ML060790273

2005/09/08-Oyster Creek License Renewal Scoping and Screening Procedures ((Form CD-Rom) (PA)

ML060790273
Person / Time
Site:	Oyster Creek
Issue date:	09/08/2005
From:	Exelon Corp
To:	Office of Nuclear Reactor Regulation
References
%dam200604
Download: ML060790273 (363)

Text

Oyster Creek License Renewlal Project Project Level Instruction 1 Preparation of Project Level Instructions and Position Papers PLI-1 Rev. 3 Sheet 1 of 8 Oyster Creek License Renewal Project Project Level Instruction 1 Preparation of Project Level Instructions and Position Papers Oyster Creek License Renewal Project Project Level Instruction 1 Preparation of Project Level Instructions and Position Papers PLI-1 Rev. 3 Sheet 2 of 8 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio 5/28/04 Dave Honan Don Warfel 1 G. J. Beck Dave Honan Don Warfel 6/22/05 2 C.Micklo Dave Honan Don Warfel 8/24/05 3 S. B. Rafferty John Hufnagel Don Warfel 9/8/05 Revision Log Rev. Description of the Change 0 Initial Issue 1 Update references and exhibits 2 Addition of PLI-16 3 Updated for formatting reasons.

Oyster Creek License Renewal Project PLI-1 Rev. 3 Project Level Instruction 1 Sheet 3 of 8 Preparation of Project Level Instructions and Position Papers 1.0 Purpose This instruction describes the format and content of Project Level Instructions and Position Papers that are prepared for the Oyster Creek License Renewal Project.2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in preparing Oyster Creek License Renewal Project Level Instruction and Position Paper documents.

3.0 References 3.1 10 CFR Part 54 -The License Renewal Rule 3.2 NEI 95-10 Rev. 5 -Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule 4.0 Definitions Current licensing basis (CLB) -is the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations contained in 10 CFR parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73, 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications.

It also includes the plant-specific design-basis information de-fined in 10 CFR 50.2 as documented in the most recent final safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports.Aging Management Review (AMR) -An engineering process that identifies aging effects that apply to passive and long lived components associated with the systems and structures falling within the scope of 10 CFR 54.4(a) (1) through (3), identifies those programs (existing, enhanced, or new) which detect, monitor, prevent, and mitigate the effects of aging, and demonstrates that through the use of such programs the effects of aging will be adequately managed during the license renewal term.

Oyster Creek License Renewal Project PLI-1 Rev. 3 Project Level Instruction I Sheet 4 of 8 Preparation of Project Level Instructions and Position Papers Component

-A piece of equipment such as a vessel, pipe, pump, valve, relay, or pressure switch, etc. Components of a structure include clearly distinct features such as doors, walls and slabs. Components and materials collectively comprise a system or structure.

Component Type -Components of similar design and function are grouped together to perform aging management reviews based on similar materials, environment, and aging effects.Typically, these reviews are performed on a system or structure basis.Component Intended Function -The component intended function is the specific function of the component that supports the system intended function.Commodity

-A grouping of like structures or components comprised of similar material and exposed to similar environments, that can be dispositioned with a single aging management review. The basis for grouping structures or components within a single commodity group can be characteristics such as similar design, similar materials of construction, similar aging management practices, similar environments, similar service time or similar operating history, e.g., cable, piping supports, concrete.Functions

-Functions are the specific processes, conditions, or actions that a system, structure or component was designed to perform.Integrated plant assessment (IPA) -is a licensee assessment that demonstrates that a nuclear power plant facility's structures and components requiring aging management review in accordance with § 54.21(a) for license renewal have been identified and that the effects of aging on the functionality of such structures and components will be managed to maintain the CLB such that there is an acceptable level of safety during the period of extended operation.

Intended Functions

-define the plant process, condition or action that must be accomplished in order to perform or support a safety function for responding to a design basis event or to perform or support a specific requirement of one of the five regulated events in §54.4(a)(3).

At a system level, the intended functions may be thought of as the functions of the system that are the bases for including this system within the scope of license renewal as specified in §54.4(a)(1)-(3).

License Renewal Boundary Drawing -A drawing which identifies major components of a system or structure which perform or support the identified Intended Function(s).

A License Renewal Boundary Drawing can be a mark-up of an existing system drawing, electrical single line, or a simple structure location drawing.License Renewal Data Base -An electronic data base that contains component information necessary to document and evaluate whether systems, structures, and components fall within the scope of 10 CFR 54.4(a) (1) through (3) and to identify those components subject to aging management review.License Renewal Systems and Structures

-Those plant systems and structures, listed in Position Paper-O1, that are evaluated for License Renewal.License Renewal System Boundary -That part of the license renewal system that is in the scope of License Renewal.Long Lived -Those structures or components that are NOT subject to replacement based on a qualified life or specified time period and are anticipated to remain in service for the life of the plant.

Oyster Creek License Renewal Project PLI-1 Rev. 3 Project Level Instruction 1 Sheet 5 of 8 Preparation of Project Level Instructions and Position Papers Nuclear power plant -means a nuclear power facility of a type described in 10 CFR 50.21(b) or 50.22.Passive Components

-Passive components are those that perform their intended function(s) without moving parts or without a change in configuration or properties.

Scoping -The identification of systems, structures, and components that meet the criteria of 10 CFR 54.4(a)(1) through (3).Screening

-The process used to determine, for a system, structure or component within the scope of 10 CFR 54.4(a)(1) through (3), which structures and components require an aging management review.Short Lived -Those components or structures subject to replacement based on a qualified life or specified time period.Structure

-An arrangement of interconnected members that is capable of supporting its own weight and externally applied loads. A structure supports, encloses and/or protects electrical and mechanical systems so that these systems can perform their intended functions(s).

Sub-component

-A part or subassembly forming part of a component.

Support System -A system whose support is necessary for another system to perform its intended function(s).

System -A group of components united by some interaction or interdependence, performing many duties but functioning as an integrated unit.Time-limited aging analyses -are those licensee calculations and analyses that: (1) Involve systems, structures, and components within the scope of license renewal, as delineated in § 54.4(a);(2) Consider the effects of aging;(3) Involve time-limited assumptions defined by the current operating term, for example, 40 years;(4) Were determined to be relevant by the licensee in making a safety determination; (5) Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, and component to perform its intended functions, as delineated in §54.4(b);and (6) Are contained or incorporated by reference in the CLB.5.0 Prerequisites None.

Oyster Creek License Renewal Project PLIA Rev. 3 Project Level Instruction 1 Sheet 6 of 8 Preparation of Project Level Instructions and Position Papers 6.0 Instructions This section outlines the content and format of the Project Level Instruction and Position Paper documents.

6.1 Project Level Instructions contain the guidance for performing the tasks required to develop the License Renewal Application (LRA) and administrative functions.

The LRA satisfies the requirements of 10 CFR Part 54 and is consistent with NEI 95-10 (Industry Guidance for Implementation of 10 CFR 54 -The License Renewal Rule).6.1.1 The Project Level Instruction document includes a cover page and is followed by tables for approvals and revision log. A table of contents may be provided.

The following sections should be used: 1. Purpose 2. Applicability

3. References

4. Definitions

5. Prerequisites

6. Instructions

7. Exhibits 6.2 Position Papers contain the evaluation and basis for decisions made for adherence to the license renewal requirements.

6.2.1 The Position Paper document includes a cover page and is followed by tables for approvals and revision log. A table of contents may be provided.

The following sections should be used: 1. Purpose 2. Scope 3. Methodology

4. References

5. Attachments There may be an additional section for specific rule requirements.

6.3 The project level instructions for this project are listed in Exhibit 1. The position papers for this project are listed in Exhibit 2.

Oyster Creek License Renewal Project PLI-1 Rev. 3 Project Level Instruction 1 Sheet 7 of 8 Preparation of Project Level Instructions and Position Papers 7.0 Exhibits Exhibit 1 -List of Project Level Instructions Exhibit 2 -List of Position Papers Exhibit 1 -List of Proiect Level Instructions PLI-01. Preparation of Project Level Instructions and Position Papers PLI-02. Scoping of Systems and Structures PLI-03. Screening of Systems, Structures and Commodities PLI-04. Boundary Drawings PLI-O5Aging Management Reviews PLI-06. Time Limited Aging Analyses PLI-07. Not Used PLI-08. Aging Management Program PLI-09. Not Used PLI-10. Not Used PLI- I1 License Renewal Document Control PLI-12 Training of License Renewal Project Team and Site Personnel PLI-13 Not Used PLI-14 10 CFR 54.4(a)(2)

Spatial and Structural Interaction PLI-15 License Renewal Document Change Request Process PLI-16 Plant Design and Licensing Basis Change Review Oyster Creek License Renewal Project PLI-1 Rev. 3 Project Level Instruction I Sheet 8 of 8 Preparation of Project Level Instructions and Position Papers Exhibit 2 -List of Position Papers PP-01. License Renewal Systems & Structures PP-02. 10 CFR 54.4(a)(1)

Safety Related Systems PP-03. 10 CFR 54.4(a)(2)

System Scoping Criteria PP-04. 10 CFR 54.4(a)(3)

Station Blackout Systems PP-05. 10 CFR 54.4(a)(3)

ATWS Systems PP-06. 10 CFR 54.4(a)(3)

EQ Systems PP-07. 10 CFR 54.4(a)(3)

Fire Protection Systems PP-08. Structures, Component and Commodity Types, with Active, Passive Determinations and Intended Functions PP-09. Not Used PP-10. Not Used PP-1. Not Used PP-12. Not Used PP-13. Abnormal Operational Transients PP-14. Not Used PP-15. Standard Materials, Aging Effects and Internal / External Environments PP-16. Not Used Oyster Creek License Renewal Project Project Level Instruction 2 Scoping of Systems & Structures PLI-02 Rev.4 Sheet I of 36 Oyster Creek License Renewal Project Project Level Instruction 2 Scoping of Systems and Structures Oyster Creek License Renewal Project Project Level Instruction 2 Scoping of Systems & Structures PLI-02 Rev.4 Sheet 2 of 36 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 H. D. Honan K. P. Muggleston D. B. Warfel 1/16/04 1 K. P. Muggleston H. D. Honan D. B. Warfel 1/28/04 2 H. D. Honan K. P. Muggleston D. B. Warfel 4/21/05 3 H.D. Honan J. G. Hufnagel A.A. Fulvio 8/16/05 4 S. B. Rafferty J. G. Hufnagel D. B. Warfel 9/8/05 Exhibit 1 LR Database Scoping Input Form PLI-02 Sheet 3 of 36 Rev. 4 a Revision Log Rev. No. Description of the Change(s)0 Initial issue.1 Revised Section 6.7 to clarify identification of supporting systems.2 Revised Section 3 to update reference documents; revised Section 4 to update prerequisites; revised Sections 6.4 & 6.5 to call out Exhibit 4; updated Exhibits 1, 2& 3; added Exhibit 4 3 Revised Section 3 to update reference 3.3 to January 2005.4 Minor Formatting Error.

Exhibit 1 LR Database Scoping Input Form PLI-02 Rev. 4 Sheet 4 of 36 1. Purpose This instruction describes the process used to identify those systems and structures that fall within the scope of 10 CFR Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants (the Rule). This process is referred to as Scoping.The Rule states:§54.4 (a) Plant systems, structures, and components within the scope of this part are -(1) Safety-related systents, stnuctures, and components which are those relied upon to renzain fitnctional during andfollowing design-basis events (as defined in 10 CFR 50.49(b)(1) to ensure thefollowvingffunctions

-(i) The integrity of the reactor coolant pressure boundary;(ii) The capability to shutdown the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to those referred to in Sections 50.34(a)(1), 50.67(b)2, or 100.11 of this chapter, as applicable.

(2) All nonsafety -related systems, structures, and components wvhose failure could prevent satisfactory accomplishment of any of the finictions identified in paragraphs (a)(1)(i), (ii), or (iii) of this section.(3) All systems, stntctutres, and components relied on in safety analyses or plant evaluations to perform a fiuction that demonstrates compliance with the Commission

's regulations forfire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thennal shock (10 CFR 50.61), anticipated transients without scram (IOCFR 50.62), and station blackout (10 CFR 50.63).Design basis events are defined in §50.49(b)(1) as follows: Design basis events are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure functions (i) through (iii) of this paragraph

[these functions are the same as 10CFR54.4(a)(1)(i) through (iii)].

