosphere.

12. C-16: Programs were ASME Section XI IWE, Appendix J, and Protective Coating Monitoring and Maintenance if credited, now Protective Coating program is deleted (11.64-5, 10 occurrences)

OC LRA effect: None -OC LRA uses IWE and Appendix J programs in each occurrence, and the Protective Coatings program where credited; this matches the September 2005 GALL and use of the Protective Coatings program is conservative.

13. C-19: Programs were ASME Section XI IWE, Appendix J, and Protective Coating Monitoring and Maintenance if credited, now Protective Coating program is deleted (11.11.1-2, 62 occurrences)

OC LRA effect: None -OC LRA uses IWE and Appendix J programs in each occurrence, and the Protective Coatings program where credited; this matches the September 2005 GALL and use of the Protective Coatings program is conservative.

14. C-22: Not a significant change (wording clarification in GALL AMP recommendation) (Il.B1.1-5,12 occurrences)

OC LRA effect: None -OC LRA applications of this line item use the aging management programs specified by September 2005 GALL (ASMIE Section Xl, Subsection IWE and Appendix J).15. C-23: Graphite plate deleted from applicable material, steel remains (li.81.1-l,1 occurrence)

OC LRA effect: None -OC LRA only used this item for steel 16. E-33: Program was Plant Specific, now Water Chemistry augmented by One-Time Inspection (V.C-4, 4 occurrences)

OC LRA effect: None -OC LRA uses the Water Chemistry program augmented by the One-Time Inspection program 17. E-42: Added "with or without coating or wrapping" to steel pipe material, and added MIC aging mechanism (V.B-8, 1 occurrence)

OC LRA effect: None -OC LRA uses Buried Pipe Inspection per GALL to manage this aging effect of loss of material 18. EP-24: Not a significant change (replaces stress relaxation with thermal effects, gasket creep, and self-loosening to mechanisms)

19. EP-32: Program was Plant Specific, now Water Chemistry augmented by One-Time Inspection (V.D2-23, 110 occurrences)

OC LRA effect: None -OC LRA uses the Water Chemistry program augmented by the One-Time Inspection program 20. LP-01: Change to name of GALL recommended program (VI.A-8, 1 occurrence)

OC LRA effect: None -OC LRA states that fuse holders (not part of a larger assembly) do not experience the aging effects identified in NLUREG-1 801 due to their location and environment.

See OC LRA Subsection 3.6.2.3.1 for additional information.

21. LP-04: Change to name of GALL recommended program (VI.A-1 1, 1 occurrence)

Page 2 of 5 LD.Ashey -Reconciliation Doc Rev_0 01-22-06.pdf Page 73 Attachment 5 OC LRA effect: None -OC LRA states that FRCT phase busses are coated to prevent oxidation, and connections are taped. Heating caused by corrosion or loosening of bolted connections would cause degradation of the tape covering detectable during a visual inspection.

22. LP-05: Change to name of GALL recommended program (VI.A-14, 1 occurrence)

OC LRA effect: None -OC LRA states that FRCT phase busses are coated to prevent oxidation, and connections are taped. Heating caused by corrosion or loosening of bolted connections would cause degradation of the tape covering de ectable during a visual inspection.

23. LP-07: AMP note added: Program was Plant Specific, now Plant Specific for plants located such that the potential exists for salt deposits or surface contamination (VI.A-9, 2 occurrences)

OC LRA effect: None -OC LRA states that high voltage insulators do not experience degradation of insulator quality due to the presence of salt deposits and surface contamination identified in NUREG-1 801. See OC LRA subsection 3.6.2.2.5 for further information.

24. R-04: Structure/component list revised to delete piping, piping components, and piping elements, heater sheaths and sleeves, pump casings and covers, and pressure housings; revised to add reactor vessel components, nozzles, and safe ends. Material list revised to delete CASS, presumably for the reasons listed for R-20 (SS and CASS share aging effects and mechanisms

-CASS only needs to be identified when thermal or neutron embrittlement is an issue) (IV.A1-6, 23 occurrences; IV.C1 -1 , 61 occurrences)

OC LRA effect: None -OC LRA uses the TLAA AMP in accordance with September 2005 GALL to manage this aging effect. September 2005 GALL added line item R-220 to address the piping, piping components and piping elements removed from R-04; the material, environment, aging effect/mechanism, and program (TLAA) for R-220 are the same as those invoked by the OC LRA.25. R-15: Deleted steel as a material from Isolation condenser components, SS remains as material.No change to programs (IV.C1-5, 2 occurrences)