Exhibit 1 LR Database Scoping Input Form PLI-02 Rev. 4 Sheet S of 36 2. Applicability This instruction applies to Oyster Creek License Renewal engineers or subcontractors engaged in the preparation, checking, review or approval of scoping evaluations in support of license renewal activities for the Oyster Creek License Renewal Project.3. References 3.1 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" 3.2 NEI 95-10, "Industry Guideline on Implementing the Requirements of 10 CFR Part 54, Revision 5.3.3 Draft NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", January 2005 3.4 PLI-04, Boundary Drawings 3.5 PLI-1 1, License Renewal Document Control 3.6 PLI-14, Identification of Non-Safety Related Systems and Components Which Spatially or Structurally Interact With Safety-Related Systems and Components 1OCFR54.4(a)(2) 3.7 ANSI/ANS-52.1-1983, Nuclear Safety Criteria For The Design Of Stationary Boiling Water Reactor Plants 4. Definitions Definitions are provided in PLI-01, Preparation of Proiect Level Instructions and Position Papers 5. Prerequisites This instruction utilizes information contained in the following Oyster Creek License Renewal Position Papers: (1) PP-01 License Renewal Systems & Structures (2) PP-02 10CFR54.4(a)(1)

Safety Related Systems & Structures (3) PP-03 IOCFR54.4(a)(2)

System & Structure Scoping Criteria (4) PP-04. 54.4(a)(3)

Station Black Out Systems & Structures (5) PP-05. 54.4(a)(3)

ATWS Systems & Structures (6) PP-06. 54.4(a)(3)

EQ Systems & Structures (7) PP-07. 54.4(a)(3)

Fire Protection Systems & Structures (8) PP-13. Abnormal Operational Transients

6. Instructions This PLI provides direction on how the information needed to fill out System / Structure Scoping data fields in the Oyster Creek License Renewal Database (LR Database) should be developed.

The Exhib LRDa ,it 1 itabase Scoping Input Form [PLI-02 Rev. 4 Sheet 6 of 36 LR Database will be used to print out hard copy License Renewal System and Structure Scoping Forms for subsequent review, approval and retention.

Current licensing basis (CLB) documents must be utilized when determining whether a system, structure or component falls within the scope of 10 CFR 54.4(a)(1) through (3). The CLB includes documents such as the UFSAR, FDSAR; separate SBO, ATWS and Fire Protection submittals; Site Technical Specifications; Safety Evaluation Reports (SER's), the IPSAR and NRC orders. Other documents or databases such as the Component Record List (CRL), flow diagrams, electrical one lines, specifications, licensed operator training plans or Maintenance Rule Database may also be used to assist in system or structure scoping. However, reference documents or databases that are not CLB documents cannot be the sole basis for deciding whether a system or structure falls within the scope of 10 CFR 54.4(a)(1) through (3). In the event of differences between CLB documents and other documents, the CLB documents take precedence.

It is not necessary for the assigned license renewal engineer to follow the steps in this instruction in the order shown, as long as all steps are completed prior to approval of a System / Structure Scoping Form.Exhibit 1 depicts the License Renewal Database Scoping Input Form Exhibit 2 depicts a sample Scoping Form printed out from the database.Exhibit 3 is a flow chart of the LR Scoping process.6.1 Scoping of Systems & Structures A License Renewal System and Structure Scoping Form (Exhibit 1 or comparable) is used to document the scoping of each license renewal system and structure listed in Position Paper PP-01 to determine whether each system and structure falls within the scope of the Rule.Begin the scoping process by selecting a System and Structure Scoping Form for the license renewal system or structure to be evaluated from the LR Database.6.2 Basic System / Structure Information Enter (or confirm) the basic information found in the Position Papers, CLB, design documentation or other data sources into the LR Database Scoping Form. For each system or structure listed in Position Paper PP-01, complete the following fields of information in the License Renewal Data Base.(1) "License Renewal System Name", (pre-populated from PP-01)(2) "System Grouping" (pre-populated from PP-01)(3) "DBD Number", if applicable (select from pull-down menu)(4) Applicable "UFSAR Sections" (enter 2-digit section(s) numbers, e.g., 6.3, unless more pinpointed citations are appropriate)

(5) Applicable "Drawing" numbers (enter)(6) "Other Reference Documents" (enter; applicable Position Papers are pre-populated, for printing in the hard copy scoping form)

Exhibit 1 LR Database Scoping Input Form PLI-02 Rev. 4 Sheet 7 of 36 6.3 IOCFR54.4(a)(1) through (3) Scoping Criteria Address the scoping criteria set forth in lOCFR54.4(a)(1) through (3). For each license renewal system or structure listed in Position Paper PP-01, fill in the following data fields in the License Renewal Database Scoping Form, as provided in the associated Position Papers or PLI-02 steps: Note The systems identified in Position Papers PP-02 through PP-07 and PP-13 are based on ES-17 system designations.

When performing scoping, it is necessary to first refer to PP-01 to identify which ES-17 system(s) are included in the license renewal system being evaluated.

If any of the ES-17 systems identified in Position Papers PP-02 through PP-07 and PP-13 are included in the license renewal system listed in PP-01, then the associated scoping criteria for that license renewal system must be answered "Yes" in the LR Data Base.(1) "Safety Related and ensures RCPB integrity, maintaining shutdown, prevent or mitigate potential offsite effects?" Select Yes or No, per PP-02 & PP-13 (IOCFR54.4(a)(1))

(2) "If this is an NSR System, Does It Prevent SR System from Function?" No, per Steps 6.5, 6.7, 6.11 and PP-03. (IOCFR54.4(a)(2))

Select Yes or (3) "Relied Upon for Compliance with IOCFR50.48 Fire Protection?" Select Yes or No, per PP-07 (IOCFR54.4(a)(3))

(4) "Does SSC Demonstrate Compliance with EQ"? Select Yes or No, per PP-06 (lOCFR54.4(a)(3))

(5) "Relied Upon for Compliance with 1OCFR50.62 for ATWS?" Select Yes or No, per PP-05 (IOCFR54.4(a)(3))

(6) "Relied Upon for Compliance with IOCFR50.63 for SBO" Select Yes or No, per PP-04 IOCFR54.4(a)(3)

(7) If the answer to one or more questions is unknown, set the corresponding fields to BLANK until the answer is established.

Exhibit I LR Database Scoping Input Form I PLI-02 Rev. 4 Sheet 8 of 36 I Note The NRC regulation for pressurized thermal shock (IOCFR50.61) is not addressed because it is not applicable to boiling water reactors.6.4 System / Structure Functions Populate the "System Functions" field. Using CLB documents and other reference material, identify all of the functions that the system or structure is required to accomplish and enter into the LR Database Scoping Form "System Functions" field.The functions associated with the system or structure being evaluated are identified by reviewing the UFSAR and other CLB documents.

The preparer enters all functions found in the UFSAR, then supplement or clarify those functions by reviewing other applicable CLB and design basis documents.

(1) Obtain and/or access the following documents:

• Applicable UFSAR Section(s)

-The part that provides a functional description of the system/structure(s)

• ATWS, SBO, Fire Protection, or other NRC submittals separate from the UFSAR* Relevant Technical Specification or Bases Sections (if they contain information beyond what is included in the UFSAR Sections)* Applicable Maintenance Rule File(s)* Applicable Design Basis Documentation (DBD, drawings, specifications)

• Applicable Operator Lesson Plan(s) [System Descriptions]

• Other applicable documents or files (2) Using the above documents and files, identify the system or structure drawings which will form the basis for the associated license renewal boundary drawing.(3) Review the applicable UFSAR Section(s) and identify all functions included in the UFSAR.Enter the system functions into the database Scoping Form "System Functions" field. Use the standardized listing of system and structure functions in Exhibit 4 where possible.

Enter the UFSAR reference for each function in the "System Functions" field following each function.(4) Review other applicable NRC submittals on, e.g., SBO, ATWS, EQ and Fire Protection.

Enter all of the system functions into the database Scoping Form "System Functions" field. Use the standardized listing of system and structure functions in Exhibit 4 where possible Enter a CLB reference for each function in the "System Functions" field following each function.(5) Review the Maintenance Rule files and DBD (if any) and determine whether any system functions listed in the DBD or Maintenance Rule files were not previously listed. If so, add those additional functions to the "System Functions" field. Use the standardized listing of system and structure functions in Exhibit 4 where possible Add only the functions which are related to the license renewal system being evaluated.

Enter a Maintenance Rule or DBD reference for each function listed.

Exhibit 1 LR Datab ase Scoping Input Form PLI-02 Rev. 4 Sheet 9 of 36 (6) Clean up the functional descriptions collected above by editing and eliminating redundancy Identify the source of the functional descriptions by 1) listing one UFSAR section where it is contained (directly or indirectly), or 2) listing the source document for the function if the function is not described in the UFSAR.6.5 System Intended Functions (1) If any of the scoping questions from Step 6.3 are answered "YES", then populate the"System Intended Functions" field. From the set of functions identified in Step 6.4, identify the Intended Functions that are the basis for including the system or structure within the scope of the Rule. The "Intended Function(s)" are those system or structure functions that satisfy any of the scoping criteria listed in 1OCFR54(a)(1) through (3). The listing of system- and structure-level intended function descriptions found in Exhibit 4 were standardized based on Reference 3.7.Enter the intended functions into the "System Intended Functions" field. Add the scoping criteria that each "Intended Function" satisfies to the "System Intended Functions" field. In those situations where a function satisfies more than one scoping criteria, also list those additional scoping criteria.

Ensure that each intended function includes a reference to the CLB source document for that function.(2) Check the "Comments" field for indication left by others regarding the system's supporting functions.

Add any supporting functions to the "System Functions" field, and to the "System Intended Functions" field. Set the 10CFR54.4(a)(2)

NSR to SR scoping criteria field to "Yes".6.6 In or Out Of Scope of the Rule (1) Populate the "In Scope of LR?" field. Using the answers to the scoping questions from Step 6.3, determine whether the system or structure falls within the scope of 10 CFR 54.4(a)(1) through (3). If the answer to any of the questions is "Yes", then the system or structure falls within the scope of the Rule. Select "Yes" on the LR Database Scoping Form "In scope of LR?" field.(2) If the answer to the 1OCFR54.4(a)(1) through (a)(3) questions are "No", then the system or structure may not fall within the scope of the Rule, pending completion of the PLI-14 10CFR54.4(a)(2) evaluations addressed in Step 6.11.(3) If, following completion of the 1OCFR54.4(a)(2) evaluation, a license renewal system still has all "No" answer, then the system is not in scope of the Rule. Select "No" on the LR Database Scoping Form "In scope of LR?" field. Continue developing documentation for the out-of-scope system or structure by completing Steps 6.9, 6.10, 6.12 and 6.13.(4) In the "In / Out of Scope Because" field of the LR Database, enter a summary rationale for concluding that the system or structure being evaluated is in or out of scope of the Rule, e.g.,"The Core Spray System meets the scoping requirements of 10CFR 54.4(a)(1) because it is a safety-related system which is relied upon to remain finctional during and following design basis events. It meets 10CFR54.4(a)(2) because failure of nonsafety-related portions of the system could prevent satisfactory accomplishment offunction(s) identifiedfor 10CFR54.4(a)(1).

It also Exhibit 1 LR Database Scoping Input Form PLI-02 Rev. 4 Sheet 10 of 36 meets 10CFR 54.4(a)(3) because it is relied upon in the safety analyses and plant evaluations to perfonr afiunction that demonstrates compliance with the Commissions regulationsforfire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49) and station blackout (10 CFR 50.63). The Core Spray Systems is iot relied upon in any safety analyses or plant evaluations to perfonn a function that demonstrates compliance with the Cotmnission

's regulation for ATWS (lOCFR50.62).

" 6.7 Supporting Systems Note The purpose of the identification of supporting systems on the scoping form is to meet the requirements of 10 CFR 54.4(a)(2) with respect to functional supporting systems. The license renewal rule requires that we identify any non safety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the functions identified in 10 CFR 54.4(a)(1).

Supporting system review is not applicable to non-safety related 54.4(a)2 systems. For 54.4(a)(3) systems, supporting systems are identified in the associated position papers. As such, identification of supporting systems is NOT required for systems that are in scope of the Rule ONLY because they have a "YES" in the 54.4(a)(2) or (a)(3) scoping criteria fields. For those systems, proceed to Step 6.8 For each safety related [IOCFR54.4(a)(1)]

system in scope of the Rule, it is necessary to populate the "Support Intended Functions" fields in the LR Data Base Scoping Form. For each in-scope system, other license renewal systems or structures which provide the functional or physical support required to accomplish that system's safety-related (1OCFR54.4(a)(1))

intended functions from Step 6.5 must be identified, where:* FUNCTIONAL support includes, e.g., 480V power, instrument air, control air, cooling water, etc.