OC LRA effect: None -both occurrences in the OC LRA are for the isolation condenser system and are for SS components, in accordance with September 2005 GALL.26. R-16: In the January 2005 Draft GALL, programs were ASME Section XI IWBIC/D for Class 1 components and Water Chemistry, with augmentation consisting of isolation condenser shell water temperature and radiation monitoring, and eddy current testing of tubes, and verification of effectiveness of the program; in the September 2005 Rev. 1 GALL, programs specified are Water Chemistry and One-Time Inspection (IV.C11-6, 2 occurrences)

OC LRA effect None -OC LRA credits inspections under Section XI ISI In lieu of September 2005 GALL's One-Time Inspection; Water Chemistry Is also specified.

In addition, OC has committed to isolation condenser shell water temperature and radiation monitoring, and eddy current testing of tubes, and verification of effectiveness of the program (as continues to be specified by GALL for the cracking aging effect under line item R-1 5), and these programs in conjunction with the large number of existing samples of components subject to the Water Chemistry and One-Time Inspection programs support the conclusion that the programs adequately manage the subject aging effect of loss of material.27. R-27: Deletes 'High-Strength" qualifier from the material, adds thermal effects, gasket creep, and self-loosening to mechanisms (IV.C1-12, 1 occurrence)

OC LRA effect: None -OC LRA uses the Bolting Integrity program in accordance with GALL to manage the loss of preload aging effect 28. R-53: Deletes CASS from material, presuriably for the reasons listed for R-20 (SS and CASS share aging effects and mechanisms

-CASS only needs to be identified when thermal or neutron embrittlement is an issue) (IV.B1-14, 20 occurrences)

Page 3 of 5 F-D. A' S h'l'ev'- Re co-ndli at i6n- b6c, k e'v' 0- 0-1" OK-D& -I I -;""I -I --1 I "I W -__I -, Z_ --, , " I'll I .11 I --- 11-1 I P.".I D sly eoclito ocRv00 22 06DfDa-Attachment 5 OC LRA effect: None -SS, CASS, and nickel alloy material components in the OC LRA identify this line item for cumulative fatigue, specifying the TLAA program, and continue to be in compliance with GALL.29. R-98: Adds inspection specifications for top guides if fluence exceeds the IASCC threshold amount (IV.B1-16, 2 occurrences)

OC LRA effect: None -OC has top guides that have exceeded the IASCC threshold

-the use of the R-98 line item in the LRA includes a plant specific note identifying that enhanced inspections are to be performed, and these inspections arn discussed in Appendix B for 8.1.9 (BWR Vessel Internals program).

The September GALL specifications are incorporated.

30. S-08: Adds treated water environment, was steam only (VUIl.B2-3, 2 occurrences)

OC LRA effect: None 31. S-13: Adds steel to SS for material of tanks (VII.E-32, 2 occurrences)

OC LRA effect: None 32. S-18: Deletes 'shell side" or tube side" specificity for heat exchangers (Vil.E-3, 14 occurrences)

OC LRA effect: None -Water Chemistry and One-Time Inspection programs are used as specified by September 2005 GALL 33. S-21: Deletes 'shell side" or tube side" specificity for heat exchangers (VlIl.E-2, 8 occurrences)

OC LRA effect: None -Water Chemistry and One-Time Inspection programs are used as specified by September 2005 GALL 34. S-23: Deletes "shell side" or 'tube side" specificity for heat exchangers, adds galvanic corrosion to aging mechanism (VlIl.E-6, 4 occurrences)

OC LRA effect: None -Closed Cycle Cooling Water program is used as specified by September 2005 GALL 35. S-25: Deletes 'shell side" or 'tube side" specificity for heat exchangers (VIII.E-4, 1 occurrence)

OC LRA effect: None -Closed Cycle Cooling Water program is used as specified by September 2005 GALL 36. S-33: Adds thermal effects, gasket creep, and self-loosening to mechanisms (VIII.H-5, 10 occurrences)

OC LRA effect: None -Bolting Integrity program is used as specified by September 2005 GALL 37. SP-16: September 2005 Revision 1 GALL deleted the PWR qualifier (VIII.D2-4, 44 occurrences)

OC LRA effect: None -OC LRA applied this line Item even though January 2005 GALL listed it as a PWR program. The OC LRA is In complia wce with the September 2005 GALL which removed the PWR qualifier.