.Exhibit 1 PLI-02 LR Database Scoping Input Form Sheet 11 of 36* PHYSICAL support includes, e.g., structures that provide shelter, etc.* The identified supporting systems and structures may be safety related or no related.* Table 2 of Position Paper PP-13 may prove helpful in identifying supporting Populate the "Support Intended Functions" fields as follows: (1) List supporting systems in the "Support System" field(s) in the LR Data Base Form.(2) Identify the "Supporting Function(s)" performed by each supporting system and corresponding "Supporting Function" field. Enter "Yes" or "No" in the correspon The Support System Support This System In Performing its 10CFR54.4(a)(1)

I Function?" field. For "Yes" answers, populate the corresponding "How It Suppor Function" field.(3) All support systems with a "Yes" answer in the "Does The Support System Su System In Performing its 10CFR54.4(a)(1)

Intended Function?" field are within the Rule. Enter the following (or similar) into the "Comments" field of the LR Dat Scoping Form for the supporting system: "This system is required to support the <enter License Renewal System Name> syst perform its intended function(s)", followed by the initials and date of the commentez Note If a review of the operator training aids, CRL, single line diagrams and flow diagrams do not readily identify the source of electrical power to system components, consult the Project Electrical Lead for guidance.(4) The license renewal engineer assigned responsibility for scoping the supporting review the comments field and set a "Yes" or "No" in the 1OCFR54.4(a)(2) scoping 4 as appropriate.

6.8 License Renewal Boundary Drawings Rev. 4 n-safety systems.Scoping enter into the ding "Does ntended rts Intended pport This the scope of abase"m to system will criteria box, Note LR Boundary Drawings are NOT required to be created for the following:

-Those systems that are not within the scope of the Rule.-Those systems within the scope of the Rule that are primarily comprised of instrumentation and electrical components which will be analyzed using a commodities approach.

An electrical single line diagram will be prepared per PLI-04.-Individual structures within the scope of the Rule. A single site plan drawing showing in-scope structures will be developed per PLI-04.

Exhibit 1 LR Datab ase Scoping Input Form PLI-02 Rev. 4 Sheet 12 of 36 (1) Create License Renewal Boundary Drawings for mechanical systems. Boundary drawings identify the components that contribute to the system level functions identified during the scoping process. The license renewal system boundary may or may not match a normal system boundary.(2) For each mechanical system that falls within the scope of the Rule, develop boundary drawings as follows:* Review the "Intended Function(s)" of the system or structure and identify those portions that are necessary to accomplish the "Intended Function(s)".

• License Renewal System boundaries may not be defined by engineering (ES-17) system boundaries, safety class boundaries, flow diagrams or other drawings, or the CRL.* The process of creating boundary drawings is iterative, starting with the flow diagram(s) for the license renewal system being evaluated:

o The initial license renewal system boundary is the mechanical process (flow diagram) boundary.o Include all the components required to accomplish 1OCFR54.4(a)(1) functions.

o If necessary, modify the boundary to include components required to accomplish IOCFR54.4(a)(3) functions.

o If necessary, expand the boundaries in accordance with the results of the IOCFR54.4(a)(2) evaluations performed under Step 6.11.o Dialogue with license renewal engineers assigned responsibility for interfacing systems; agree on boundaries; use the "Comment" field to document decisions and rationale for designating interfacing components in or out of scope and adjust boundaries as appropriate.

• Assign unique license renewal drawing number(s) designated as LR-<ABCD>, where<ABCD> denotes the existing drawing numbers on which the LR Boundary Drawing is based. Existing sheet numbers will be retained.* Record the license renewal boundary drawing number(s) in the "System Boundary Drawings" field in the LR Database Scoping Form.(3) Coordinate boundary drawing markup activities with other LR Engineers who may be evaluating license renewal systems of which portions may be shown on the same drawing.(4) Following initial preparation, all license renewal boundary drawings must be compared to interfacing system boundary drawings and any boundary differences reconciled.

(5) Follow the instructions in PLI-04 to produce final license renewal boundary drawings for review & approval.(6)Review and approval of license renewal boundary drawings is accomplished in accordance with PLI-i 1.6.9 System Description, Operation

& Boundary Narratives Exhibit 1 PLI-02 Rev. 4 LR Database Scoping Input Form Sheet 13 of 36 Note Description, Operation and Boundary narratives do NOT need to address electrical

/ I&C parts of mechanical systems. These in-scope components are treated as commodities.

Based on the reference UFSAR sections, other applicable CLB references, and the system's or structure's Intended Function(s), develop narrative descriptions of the system or structure evaluated and its operation and what part (if any) falls within the scope of the Rule. These narrative descriptions are documented in the designated LR Database Scoping Form fields.(1) "System Description":

Purpose of the System or Structure, including a description of the part of the system or structure within the scope of the Rule. System descriptions for out-of-scope systems may be less rigorous than those for in-scope systems.(2) "System Operation":

Describe operation of the system. System operation narratives are NOT required for electrical systems, structures or out-of-scope systems.(3) "System Boundary":

Describe the boundary of the system or structure evaluated, based on the boundary drawing(s) for that system. Ensure that all mechanical "supporting system" boundaries are addressed.

System boundary narratives should also explain why parts of this system may have been included within the boundaries of other systems, and vice-versa.

System boundary narratives are NOT required for electrical systems, structures and out-of-scope systems.(4) Explanation of why parts of the system or structure are outside the scope of the Rule, if any.6.10 Scoping Comments Record any comments pertinent to the logic used in scoping a system or structure in the"Comments" field of the LR Database Scoping Form. These may include, but are not limited to notes indicating why parts of the system are not in scope of the Rule or that the system supports the performance of another system's intended functions.

6.11 10CFR54.4(a)(2)

Evaluations (1) Three types of interaction between non-safety related SSCs and safety related systems (NSR /SR) must be considered during the scoping process:* The functional or physical support provided by non-safety related SSCs which enables a safety related system or structure to perform its intended function, e.g., 480V power, cooling water or shelter. Step 6.7 identifies this type of support.* The interaction which occurs between non-safety related SSCs which are physically connected to a safety related system which could adversely impact the intended function(s) of the safety related system should they fail. PP-03 provides criteria for performing this evaluation.

• The interaction between a non-safety related SSCs which are NOT physically connected to a safety related system, but could adversely impact the intended function(s) of the Exhibit 1 LR Database Scoping Input Form safety related system due to their physical pr(performing this evaluation.

(2) Following the guidance in PP-03, perform the 1(related systems connected to safety related systems a potential spatial interaction with safety related syster (3) Factor the results of the evaluation into Steps 6.2 6.12 Review & Approval Once all fields of the LR Database Scoping Form ha'Engineer shall initiate the review and approval proce 6.13 Completion of Scoping Scoping is complete when (1) all plant systems and s process as described in this Instruction and hard cop)and approved in accordance with PLI-1 1, and (2) bot systems in scope of the rule in accordance with this i 7. Exhibits Exhibit 1 LR Database Scoping Input Form Exhibit 2 Sample System / Structure Scoping Form Exhibit 3 Scoping Process Flowchart Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 14 of 36 oximity. PP-03 provides criteria for)CFR54.4(a)(2) evaluations for non-safety and for non-safety related systems with ns.3 through 6.10 as appropriate.

ve been populated, the responsible LR ss defined in PLI-1 1.tructures have been subjected to the scoping y scoping forms have been prepared, checked indary drawings have been prepared for all nstruction and PLI-04.

Exhibit I LRZ Database Scoping Input Form PLI-02 Rev. 4 Sheet 15 of 36 oyster Creek License Renewal System Scoping Form-Safety-Related and ensures RCPB integrity, e-maintaining shutdown, (rr P2adP-3 prevent or mitigate I c fL? -~potential offsite effects?:

RYe Iflthis isflSRlSystem, Does it Prevent SR System from Y s Funton (Fom P3)In/Out of scope beca!,use:

Relid Uon fr --~The Core Spray System meets the scoping requirements ot* Wth1DCFR 54.4a~la) because ltis a safety-related system wlichris* CROm8 Firne PWothcrn (Fomelied upon to remain functional during anid folloing design banss 1 OFR5.48Fir Prtecion Ievents, ft meetsl1CFR54.4(aJ2]

becauseta~lke of nonsafety-related portions of the system could prevent satisfactory Does SSC Demonstrate 1 f.........Yes_3, i accompfshment offtunctionfsl identified forl10CFR54.4fa~lI It i Compliance with EQ? also meets1 OUR 54.4faI3]

because iostreied upon inthe f~rorn 6]atfsty analyses and plant evaluations to perform a function that demonstrates compliance with the Coriuissions regulations for*Relired Upon for F*si tre protectionflQ0CliR 50.481. environmrental qualification (1 0 CmplianceW't N.o i CFR5Qb49lardstationblackori(1OCFR50.631 The Core 100FSIJSforTWS? (Frm F'~5]Spray System is trot ereied upon in any safety analyses or plant Upon or *evaluations to perform a hanction that demonstrates compliance Comprancwrth I .with the Comrrission~s regulation for AT WS f1Q0CF50.6211 1 DCFRSO.63 for S'BO?I (FsomrPP-4]

usystetri'Des'cription:

[The Core Spray System (CSS] is a tow pressure Emergency Core Coofrng System fECCSJ designed to provide cooling water for removal of (decay heat fom the reactor core followiga postulated Loss-of-Coolant Accrdent (LOCAI Large-to-inlermediate ppelbreaks in the reactor (coolant system result in a reactor pressure reduction sufficient to peret the CSS to achieve its rated injechon flow prior to fuel cladding melt.--ITo accommodaite the remairing intermediate-to-smial pipe breaks, the Automatic Depressurization System provides the initial controlled

-depressurization to reduce reactor pressure, and thus permit rimely CSS riiection.

In tfis marnner, the CSS provides coe cooing such that fuef clad melting is prevented for the entire spectrurs of postulated LOCAs. The CSS provides a supply of cooling water to the reactor core wh-ich i, i-,i-ansMnrsnf iii th Feertici~te qinlemn And whirh i-sn hpInrs Ar-r-r An .r-npn, irr Oyster Creek License Renewal System Scoping Form* [The purpose of the CSS is to provide tor the post-LOCA removal of decay heat troms the reactor core so thet fuel clad melting is prevented for Ithe entiespetu fpsuae O~.TeCSsse co~fse hsproeb eieigalwpesr pa atr vrtefe folwigaLOA imiting peak cldtemperature.

The CSS operar on is initiated autonmatically by either reactor low-tow watre level or high .~drywellpesrt o cnb ntae manually.Sysem peritin:She CSS ris compeised of rwo independent toops. Each top consists or two main purips. two booster pumrps, and associated spi~ng, valves, instrumentarion, and controls.

Main pump suction is through strainers located in the torus fevatuated wirth the Cor-tainmernt Spray System], and 21 booster pu-rp discharge is through the system isolation valves kilto Spray spargers located inside the reactor shroud (evaluated with Reactor InenllEach CSS loop contains tull tlow test, keep-lill.

and rinniurrrn flow pump protection teatries.

Flow and pressure instrumentation are I.. : .provided in the control room for each loop. An motor operated valves in the mainttowpath of each loop ate normallyopen during system Jstandby, with the exception ot the parallel system isolation valves located ortside the drywell The core spray system piping and components 2A 4f in the pressure boundary are considered an extension of the primary containment boundary.tiitiation of both loops of the CSS occurs upon receipt of a high dra we! pressure or low-low reactor vessel level signal These signals also start ii I ~both Emergency Diesel Generators IEDtGsL in order to supply power to the Core Spray prar-ps to the event of loss ot normal electsic power Supply. The CSS can also bekiltiated manuiatly.

If the suction anddischarge valvesct antfive reciculalion loops are closed, alevel reduction in the core region witl riot result to a corresponding level reduction in the downcorser where the low-tow reactor vessel level is measured.

For I t-is reason, the suction and discharge valves of at least one recircutation toop are required to be open when CSS is reguired to be operable as bysm on~ r h S cp bobo aundary begins with the attachment pornts ot the main pu-rp suction hines to the irig header corrmon to the CSS and I -Containment Spray System suction piping. It continues through the main CSS pumrps' suction lin~es, through the main pumps and booster Bpumsps to the discharge piping, where cacti CSS toop attaches to a reactor vessel nozzle. Included in this boundary is a Ufil tow test tine on-.each loop from the common header downstream of the booster pumps to its attachment to the torus-fto-dywel vacuesr relief piping= Also pumrp back kilto the main pumrp discharge line, cndexts the CSS main flowpath piping though the sminirmumr flow return nine attached to the fill How test line. The CSS boundary includes the parallel motor operated system isolation valves outside containmient, the paraflel testable check lines described above. The alternte water suppflytow path boundarymwih the Condensate Storage and Transfer System is atthe interlace i'1.located on the CSS main pump corrarunosuctionktie.

Thealternate watertsupply boundary with the FieProtecton System is atthe normal-closed manual isolation valves where the pipir-g cot-nects to the suction of Loop I booster pu-rps and the discharge of Loop 11 booster pumps. ~The boredaainsswith the Post Accident SamoirrnaSvstem IPASS extend to thefCostvalve ofthe PASS downstream of each ofthe samrotno ytmFntions 1.Povid eemergency core cooling where the eqrApment provides coolant deectipto the core. The CS5 provides the ECCS fur-acionitoImit peak clad temperatures below 2200) deg F, maintain local oxidization of clad to a thickness not exceeding 17% of unosidized clad, Eimit hydrogen generation from the metal-water reaction to net greater that- 1 % of the calculated value for the total metal-water reaction hydrogen generation, maintain a coolable geometry, and provide tong term costing Miniirriurs flow capability providles pu-rp protection to assure capablity otECCS function.

fIJFSAFI 6.31.31 1 0FR54.4(aXl1f Exhibit 1 LR Database Scoping Input Fonn PLI-02 Rev. 4 Sheet 16 of 36 Oyster Creek License Renewal System Scoping Form..System Intended Functions Comments I 1. Provide emergency core cooling where the equipment provides coolant directly to the core. Operates withADS to accommodate entire spectrum ot postulated LOCA breaks. Mirimum ilow capability provides pump protection to assure capabrlity of ECCS tunction 1OCFR54.4(aXl]

2 Provide primary containment boundary.

10CFR54.4(ajll)

.Prnvidtes rn.er r.nntnit rwe..r h rr atru 1PfllTRS4 4lI1 1. CLOSED -The Core Spray/Automatic Depressurization System JADSI has been separated into two separate systems tar the purpose ot License Renewat Scoping This Scoping Form covers the Core Spray System only. The Automatic Depressuization System will be covered under another Scoping Form. D. MacIsaac.

12/04/02 2. CLOSED -The Torus. Torus strainers and ring header are not ir the scope of the Core Spray System D. Mactsaac.

12/04/02 3. CLOSED -License Renewal Boundary lOt the inteflace between the Core Spray System and the Condensate Transfer System is located at the downstream lace ot valvesV-11-1 11.V-11-109

[see drawing BR 2004 sht. 21 and the upstream lace oaV-20-1 (see drawing GE 885D7811 D. Macisaac.

12/05/02 4. CLOSED -License Renewal Boundary for the interlace between the Core Spray System and the Fire Protection system is located at the upstream lace oa valves V-9223 and V-9-232 (see drawing LR-GE 885D781 sht. 11 D. Macisaac.

12/05/02 5.CLOSED -License Renewal Boundary for the interlace between the Core Spray System and the Post Accident Sampling System is located at the downstream lace of valves V-11-1 04. V-20}28 and the upstream lace oa V-20-105 (see drawirg GE 885D781 shL 1 ID.Mactsaac.

12/05/0Z 6. CLOSED -Supports Intended Function:

Provides alternate source of makeup water from torus to 211 isolation condensers.

S. Getz 1/15/04.7. CLOSED -Resolution required regarding nomenciature/defnilon for the parallel system isolation valves. Are these "Containment Isolation i Oyster Creek License Renewal System Scoping Form 7. CLOSED -Resolution required regarding nomenclattee/delinition tor the paratel system isolation valves. Are these "Containment Isolation Support Intended Function -*.Support System Supporting Function Does the Support How It Supports System support this Intended system in performing Function its lOCFR 54.4(a)(1)

Intended Function?.FireProtection System .:J Provides alternate source No j Backup source of I ..of water if torus is not injection water. Not_ Condensate Transfer J IProvides means of F l Yes I The Condensate System I_ transferring CSS water to lTransfer System _t._ l A-CSystem

! Provides power to Booster .l Yes lProvides Booster.l_ .-Pumps, Fill Pumps and Pump Motor, FilllPnmary Containment

Torus provides safety- .lYesj l Torus provides related source of water for -safety-related 14160V AC System :: Provides power to Core Yes i l Provides Core.I ..iSpray Main Pump Motors. Spray Main Pump t R cori i4 1' 'F TlT;,lof t. 41; 4 Exhibit 2 Sample System / Structure Scoping Form PLI-02 Sheet 17 of 36 Rev. 4 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Core Spray System Engineered Safety Feaures Part of System Grouping Ini Scopefor License Renewi: Yes Approvals:

Preparer: Rev ever: Site Reeviewer:

-LR Technic Lead:-

Exhibit 2 Sample System / Structure Scoping Form I System DescriptiontScopinp SummarV: PLI-02 Rev. 4 Sheet 18 of 36 System

Description:

The Core Spray System (CSS) isa lowpressure Emergency Core Cooling System (ECCS) designed to provide cooling water for removal of decay heat from the reactor core following a postulated Loss-of-Coolant Accident (LOCA). Large-to-interm ediate pipe breaks in the reactor coolant system resul in a reactor pressure reduction sufficient to perm it the CSS to achieve its rated injection flowprior to fuel dadding melt. To accommodate the remaining intermediate-to-small pipe breaks, the Automatic Depressurization System provides the initial controlled depressurization to reduce reactor pressure, and thus permit tim ely CSS injection.

I n this manner, the CSS provides core cooling such that fuel dad melting is prevented for the entire spectrum of postulated LOCAs. The CSS provides a supply of cooling weter to the reactor core 'Ahich is independent of the Feedvater System and Mhich can be operated on emergency pover.The purpose of the CSS is to provide for the post-LOCA removal of decay heat from the reactor core so that fuel dad melting is prevented for the entire spectrum of postulated LOCAs. The CSS system accomplishes this purpose by delivering a low-pressure spray pattern over the fuel folloy'ing a LOCA, limiting peak dad temperature.

The CSS operation is initiated automatically by either reactor Iowolowwater level or high dry'Aell pressure, or can be initiated manually.The CSS is a to-loop system. No single failure in the CSS can cause both loops to malfunction.

Operation of the CSS loops is credited in the 1 OCFRS0 Appendix K evaluation.

System Operation:

The CSS is comprised of tFo independent loops. E ath loop consists of tAo m ain pumps, tW booster pum ps, and associated piping, valves, instrum entation, and controls.

Main pump suction is through strainers located in the torus (evaluated

%ith the Containment Spray System), and booster pum p distharge is through the system isolation valves into spray spargers located inside the reactor shroud (evaluated with Reactor Internals).

E ah CSS loop contains full flowtest, keep-fill, and minimum flowpump protection features.

Flowand pressure instrumentation are provided inthe control room for each loop. Pil motoroperated valvesinthe main 1o'Apath of eath loop are normally open during system standby, with the exception of the parallel system isolation valves located outside the dryAell .The core spray system piping and components in the pressure boundary are considered an extension of the primary containm ent boundary.Initiation of both loops ofthe CSS occursupon receipt of a high dryvell pressure or low-lowreactor vessel level signal. These signals also start both Emergency Diesel Generators (EDGs), in order to supply poAer to the Core Spray pumps in the event of loss of normal eledric pover supply. The CSS can also be initiated manually.

If the suction and discharge valves of all five recirculation loops are dosed, a level reduction in the core region 'ill not resul in a corresponding level reduction in the dow-comer where the low-lowreactor vessel level is measured.

For this reason, the suction and discharge valves of at least one recirculation loop are required to be open WMhen CSS is required to be operable as an E CCS system. Once the reactor pressure drops belowa preset value and the CSS actuation signal is present,the parallel motor operated system isolation valves receive a permissive signal to open. Opening of the parallel motor operated system isolation valves completes the floApath, and injection water from the tWo loops entersthe vessel through tmo penetrations.

Inside the vessel, eath line extends half may around the outside of the core shroud with one loop penetrating the shroud above the other. The core spray spargers inside the shroud (evaluated Wth Reactor pago 2 of 11 Rs yliIonl No: D1 Psg. 20111 Riviulon No: D Exhibit 2 Sample System / Structure Scoping Form PLI-02 Rev. 4 Sheet 19 of 36 Internals) consist of tA 1 80-degree segments.

Thus each sparger forms a complete circle above the core.The main flovApath for each CSS loop is suction from the torus through one of teto main pumps, continuing through one of two booster pumps, through the outboard parallel system isolation valves, throughthe inboard parallel testable check valves, and into the reactor vessel for discharge onto the core through the associated spray sparger. Each of the parallel valves has 100% flowcapacity, so active failure of one valve Wil not result in insufficient flow. Upon receipt ofthe initiation signal, one preferred main pump in each CSS loop starts.Should either of these main pumps fail to start, the second main pum p in that loop vxill receive a signal to start.Upon sensing both an actuation signal and a discharge pressure signal of its associated main pump, the preferred booster pum p wlI start. If the preferred booster pump in either loop fails to start, the alternate booster pump in that loop wil receive a signal to start.Alter CSS flowhas been established into the vessel, the torus provides an essentially unlimited supply of cooling water. Water discharged from a pipe break inside the dryAell SlI overflowthrough the dryvtell vents into the torus. An alternate supply of cooling water for the CSS isthe Condensate Storage Tank through locked dosed manual valves located at the suction of each CSS main pump. The Fire Protection System is also capable of delivering water to the reactor vessel using CSS piping. During CSS operation, the heat being absorbed bythe waterthat flowsback tothe Torusistransferredto the Ultimate Heat Sink bythe heat exchangers inthe Containment Spray System.The primary water supply piping forthe CSS isattachedto suction strainers in thetorus (evaluated wththe Containment Spray System). The water in thetorus is dravnthroughthree strainers into a common header.Thisheaderalsofeedsthe ContainmentSpraySystem pumps. EachCSS comerroom pump compartment is provided vkith coolers sized to extract the heat generated by pum p operation.

Cooling water supplied to these coolers is evaluated Wththe Reactor Building Closed CoolingWater System. Air flowpath forthese coolers is evaluated

'Mh the Reactor Building Ventilation System. Operation of these coolers isnot required to support the CSS safety-related function.For more detailed information, see UFSAR sections 6.3.1 and 6.3.1.3.)vstPm Rniinrl rv-The CSS scoping boundary begins vfith the attachment points of the main pump suction lines to the ring header common to the CSS and Containment Spray System suction piping. It continues through the main CSS pumps'suction lines,through the main pumps and booster pumpstothe discharge piping, where each CSS loop attaches to a reactor vessel nozle. I nduded in this b oundary is a full flowtest line on each loop from the common header downstream of the boosterpumpsto itsattachmentto thetorus-to-drywell vacuum relief piping. Also induded is each loop's keep-fill piping v'.ich takes suction from the discharge of a CSS main pump in each loop, continues through the fill pum p back into the main pump discharge line, and exdts the CSS main tovpath piping thoughthe minimum flowreturn line attachedtothe full flowtest line. The CSS boundary includesthe parallel motor operated system isolation valves outside containment, the parallel testable check valves inside containment, and associated piping, components, and instrumentation on each of the main flo'spath, test, fill, and minimum flowlines described above. The alternate water supply towpath boundary Wth the Condensate Storage and Transfer System isat the interface located onthe CSS main pump common suction line. The alternate mwter supply boundary 'Mth the Fire Protection System isat the normally dosed manual isolation valves verethe piping connectstothe suction of Loop I booster pumpsandthe discharge of Pago S of I I Rotation No: O Page Sot 11 Revitlon No: 0 Exhibit 2 Sample System / Structure Scoping Form J I1Seet it oJ at Loop 11 booster pum ps. The boundaries Wth the Post Accident Sampling System (P ASS) extend to the first valve of the PASS downstream of each of the sampling connectionsto the CSS at the suction of the Loop I main pumps suction header and on the discharge of the Loop I booster pumps.Also induded in the license renewal scoping boundary of the Core Spray System are those portions of nonsafety-related piping and equipment that extend beyond the safety-relatedknonsafety-related interface up to the location of the first seismic anchor, orto a point no longer in proximityto equipment performing a safety-related function, %Ahicheveer extends furthest.