38. SP-25: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VIII.D2-5, 10 occurrences; VI I.A-3, 26 occurrences)

OC LRA effect: None -OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs.

This is in compliance with September 2005 GALL.39. SP-38: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VIII.A-2, 12 occurrences)

OC LRA effect: None -OC LRA uses the corresponding Lubricating Oi Monitoring and One-Time Inspection programs.

This is in compliance with September 2005 GALL.Page 4 of 5 I D. -uReIoclation Doc Rev_00_20.

are Pnnt 75il D.Ashie -Recnciliaton DocRev,..O0U2206pdf P 'n *71;Attachment 5 40. TP-8: Galvanized steel removed from material, now only aluminum; aging effect/mechanism was loss of materialgalvanic corrosion, now None; program was Structures Monitoring, now None (III.B5-2, 1 occurrence; 111.81.2-3, 2 occurrences; 111.82-4, 26 occurrences)

OC LRA effect: None -OC LRA uses this itlem for galvanized steel material components with no aging effect and no program specified, explained with an "I" standard note. This is in conformance with September 2005 GALL, in which new line item TP-1 1 has been added to address the galvanized steel material removed from TP*8, and lists aging effect and program of None -None.41. T-14: Aging Management Program Description continues to specify Water Chemistry program and monitoring of the spent fuel pool water leve, and adds clarification of "in accordance with technical specifications and leakage from the leak chase channels' (III.A5-13, 2 occurrences)

OC LRA effect: None -OC LRA invokes the Water Chemistry program in continued compliance with GALL The OC spent fuel pool water level is a Technical Specification-controlled parameter.

Pool leak chase piping is routed to a monitoring location and includes individual valving to provide detection of any leakage. Oyster Creek will commit to monitoring any leakage at this location.

This remains in compliance with GALL.Page 5 of 5 LD. Ashley -Reconciliation Doc Rev 0 01L2206.pdf Pan 706p Dar1 c 7- il........w7.... OAFOO.N~ ...-.w ... .............................................

........ I I Attachment 6 AMR Line Items used in the Oyster Creek LRA which invoke Plant-Specific Programs Requiring Further Evaluation in both the January 2005 Drafi and September 2005 Revision 1 SRP if D. Ashlev -Reconciliation Doc Rev_0 01 2206.pdfP Page 773 Attachment 6 AMR Line Items used In the Oyster Creek LRA which invoke Plant-Specific Programs Requiring Further Evaluation in both the January 2005 Draft and September 2005 Revision 1 SRP Line Further Item January 05 Draft SRP September 05 Revision 1 Evaluation No. section SRP section Significant

_ __ _Change 1 A-09 3.3.2.2.10.2 3.3.2.2.10.5 No 2 A-16 3.3.2.2.5.2 3.3.2.2.5.2 No 3 A-17 3.3.2.2.5.1 3.3.2.2.5.1 No 4 A-17 3.3.2.2.13 3.3.2.2.13 NO 5 A-27 3.3.2_2.7.3 3.3.2.2.7.3 No 6 A-46 3.3.2.2.10.2 3.3.2.2.10.3 No 7 A-71 3.3.2.2.3.2 3.3.2.2.3.2 No 8 A-73 3.3.2.2.13 3.3.2.2.13 No 9 A-85 3.3.2.2.3.2 3.3.2.2.3.2 No 10 A-89 3.3.2.2.14 3.3.2.2.6 No 11 AP-33 3.3.2.2.3.2 3.3.2.2.3.3 No 12 E-06 3.2.2.2.5 3.2.2.2.5 No 13 LP-07 3.6.2.2.5 3.6.2.2..2 No 14 LP-08 3.6.2.2.6 3.6.2.2.3 No 1 5 LP-1 1 3.6.2.2.5 3.6.2.2.2 No 16 R-61 3.1.2.2.4.2 3.1.2.2.4.1 No 17 RP-18 3.1.2.2.11 3.1.2.2.11 No 18 SP-37 3.4.2.2.7.2 3.4.2.2.7.2 No Page 1 of 1

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