This includesthe nonsafety-related portions of the system located v!Athin the Reactor Building and P rimary Containm ent. Ind uded in this boundary are pressure retaining components relied uponto preserve the leakage boundaryintended function ofthisportion of the system. For more information, referto the License Renewal Boundary Drawng for identification of this boundary, shown in red.Not induded in the scoping boundary of the CSS are the suction strainers and piping located inside the torus, andthe ring (suction) header, Which are induded inthe Containment SpraySystem scoping boundary.

Also not included are the piping and spargers located inside the reactor vessel, Mkich are included in the Reactor Internals scoping boundary.

Not induded in the CSS license renew~al scoping boundary are the follo wing interfacing systems, Which are separately evaluated as license renewal systems: Automatic Depressurization System Prim ary Containment System Condensate Storage and Transfer System Fire Protection Systems Reactor Internals Post Accident Sampling System Containment Spray System Page 4 of lIl Rs yal I on No: 13 Page 4otlI Revision No: 0 Exhibit 2 PLI-02 Rev. 4 Sample System / Structure Scoping Form Sheet 21 of 36 ScopinQ Questions 1.) Is mie system orstuctresat1-rebtedamd tiedipnk t vm31i MnMlalcadurlkgandtIbliligdes

-Yes bassreuemts 43s delned Is I0CFRSO.t9$)()t ekSire mde tlbwihg: Tie imtegtr fotie reactrcooaimtpress ft ebol mdarvr IDWFRS3.4to(tF; Tie capabibts ID5i tlw tie reactramd malIth in asat si m Iowa coadI#Mb1 DCFRS4.4@(t QD Tie capabit-btprewitormlmat l t e corseq eaces otackieatwis co il reslth polaefIoIttIt expomse I comparable tiose reterred t lb 1DFRSJ32to0 0).6D7 .or 100.11 as appIb '?2.) i tie system orstrctu re mohta$r rehted wiicee flire wotli preue ktne sa1tselatrf Yes azoomplttIme atofakyofte tiree satty reMted1u In kgs listd h quesMtb I? I ECFP.54@0 Y 3.5 IS -me rystem orstrip re reIkd oh 1 safert anases orpbiteual3at0bks b pe rrorm a Inotni that Yes demoistbAs complbic ewim NRMs regubtbis trflre Protc1on (OOCFRS.t4,?

1DZFRSL.4te 43 Is lie system orstrich re reIkAd o I1 safet aaha)ses orpb1teualaatbIs IpDue rorn a ncia tiat Yes chmostnAs comptiace witn NM's regulittis trEmulronmentfllaallratlni (ItCF1SJ.4$)?

10CFR34.4Q)

5. ) Is tie system orsticti re relled o II sate-V at alses orpb1teul3atbIs ti pe rorM a n1ctnb that No demomstfsA complLne wltH Ne Is regir3tbis brAmtbpated Taissle it W HioitScram Q DCFRSOZ.6?

10CFRSFt.t4AQ)

C.) Is ie system orstrchre relekdom Ik sater akailses orpbiteualiatois bpertorm a iocfk tiat Yes demokstalscomplnnoe wilt NFCYs regil3tbhs trSt*tm ti ctoit IDFPS.&f 1DCFRS4JY0s Scone Determination Dc'estesysem orstrsoture tllwlll tiescope ot10CFR PartSt? Yes Qttie asswertanyotme questias Iltd b (1-6 rYertietlezstm orstnchre tit wlkitie sope of 10CFRSi)Reason for Scone Delernination:

The Core SpraySystem meetsthe scoping requirements of IOCFR 54.4(a)(1 )because it is a safety-related system 'Alich is relied upon to rem ain functional during and followng design basis events. It m eets 1 OCFR54.4(a)(2) because failure of nonsafety-related portions ofthe system could prevent satisfactory accomplishment of fundion(s) identified for IOCFR54.4(a)(1).

It also meets 1OCFR 54.4(aX3) because it is relied upon inthe safety analyses and plant evaluationsto perform a function that demonstrates compliance Withthe Commissionsregulations for fre protedion (10 CFR 50.48), environmental qualification (10 CFR 50.49)and station blackout (10 CER 50.63). The Core SpraySystem isnot relied upon in anysafety analyses or plant evaluations to perrm a function that demonstrates com pliance v4th the Comm ission's regulation fbr ATWS (1 OCFR50.62).

Page Sotil Revinlon No: 0 Pac 5so? II Rs Yv Ilon No: G Exhibit 2 Sample System / Structure Scoping Form System Functions PLI-02 Rev. 4 Sheet 22 of 36 I. Provide emergency core cooling 'Ahere the equipment provides coolant directlyto the core. The CSS provides the ECCS function to limit peak clad temperatures below2200 deg F, maintain local oxidization of clad to a thickness not exceeding 17% of unoxidized clad, limit hydrogen generation from the metal-water reaction to not greater than 1 % of the calculated value for the total metal-wnater reaction hydrogen generation, maintain a coolable geometry, and provide long term cooling. Minimum ilowcapability provides pump protection to assure capability of ECCS fundion. (UFSAR 6.3.1.3) 10CFR54.4(aX1)

2. Provide primary containment boundary. (UFSAR 6.3.1.3) 10CFRS4.4(a)(1)

3. Reactor Coolant Pressure Boundary (UFSAR 6.3.1.3.2) 1 0CFRS4.4(a)(1)

4. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function. (UFSAR 6.3.1) 10CFR54.4(a)(2)

5. Relied upon in safety analyses or plant evaluationsto perform a function that dem onstrates compliance VLth the commission's regulations for Station Blackout (10 CFR 50.63) 1 OCFR54.4(a)(3)

6. Relied upon in safety analyses or plant evaluationsto perform a fundion that demonstrates compliance vith the commission's regulations for Fire Protection (10 CFR 50.48) 1 OCFR54.4(a)(3)

7. Relied upon in safety analyses or plant evaluations to perform a function that dem onstrates compliance

%dith the commission's regulations for Environmental Qualification (10 CFR 50.49) 10CFR54.4(a)(3)

8. Rem ove residual heat from the reactor coolant system. Provides a safety-related backup source of condensing (cooling) waterto the Isolation Condensers

-- credited during SBO and some external events.(UFSPR 6.3.1.1.2) 1 OCFR54.4(a)(1) and (a)(3)9. Provides abilityto test system function in accordance with Technical Spedfications requirements. (UFSAR Sections 6.3.1.3 and 16.2)System Intended Functions:

1. Provide emergency core cooling where the equipment provides coolant diredlyto the core. Operates 'fth ADS to accommodate entire spectrum of postulated LOCAbreaks.

Minimum lowcapabilityprovides pump protection to assure capability of ECCS function.

I OCFR54.4(a)(1)

2. Provide primary containment boundary.

I OCFR54.4(aXl)

3. P rovide reactor coolant pressure boundary.

1 OCFR54.4(a)(1)

4. Resist non-safety related SSC failure that could prevent satisfactory accomplishm ent of a safety related function.

10CFR54.4(a)(2)

5. Relied upon in safety analysesor plant evaluationsto perform a functionthat demonstratescompliance with the commission's regulations for Station Blackout (10 CFR 50.63) 1OCFR54.4(a)(3)

6. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance nth the commission's regulations for Fire Protection (10 CFR 50.48) I0CFR54.4(a)(3)

7. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance fith the commission's regulations for Environmental Qualification (10 CFR 50.49) 1OCFRS4.4(a)(3)

8. Remove residual heat from the reactor coolant system. Provides a safety-related backup source of condensing (cooling) waterto the Isolation Condensers.

1 OCFR54.4(aX1) and IOCFRS4.4(a)(3)

Page 60th Revimlon No: U Page G Of II Rs yli Ion No: O3 Exhibit 2 Sample System / Structure Scoping Form PLI-02 Rev. 4 Sheet 23 of 36 Identification of Supiportingi Systems: Support System Supporting Function Doesthe Support Howlt Supports System support this Intended system in performing Function its 1 OCFR 54.4(a)(1)

Intended Function?Fire Protection System P rovides alternate source of I JNo Backup source oflY4 erift rusisnotavailbble i injection water. Not credited for 1OCFRS4.4(a)(1) function.PCondensate Transfer rovides means of I Yes, The Condensate System i transferring CSS waterto Iso Transfer System Condenser.

Also provides provides a flovpath alternate source of CSS for transferring CSS water if torus is not available.

water from the torus o the iso condensers as a backup safety-related water supply for IC, which is a 1OCFR54.4(a)(1) function.In addition, the Condensate Transfer System also provides a backup source of injection vater for CSS. This is not credited for CSS 1 OCFRS4.4(a)(1) function.l480VAC System Provides power to Booster ! Yes j Provides Booster Pumps, Fill Pumps and Motor Pump Motor 1 Fill Operated Valves. P um p Motor and Motor operated Valves Motor P over.Loss prevents P3gs 7 o1 1 ROYIIIOn NO: a Paa. 10111 Revillon No: 0 Exhibit 2 Sample System / Structure Scoping Form PLI-02 Rev. 4 Sheet 24 of 36 booster pump and fill pump operation and causes valvesto fail in as-is position.IPrimary Containment i Torus provides safety-related J Yes Torus provides safety-'__ _ source of water for injedion.

related source of DryAell provides housing and water to perform support for piping and Decay Heat Removal components.

__, _ function.

Drywell houses and supports piping and components located inside the drywell. _4160V AC System IProvides power to Core l Yes Provides Core Spray__ ISprayMain PumpMotors.

Main Pump Motor i Povier. Loss results in failure of Core Spray Main Pumps to operate.FReactor Protection System !Processes Containment l Yes Positions core spray___ _ ilsolation sicnals.__

system isolation valves and provides initiation signal to CSS logic. Loss results in failure of valves to open upon demand and loss of CSS function.l1 25V Station D C System IProvides CSS pump controls l Yes Provides power toland logic initiation logic and to CSS pump controls.Loss results in failure of CSS fundion.Building Provideshousing and lYes Housesand supports I support for piping and piping and components.

__ components located outside the prim ary containment in the reactor building.Page a of I11 ReYlflon No: a Page 50111 Revillon Na: U Exhibit 2 Sample System / Structure Scoping Form PLI-02 Rev. 4 Sheet 25 of 36lComponent Supports IProvides support for system J__Yes Supports CSS pipinglpiping and components.

and components.

IReactor Building Closed I Provides cooling Neterto No Provides cooling Cooling Water System iroom coolers. _ _water tothe corner room coolers. Not required for support of 1 OCFR54.4(aXI) function.Containment SpraySystem Coolstorus IProvide s cooling of torus IYes li __n__ !inventory.

Core Spray rem ove s de cay heat from the reactor and transfers it to the orus mater.Containment Spray cools the torus waeter by transferring heat o ESW and UHS.Containment Spray piping includes torus strainers and ring header hich also provide suction source from torus for Core Spray pumps.jAutomatic jSupports CSS in performing r e PADS is required to DepresSur;Zation System !ECCS function.

-_ depressurize the reactor for small break and some interm ediate break LOCAs to permit CSS injection at rated A owbefore core melt.Reactor Building l U rovidescoolingto crner lNoi Unit coolers provide I Ventilation System Irooms. _ __ __ colingtothecorner rooms. Not required for support of 1OCFRS4.4(a)(1) function.

_Page Dot 11 Revimlon No: U PHg$ of 1T I1 Rs yv I on No: O Exhibit 2 Sample System / Structure Scoping Form PLI-02 Rev. 4 Sheet 26 of 36 FContainment Vacuum : Provides return path to torus I Jreakers for m in-f owand full- flowtesti line pipinq ....! Full flowtest lines from each CS loop attach to vacuum breaker piping to complete return path totorus. Min-flow path also usesthis return piping. The minimum flow function and greater flowthrough the full flowreturn piping during extended CSS pump operation Wkhile not injeding into the RP V is credited to support CSS operability._______-

Page 10 ot ii Rsvlulon No: U Pago to of 11 Rem[ l I on No: 13

.Exhibit 2 Sample System / Structure Scoping Form PLI-02 Sheet 27 of 36 Rev. 4 Referen ces: UFSAR Section: DBD Number: B oun dawy Drawings: 6.3 SDBD-OC-212A (LowPressure Core Spray)LR-GE-855D781 LR-GU-3E -243-21-1000 LR-BR-2004 sheet 2 PID: GE885D781 Other References PP-01 License Renev"aI Systems and Structures PP -02 54.4 (a)(1) Safety R e lated System s PP-03 54.4(a)(2)

System Scoping Criteria PP-04 54.4(a)(3)

Station Black Out Systems PP-05 54.4(a)(3)

ATWS Systems PP-06 54.4(a)(3)

EQ Systems PP-07 54.4(a)(3)

FireProtectionSystems PP-11 Piping and Equipment Insulation PP-13 Abnormal Operational Transients Procedure P LI-02, Scoping of System sand Structures TDR-1 099, Station Blackout Evaluation Report.Procedure 2000-ABN-3200.37, Station Blackout DraAing BR 2002 D raving GE 148F 262 Page 11 of 11 Re vl Imlon No: O Exhibit 3 SystenmStructure Scoping Process PLI-02 Rev. 4 Sheet 28 of 36 , .6.1 Select a System Or Structure 6.2 Identify & Enter Basic b System / Structure Information 6.3 Address 54.4(a)(1)

-(3)Scoping Criteria IJ 6.4 Identify & Enter System / Structur Functions I Pe W 6.5 Identify & Enter Intended Functions.'A L 6.11 10CFR54.4(a)(2)

Evaluation per PP-03-NSR Connected to SR Systems-NSR Spatial Interaction w/SR Systems Description only req'd for structures and electrical systems Marked up site plan for structures 6.9 Develop & Enter System / Structure Description, Operation

& Boundary Narratives 4-6.8 Develop License Renewal Boundary Drawing 4, Required Changes 6.7 Identify & Enter Supporting System Info yes In Scope of ule No Not required for S/S with YES' to (a)(2) or (a)(3)ONLY 6.10 Enter Additional Comments, If Appropriate 6.8 Boundary Drawing Production Per PLI-04 6.7 Add Note to Comment Field of Supporting System Scoping Form 6.9 Develop & Enter System / Structure Description Narrative A L.6.8 Boundary Drawing Reconciliation

.No All YYes coping Scoped ~ ~ oipleteet Description only req'd for structures and electrical out of scope systems 6.12 Review & Approval Per PLI-11 Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 29 of 36 ANSI/ANS-52.1 Notes 1OCFR54.4 System Function Description Discussion Criterion Paragraph I Provide reactor coolant pressure 3.3.1.1 (a) 1 boundary.

4.4.1 2 Maintain reactor core assembly 3.3.1.3.g Maintain geometry within the reactor to (a)1 geometry.

4.1.1 ensure core reactivity control and core cooling capability.

4.4.1 3 Introduce negative reactivity to 3.3.1.3.e (a) 1 achieve or maintain subcritical reactor 4.2.1 condition.

4 Introduce emergency negative 3.3.1.2.c Functions include limiting the (a)1 reactivity to make the reactor 4.2.1 introduction of positive reactivity.

subcritical.

5 Sense process conditions and generate 3.3.1.3.1, m, n, o Includes indication used for manual (a)1 signals for reactor trip or engineered 4.3.1 actuation of safety related equipment.

safety features actuation.

6 Remove residual heat from the reactor 4.5.1 Residual heat removal for any event (not (a)1 coolant system. including normal operation) when the reactor is shutdown that does not require emergency core cooling system operation.

7 Provide emergency core cooling where 3.3.1.2.d, e Provide coolant to the reactor for any (a)1 the equipment provides coolant 4.8.1 event that requires engineered safety directly to the core. features actuation when other means of providing coolant are not sufficient to adequately cool the reactor core. This function also addresses coolant inventory that is maintained for use by the emergency core cooling system.

Exhibit 4 Standard Intended Functions ANSIIANS-52.1 Notes 10CFR54.4 System Function Description Discussion Criterion Paragraph 8 Provide heat removal from safety 4.7.1 This function addresses heat removal as (a)1 related heat exchangers.

necessary to provide a nuclear safety function.9 Provide primary containment 3.3.1.2.a This function addresses any primary a(l)boundary.

4.9.1 containment fission product barrier or primary containment radioactive material holdup or isolation.

10 Provide emergency heat removal from 3.3.1.2.b a(1)primary containment and provide 4.11.1 containment pressure control.11 Provide emergency removal of 3.3.1.2.b a(1)radioactive material from the primary 4.11.1 containment atmosphere.

12 Control combustible gas mixtures in 3.3.1.3.c a(1)the primary containment atmosphere.

4.11.1 13 Provide secondary containment 3.3.1.3.b a(1)boundary.

4.10.1 14 Control and treat radioactive materials 3.3.1.3.d, p Includes function to confine and treat a(1)released to the secondary containment.

4.10.1 radioactive materials that may leak from or may be released outside of the primary 4.11.1 containment, for controlled release to the environment.

15 Maintain emergency temperature 3.3.1.3.b a(1)limits within areas containing safety 4.12.1 related components.

Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 31 of 36 ANSI/ANS-52.1 Notes 10CFR54.4 System Function Description Discussion Criterion Paragraph 16 Ensure adequate cooling in the spent 3.3.1.3.j a(1)fuel pool to maintain stored fuel within 4.13.1 acceptable temperature limits.17 Provide motive power to safety related 3.3.1.3.1, n a(1)components.

4.14.1 18 Provide centralized area for control 3.3.1.3.p Function includes providing an a(1)and monitoring of nuclear safety 4.16.1 acceptable environment for operating related equipment.

.1. personnel.

Function also includes remote shutdown from outside the control room.19 Post accident containment holdup and The main condenser provides for post a(2)plate out of MSIV bypass leakage. accident containment, holdup and plate out of MSIV bypass leakage.20 Resist non-safety related SSC failure 3.3.1.3.k a(2)that could prevent satisfactory accomplishment of a safety related function.21 Relied upon in safety analyses or plant N/A Includes fire detection, suppression and a(3)evaluations to perform a function that confinement function for protection of demonstrates compliance with the SSCs important to safety. Also includes commission's regulations for Fire fire safe shutdown functions, and Protection (1OCFR50.48) functions associated with Appendix A to Branch Technical Position ASB 9.5-1.

Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 32 of 36 ANSI/ANS-52.1 Notes 10CFR54.4 System Function Description Discussion Criterion Paragraph 22 Relied upon in safety analyses or plant N/A Includes systems that contain electrical a(3)evaluations to perform a function that equipment subject to the requirements of demonstrates compliance with the IOCFR50.49, the EQ rule. Also includes commission's regulations for structures that provide the physical Environmental Qualification boundaries of the postulated harsh (1OCFR50.49) environments and contain environmentally qualified electrical equipment.

23 Relied upon in safety analyses or plant N/A Includes systems and equipment to a(3)evaluations to perform a function that reduce the risk from ATWS.demonstrates compliance with the commission's regulations for Anticipated Transients without Scram (1OCFR50.62) 24 Relied upon in safety analyses or plant N/A a(3)evaluations to perform a function that demonstrates compliance with the commission's regulations for Station Blackout (IOCFR50.63)

Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 33 of 36 No. Structural Function Description Notes 1OCFR54.4 Criterion 1 Provides physical support, shelter, and protection for safety 1OCFR54.4(a)(1) related systems, structures, and components (SSCs).2 Provides physical support, shelter, and protection for 1OCFR54.4(a)(2) nonsafety related systems, structures, and components (SSCs) whose failure could prevent satisfactory accomplishment of function(s) identified for IOCFR54.4 (a)(1)3 Provides protection for safe storage of new and spent fuel. IOCFR54.4 (a)(1)4 Controls the potential release of fission products to the IOCFR54.4 (a)(1)external environment so that offsite consequences of design basis events are within acceptable limits.5 Provides for the discharge of treated gaseous waste to meet IOCFR54.4(a)(1) the requirements of 1OCFR100.6 Prevent liquid radioactive waste from being released to the lOCFR54.4 (a)(2)environment in the event of a Safe Shutdown Earthquake (SSE).7 Provides Ultimate Heat Sink (UHS) during design basis IOCFR54.4(a)(1) events 8 Provides a source of cooling water for plant safe shutdown 1IOCFR54.4(a)(1)

_

Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 34 of 36 No. Structural Function Description Notes 10CFR54.4 Criterion 9 Provides a source of water for emergency core cooling IOCFR54.4 (a)(1)systems 10 Provides sufficient air and water volumes to absorb the 1OCFR54.4(a)(1) energy released to the containment in the event of design basis events so that the pressure is within acceptable limits 11 Controls the release of fission products to the secondary IOCFR54.4(a)(1) containment in the event of design basis loss-of-coolant accidents (LOCA) so that offsite consequences are within acceptable limits 12 Provides a safe means for handling safety related 10CFR54.4(a)(2) components and loads above or near safety related components 13 Prevents criticality of fuel assemblies stored in the spent 1OCFR54.4(a)(1) fuel pool Relied upon in safety analyses or plant evaluations to 1OCFR54.4(a)(3) 14 perform a function that demonstrates compliance with the commission's regulations for Fire Protection (1OCFR50.48)

Exhibit 4 Standard Intended Functions PLI-02 Rev. 4 Sheet 35 of 36 No. Structural Function Description Notes 10CFR54.4 Criterion 15 Relied upon in safety analyses or plant evaluations to 1OCFR54.4(a)(3) perform a function that demonstrates compliance with the commission's regulations for Environmental Qualification (1OCFR50.49)

Relied upon in safety analyses or plant evaluations to IOCFR54.4(a)(3) 16 perform a function that demonstrates compliance with the commission's regulations for Anticipated Transient without Scram (IOCFR50.62)

Relied upon in safety analyses or plant evaluations to IOCFR54.4(a)(3) 17 perform a function that demonstrates compliance with the commission's regulations for Station Blackout (1OCFR50.63) 18 Provides structural support or restraint to SSCs in scope of 1OCFR54.4(a)(1) license renewal. 1OCFR54.4(a)(2) 1OCFR54.4(a)(3) 19 Provides structural support or restraint to SSCs not in scope of license renewal to prevent interaction with safety related SSCs.lOCFR54.4(a)(2)

Exhibit 4 Standard Intended Functions No. Structural Function Description Notes 10CFR54.4 Criterion 20 Provide centralized area for control and monitoring of 1OCFR54.4(a)( 1)nuclear safety related equipment.

Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.7 Page 1 of 22 Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures and Commodities Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 2 of 22 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 K. P. Muggleston H. D. Honan D. B. Warfel 6/5/04 1 K. P. Muggleston C. Micklo D. B. Warfel 6/17/05 2 S. Rafferty J. Hufnagel D. B. Warfel 9/8/05 0 1 Revision Log Rev. No. Description of the Change(s)0 Initial issue.I Updated to correct references, minor editorial changes.2 Updated for formatting reasons.

Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 3 of 22 1. Purpose This instruction describes the process used to identify those structures and components, including commodities, that are subject to aging management review in accordance with 10 CFR Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants (the Rule). This process is referred to as Screening.

The Rule states:§54.21 Contents of application

-technical information Each application must contain the following information: (a) An integrated plant assessment (IPA). The IPA must --(1) For those systems, structures, and components within the scope of this part, as delineated in§54.4, identify and list those structures and components subject to an aging management review.Structures and components subject to an aging management review shall encompass those structures and components

--(i) That perform an intended function, as described in §54.4, without moving parts or without a change in configuration or properties.

These structures and components include, but are not limited to, the reactor vessel, the reactor coolant system pressure boundary, steam generators, the pressurizer, piping, pump casings, valve bodies, the core shroud, component supports, pressure retaining boundaries, heat exchangers, ventilation ducts, the containment, the containment liner, electrical and mechanical penetrations, equipment hatches, seismic Category I structures, electrical cables and connections, cable trays, and electrical cabinets, excluding, but not limited to, pumps (except casing), valves (except body), motors, diesel generators, air compressors, snubbers, the control rod drive, ventilation dampers, pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans, transistors, batteries, breakers, relays, switches, power inverters, circuit boards, battery chargers, and power supplies; and (ii) That are not subject to replacement based on a qualified life or specified time period.2. Applicability This instruction applies to Oyster Creek License Renewal personnel engaged in the preparation, checking, review or approval of screening evaluations in support of license renewal activities for the Oyster Creek License Renewal Project.3. References 3.1 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" 3.2 NEI 95-10, "Industry Guideline on Implementing the Requirements of 10 CFR Part 54," Revision 5.

Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 4 of 22 4.5.6.3.3 Draft NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, January 2005" 3.4 PLI-01, Preparation of Project Level Instructions and Position Papers 3.5 PLI-02, Scoping of Systems and Structures 3.6 PLI-04, Boundary Drawings 3.7 PLI- 1, License Renewal Document Control 3.8 NSAC-202L-R2, "Recommendations for an Effective Flow-Accelerated Corrosion Program," April 1999.3.9 Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 3, EPRI, Palo Alto, CA: 2001.1003056 3.10 Safety Evaluation Report Related to the License Renewal of Arkansas Nuclear One, Unit 1 (Docket No. 50-313), US NRC, April 2001 Definitions Definitions are provided in PLI-01, Preparation of Project Level Instructions and Position Papers Prerequisites This instruction utilizes information contained in the following Oyster Creek License Renewal Position Papers: (1) PP-01 License Renewal Systems & Structures (2) PP-08 Structure, Component and Commodity Types With Active, Passive, Short Lived Determination and Intended Functions (3) PP-15 Standard Materials, Aging Effects and Internal / External Environments The system scoping package should be complete and the associated license renewal boundary drawing prepared before the system screening evaluation can be completed.

The structure license renewal boundary drawing (plot plan drawing) need not be completed before structural screening can be performed.

Instructions This PLI provides direction on how to complete System / Structure Screening forms in the Oyster Creek License Renewal Database (LR Database).

The LR Database will be used to print out hard copy license renewal screening forms for subsequent review, approval and retention.

Screening will be performed for each mechanical system and structure previously determined to be in the scope of license renewal. Screening is not required for electrical systems as the electrical components that require an aging management review are determined by an industry accepted Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 5 of 22 commodity approach.

Electrical systems are systems that do not contain passive long-lived mechanical components typically shown on a flow diagram. The passive, long-lived components in the electrical systems are electrical components included as electrical commodities.

Screening is performed on a system and structure (or commodity, as discussed below) basis, with one screening evaluation completed for each in-scope mechanical system and structure.

The actual screening process (passive and long-lived determination) applies to the individual components, including structural components and commodities.

In the screening process, the term "structure" refers to structural components and not the overall building structure.

Screening is applied to in-scope structures and components, to determine those structures and components that are subject to an aging management review in accordance with 1OCFR54.21.

Structures and components subject to an aging management review are those that perform an intended function, as described in §54.4, without moving parts or without a change in configuration or properties (passive), and that are not subject to replacement based on a qualified life or specified time period (long-lived).

Screening will be performed and documented on a screening form for each group of components addressed as a commodity.

When a new commodity group is identified, it will be added to PP-O1 and incorporated into the license renewal database menus. An identified commodity group is, by definition, passive and long-lived.

Commodity groups are not established for active or short-lived component types. The screening of commodities will determine and document the intended functions, materials, environments and aging effects requiring management applicable to the commodity group. Reference to "components" throughout this instruction also includes components that are grouped and screened as a commodity.

During screening, information will be gathered to assist in the eventual aging management reviews and the preparation of the license renewal application (LRA). The information to be gathered includes structure or component type, internal and external environment, material, component intended function, and applicable aging effects.Plant design documents will be utilized to identify infonmation to be entered into the screening form.The needed information can generally be obtained from flow diagrams, specifications, the Component Record List (CRL), structural plan and elevation drawings, component drawings, system training materials, the UFSAR, or the Maintenance Rule Database.

In some cases, a plant walkdown may be the most efficient or only way to obtain necessary screening information.

It is not necessary for the assigned license renewal engineer to follow the steps in this instruction in the order shown, as long as all steps are completed prior to approval of a System / Structure Screening Form.Exhibit 1 depicts the License Renewal Database Screening Input Form Exhibit 2 depicts a sample Screening Form printed out from the database.Exhibit 3 is a flow chart of the LR Screening process.A License Renewal System and Structure Screening Form (Exhibit 1 or comparable) is used to document the screening evaluations, to determine the structures and components subject to an aging management review.Begin the screening process by selecting from the LR database, a screening form for the in-scope license renewal mechanical system, structure or commodity to be evaluated.

Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities 6.1 Component Selection PLI-03 Rev.2 Page 6 of 22 Using information from the completed scoping evaluations and/or associated drawings for the system, structure or commodity being evaluated, identify the passive, long-lived components types.Select the identified passive, long-lived component from the screening form "Structural and/or Component/Commodity" pull-down menu. The component types listed in the pull-down menu are those identified in PP-08, "Structure, Component and Commodity Types With Active, Passive, Short Lived Determination and Intended Functions." If a structure, component or commodity type is identified during screening that is not on the pull-down menu and not identified in PP-08, then initiate a change to PP-08 to add the new structure, component or commodity type.For mechanical systems, a listing of system components should be downloaded from the CRL to assist in identifying all passive, long-lived component types in the system. Review of boundary drawings and the CRL component listing provides reasonable assurance that all system components are reviewed.

For mechanical systems, the boundary drawing should be marked up to help track the review and confirm that all the components were addressed.

The marked up boundary drawing will be retained with the screening file to facilitate subsequent checks and reviews. The following guidelines should be used for marking the system boundary drawings during screening:

• Use of colored highlighters can help facilitate tracking the long-lived, passive components as they are added to the license renewal database screening form.* The review should include all of the in scope portions of the system, as identified by the green and red color-coding previously established during system scoping.* It is not necessary to review or annotate components located within areas of the flow diagram that are not included within the in scope boundary flowpath.

This includes electrical control schemes or background reference information such as structural or building location or interface information.

The mechanical system component CRL listing may include certain structural commodity type components such as pipe supports, panels or cabinets.

These items are screened with the structures or structural commodities, and as such should not be included with the mechanical system screening.

Most electrical components that may be identified within a mechanical system boundary are active components.

As discussed previously, passive electrical components are addressed as electrical commodities and should not be included in the mechanical system screening.

Closure bolting must be included in the screening database for each mechanical system, unless it is confirmed that the system does not utilize closure bolting. The intended function for closure bolting is Mechanical Closure (PP-08). An internal environment is not applicable, and the external environment will be the same as the external environment of the associated component(s) based on their location within the plant.Only passive, long-lived structure, component or commodity types are included on the screening form. Active or short-lived components are not included on the screening form and are not included in the pull-down menu. Refer to PP-08 to determine if the component, structure or commodity being evaluated is classified as active or short-lived.

Short-lived components are not common, and when identified, the rationale for the short-lived determination must be documented on the screening form in the Comments field.

Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 7 of 22 In general, a Component Type should be entered only once for a given system or structure.

The subsequent columns for Intended Function, Material and Environment may require multiple entries to address all of the components in the system or structure for the given Component Type. There are specific exceptions to this general rule, as described below:* Major components types should be uniquely identified, by typing in the commonly used name of the component (or group of components).

For example, major heat exchangers and coolers should be uniquely identified, by typing in the name of the heat exchanger in parenthesis after the Component Type label. Note that the unique name does not need to apply to individual heat exchangers.

The name can apply to groups of similar heat exchangers such as room coolers, seal coolers or Containment Spray heat exchangers.

This is especially applicable when a system includes several heat exchangers of different design. It is appropriate to differentiate between a major process heat exchanger and a component or seal cooling heat exchanger.

Heat exchangers in the same system with different intended functions, materials or environments should also be uniquely identified.

Major components that may also be listed separately include pumps, tanks, and nozzles.* Any other situation where it is appropriate for clarity or accuracy to identify an additional unique line item for a component type.6.2 Intended Functions The next column on the screening form is the "Intended Function" column. Using information from the completed scoping evaluations and/or associated drawings, identify the applicable intended function or functions for the selected structure, component or commodity.

The list of potential intended functions is identified in PP-08 and is also included as a pull-down menu for the "Intended Functions" database field. For some components, such as a restricting orifice or heat exchanger, the appropriate intended function will depend on the specific application within the system or structure.

For example, in-scope heat exchanger will always have a pressure boundary intended function, but the tubes may also have a heat transfer intended function if the heat transfer function of the heat exchanger is required to support a system intended function.All in-scope passive, long-lived structures, components or commodities will have at least one component intended function.

In some cases, the structure, component or commodity being evaluated will have more than one intended function.

All applicable intended functions must be included for the item being evaluated.

In cases where a component type has more than one intended function, each intended function is entered into the nested data entry table under the component type. Note that it will be necessary to enter material, environment and aging effect data for the component type, for each of the intended functions entered into the nested table.A restricting orifice and a flow element will always have a Pressure Boundary intended function, but may or may not have a Throttle intended function, depending on the application within the CLB.However, experience with license renewal indicates no significant benefit in making this distinction.

Therefore, it is acceptable and simplifies the results to conservatively include both the Pressure Boundary and the Throttle intended function for all of these component types.

Oyste Projei Screei r Creek License Renewal Project ct Level Instruction 3 ring of Systems, Structures

& Commodities PLI-03 Rev.2 Page 8 of22 Heat exchangers will always have a Pressure Boundary intended function, but may or may not have a Heat Transfer intended function, depending on the application within the CLB. It is beneficial to make the determination if Heat Transfer is an applicable intended function in the CLB, as it introduces additional aging effects, e.g., Loss of Heat Transfer.

For heat exchangers with both a Pressure Boundary and a Heat Transfer intended function, each intended function is entered separately into the nested data entry table. As stated above, it will be necessary to enter material, environment and aging effect data for each of the intended functions, for each component type, entered into the nested table.Non-safety related components in scope of license renewal for physical or spatial interaction, in accordance with 10 CFR 54.4(a)(2) and NRC Interim Staff Guidance ISG-09, are identified with red highlighting on the mechanical system boundary drawings.

These components fall into one or both of the following two categories:

• Spatial interaction

-applies to non-safety related components spatially located in the vicinity of safety related equipment, such that there is the potential for failure of the non-safety related component to cause failure of safety related equipment.

• Physical interaction

-applies to non-safety related components attached to safety related equipment, such that the non-safety related component provides structural support to attached safety related equipment.

As identified in position paper PP-08, the appropriate component intended function for the "spatial interaction" category is "Leakage Boundary" and the appropriate component intended function for the "physical interaction" category is "Structural Support".In cases of (a)(2), the throttle intended functions of restriction orifices and heat transfer intended function of heat exchangers are not applicable.

6.3 Material 6.3.1 Overview The next column on the screening form is the "Material" column. Using information from the completed scoping evaluations, associated drawings or additional references, identify the applicable material for the selected structure, component or commodity.

The list of potential materials is identified in PP-15 and is also included as a pull-down menu for the "Material" database field.Sources for material information include the following:

(1) Flow Diagrams (2) Vendor Drawings (3) SYS-LL-OC-1, OCNGS Line List & Specification (4) Component Specifications (5) Field Walkdowns (6) Component Record List (CRL)There can be more than one material for a given component type and intended function entry. In some cases, the component may be constructed of more than one material.

For example, a heat Oyste: Proje(Screei r Creek License Renewal Project ct Level Instruction 3 iing of Systems, Structures

& Commodities PLI-03 Rev.2 Page 9 of 22 exchanger will generally include different materials for the shell and tubes, and possibly other internal components such as tube sheets.In the case of a heat exchanger with a Heat Transfer intended function, the tube material must be identified as such by adding "(tubes)" after the material identification.

Note that this tube material will then be identified with both the Heat Transfer and the Pressure Boundary intended functions.

Heat exchanger materials that do not have a Heat Transfer intended function are listed only under the Pressure Boundary intended function.In some cases, the given component type and intended function row may include different groups of components made of different materials.

For example, a system may include both carbon steel and stainless steel valves, all with a Pressure Boundary intended function.

As discussed in Section 6.1, a component type is only entered once for a given system, unless the component type is a major component type such as heat exchanger that requires unique identification for clarity. The components constructed of different materials are added under the same component type and, if applicable, under the same intended function, but then broken out by the different applicable materials.

6.3.2 Sources of Material Information The following specific sources of material information are available for the identified component types: Piping The Oyster Creek Line List SYS-LL-OC-1 provides material information for the piping classes shown on many flow diagrams.

This is the primary source for identifying piping material.

Some flow diagrams identify piping material information directly on the flow diagram.Instrument Tubing Based on field walkdowns and interviews with plant personnel, instrument tubing is stainless steel for all water and steam systems. For oil, gas or ventilation systems, the instrument tubing may be copper or other materials and should be confirmed.

Valves The line list references two primary specifications for valves: S-2299-55 and S-2299-61.

These specifications address multiple materials.

The specifications include a list of system valve numbers with valve "Group" numbers identified.

The Group number can be used to determine the material, as defined in the specifications.

These specifications identify a significant but limited number of the valves in the plant. The valve numbering system in the specifications do not always directly match the flow diagrams.

It may be necessary to utilize the 2-letter system designator codes (from the line list) and also the original vendor assigned component numbers (often indicated in parenthesis on the flow diagrams) to correlate the specification component to the flow diagram component.

Bolting The line list provides a specification reference for the pressure bolting used in the system, from which material can be determined.

Fittings are made from essentially the same material as the pipe, as indicated on the line list.Ductwork Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 10 of 22 lIn accordance with specification S-2299-59 the ductwork material at Oyster Creek is aluminum and galvanized carbon steel. When screening HVAC systems, it should be confirmed if one or both of these materials are installed within the in-scope portions of the system.Restricting Orifice A search of EDMS for "orifice" identified numerous documents and drawings that were reviewed to determine the orifice material.

A number of drawings and documents identified the restricting orifice material, and in all cases where the material was identified, the material was stainless steel. It is, therefore, reasonable to assume identified restricting orifices are stainless steel unless otherwise identified.

Gauge Snubbers Based on field walkdowns and interviews with plant personnel, gauge snubbers are stainless steel.Other Components Materials are identified from sources such as the CRL, vendor drawings, vendor manuals, modification packages, specifications or plant walkdowns as described below.6.3.3 Material Research Process Guidance Piping materials are identified from flow diagrams and the line list. If the system does not include stainless piping in the line list, review the system instrumentation and add stainless piping if the system includes stainless instrumentation tubing. If the piping materials cannot be determined from the flow diagrams or line list or specification, then a walkdown may be required.Valve materials are identified from the applicable valve specification, for those valves that are listed in the specifications.

If the specifications do not identify any stainless steel valves in the system, it is necessary to research valves associated with system instrumentation (see CRL guidance, below) to determine if stainless steel valves should be included in the system.It is not necessary to research the material for every valve in the system. It would be expected that there would be valves of the same material/environment combination as the piping in the system.After reviewing the valve specifications and the system instrument valves as described above, review the results to determine if the identified valve material and environment combinations are the same as those identified for the system piping. If so, then it is likely that all appropriate valve materials and environments have been identified.

If not, additional research may be appropriate to confirm all the valve materials and environments have been properly identified.

Flow elements are usually stainless steel. If the material cannot be confirmed for a specific flow element, but the system contains others that have been confirmed as stainless steel, then it is reasonable to assume the unknown flow element is also stainless steel.The CRL provides material information for some components.

On Page 1, there are a few fields that may contain material information.

For some instrumentation valves, the Manufacturer Field may indicate Whitey or Swagelok or Cajon, and if the Model Number starts with "SS-" then it is a reasonable assumption that the valve material is stainless steel. Depending on the type of component, CRL Page 2 may have a field for material information.

CRL Page 5 is a common location for material information.

CRL Page 3 has drawing references, which may identify a vendor print or a vendor manual. If the drawing title looks promising, try getting the print from EDMS. EDMS also contains some vendor manuals. If the references either are not in EDMS or do not identify the materials, this component should be flagged as an unknown and go on to the next component.

If Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 11 of 22 needed, the appropriate references can be obtained from site, or a walkdown will be required to identify the material.Walkdowns may be the easiest way to determine some component materials.

Pictures can also be used in some cases. For example, a heat exchanger shell that is painted is assumed to be carbon steel.A stainless steel or rubber flex hose can usually be determined from a picture.Some components require determination of internal materials, such as heat exchangers or filters.Research through design information, procurement files or maintenance histories will be required to determine the internal materials.

6.3.4 Material Reference Documentation This instruction provides a number of specific sources of information for material identification, such as the line list, CRL and valve specifications.

These references need not be identified on the individual system or structure screening form, because they apply generically as documented in this instruction.

Other references, such as specific vendor drawings, vendor manuals, maintenance records or field walkdown, should be documented in the Comments field of the screening form or marked-up flow diagram. The applicable license renewal boundary drawing is referenced in the"Boundary Drawings" field.Any additional assumptions or rationalizations for material determinations should be documented in the Comments field of the screening form.6.4 Environment The next column on the screening form is the "Environment" column. Using information from the completed scoping evaluations, associated drawings or additional references, identify the applicable environments for the selected structure, component or commodity.

Both the internal and the external environment must be identified.

The list of potential environments is identified in PP-15 and is also included as a pull-down menu for the "Environment" database field.For mechanical system components, a minimum of two environments should be entered for each material, to account for both the internal and the external environment.

Each environment entered should be identified as either internal or external.

An exception is for mechanical components where an internal environment is not applicable, such as for Closure Bolting. In such cases, only the applicable (external) environment(s) need be listed.For heat exchangers, the material representing the tubes will have an internal environment based on the fluid inside the tubes, and an external environment based on the fluid outside the tubes, i.e., the same as the environment inside the heat exchanger shell.Operating environments are defined by the fluid medium and chemistry, such as treated water, raw water, or lubricating oil. For some materials, the applicability of certain aging effects can also depend on the service temperature or condition of fluid flow. For example: 1. Flow Accelerated Corrosion (FAC) is not an applicable aging mechanism for Loss of Material when there is normally very low or no flow, such as in the steam supply line to the Isolation Condenser. (Reference 3.8, Section 4.2.2)2. Stress corrosion cracking is not a significant aging mechanism for Cracking of stainless steel when the service temperature is normally below 200'F. (Reference 3.10, Section 3.3.5.2.1.1.1)

Oyster Creek License Renewal Project PLI-03 Rev.2 Project Level Instruction 3 Page 12 of 22 Screening of Systems, Structures

& Commodities

3. Thermal Aging Embrittlement is a potential aging mechanism that can result in Loss of Fracture Toughness for cast austenitic stainless steel. However, this aging mechanism is not a concern if the normal service environment is below 482 0 F. (Reference 3.9, Appendix A, Section 3.3.1)4. Stagnant conditions can result in higher concentrations of corrosive contaminants.

Unique environmental conditions such as those identified above should be noted in the Environment column. Note that it is not necessary to identify stainless steel below 140'F in systems subject to water chemistry controls, as in accordance with NUREG-1801 (GALL), cracking will be managed by the GALL Water Chemistry Programs (including One-Time Inspections as required).

This approach is consistent with previous applicants, appears to be an accepted approach by the NRC, and will be documented in the Oyster Creek LRA.6.5 Aging Effects Requiring Management The next column on the screening form is the "Aging Effect Requiring Management" column. The list of potential aging effects is identified in PP-15 and is also included as a pull-down menu for the"Aging Effects Requiring Management" database field. The applicable aging effects are a function of the material and environment being evaluated, and possibly other factors such as temperature or flow conditions as described above in Section 6.4. The variety of applicable aging effects for the material and environment combinations found in a nuclear power plant has been well established in previous license renewal evaluations.

The applicable aging effects can be identified from the following sources: (1) The Dresden and Quad Cities Aging Effects Topical Report (2) Previous License Renewal Applications (3) NUREG-1801, Generic Aging Lessons Learned (GALL) Report (4) Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 3, EPRI, Palo Alto, CA: 2001.1003056 (5) Aging Effects for Structures and Structural Components (Structural Tools), Revision 1 At least one entry must be provided for each material-environment combination.

Enter the applicable aging effect(s) or enter "None" if there are no significant aging effects for the material-environment combination.

If no aging effects are identified, provide ajustification for the conclusion of no aging effects by use of a plant specific note.6.6 Completion of Screening Screening is complete when all plant systems and structures have been subjected to the screening process as described in this Instruction and hard copy screening forms have been prepared, checked and approved in accordance with PLI-1 1. The remaining fields in the database will be completed during the Aging Management Review process.

Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 13 of 22 7. Exhibits Exhibit 1 LR Database Screening Input Form Exhibit 2 Sample System / Structure Screening Form Exhibit 3 Screening Process Flowchart Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 1 LR Database Screening Input Form[LI-03 Reiv.7 Page 14 of 22 Oyster.CreekLicense Renewal System Screening Form-A~hLI System.Grouping

-~ Auxiliary Systems License Renewal System Name Control Rod Drive System-.-..- -...-.n .7 ... I (From PP-1i--]Screening Commients:..-

-.L --L CR0 Pump Casing material from GE Specification 21A5351 Revision 2.Y-S trainers NC51 and NCO7 body and strainer materials from GE Specification 2145304 Revision 1.Temporary Strainers S-1 02A, S-i 028 and S-1 03 do not have strainers installed. (Tom Quintenz e-mail 5/6/2004J CR0 Temperature Element shown on 1 97E 871 is part of the Position Indication Probe, located inside the CRD Dry Tube, and does not involve a thermowell.

The "Dry Tube" is an integral part (subcomponent) of the CR0 mechanism.

Boundary.DOiwings:--

LR-GE-237E487 LR-GE-i197E 871.7 J-Screening En-giniee~r

[ 20 4K M Che ck-r bf Scre en ini: Screening---r-

--_ flevision No:- -_ _ _ _ _ _ Ap pirbov'-abf Screening4 I., ScreeningNo Complete:-Report Preview-W f l 7F 7 7 T h i 7 T 7 / F.Re'( Fd 7 '4 I 1 F i- TI 14 of i( itered)-... 4 j'FTorm View ---

Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 1 LR Database Screening Input Form ,-.... .. ....Oyster Creek License Renewal System Screening Form r Tiered Component Type subform_ l Cornponent DTOp r-iValve Body A LL0tkk._ Va l Intended Function: 1s :Pre ssure Boundary_

E: ;45 1--i : :fit1X l~: ;Xi <<0 ^:,$bLL 1;:~t_ :Material

_J 7a 7-- J, ;7.0;:X000i5 Carbon and low alloy steel Environment ITreated Water Internal)e -Aging Effect 7 ! : 4 4%;-q -E0 0;Loss of Material Vl#; :: : LiVol #2 : gling Pr ograrn: Notes ::; 9 Inside Air Internal & Exterr Aging Effect--None??? t ? ;: Brass

• Vol #2 Aging Program l Notes j Environment

[, l ] Treated Water (Internal)

__I Loss of Material f3-Vol#2 Aging Program No te*.- _l_- 1 II U I.I,]Screening Engineer 105j14/2004 KPM Checker of Screening:

Screening Revision No: 1 .Approval of Screening:

Record: 14 Lii FT 1 LtJ il _1i of 1 (Filtered) i Screening No Complete:

-;f Report Preview I --

I Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 2 Sample System / Structure Screening Form PLI-03 Rev.2 Page 16 of 22_=__~~~~~~~

---

UL,.. .fI..............................

_.__..........,..__s-Oyster Creek Nuclear Generating Station System and Striuctire Screening Form Control Rod Drive System Screed ni E nineer 0-714I304 KPM Checker Site RevieAer Approval of Screening:

Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 2 Sample System / Structure Screening Form PLI-03 Rev.2 Page 17 of 22 Compoiw itt Type Attended fwt et ion iVMeriaI Aging Effect Requiring Component Type kntended Function AobteriaJ Environment Aging Effect R~equiring fktagement Accumulators PressureBoundary Carbon and lowalloy steel Nitrogen None Treated Water Loss of Material Stainless Steel and Nickel Nitrogen None Alloy Closure boiling Mechanical Closure Carbon and lowalloy steel Inside Air (External)

Loss of Bolting Function Filter l Filter (elem ent) Stainless Steel and Nickel Treated Water(Iernel and Cracking I nitiation and I Alloy External)

Gomvah Loss of Material Pressure Boundary (Shell Carbon and lowalloy steel Inside Air (External)

None ???and Flange) (Closure Flange)Treated Water Q nternal) Loss of Material Stainless Steel and Nickel Inside Air (External)

None Alloy (Shell)Treated Water Onternal)

Loss of Material Cracking I nitiation and GromWh Cotrol Rod DrtieS Ptm Php2of(

Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 2 Sample System / Structure Screening Form PLI-03 Rev.2 Page 18 of 22 Component Type kntended Function AMrerial Environment Aging Effect Requring I nagement Flowelements Pressure Boundary, Throttle ?? Unknown ?? Inside Air (External)

None Treated Water Q nternal) Loss of Material??? Cracking???

Gauge Snubber Pressure BoundaryThrottle Stainless Steel and Nickel Inside Air (External)

None AlloyT Treated Water (internal)

Loss of Material Cracking I nitiation and Heat Exchangers Heat Transfer ?? (Shell) Lubricating Oil (Internal or External???)

Treated Water (nternal or External???)

Pressure Boundary ??? (Shell) Inside Air (External)

None ???Lubricating Oil or Treated ??????Water ??? (internal)

I --Piping and tittings Pressure Boundary Carbon and lowalloy teel Inside Air (Internal None???l l E Eternal)cotn ei Rod Drile Systm Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 2 Sample System / Structure Screening Form Component Type Intended Fwunction Mhterial EvwironmPnt Aging Effect Requiring m3gement Piping and fittings Pressure Boundary Carbon and lowalloy steel Treated Water (rnternal)

Loss of Material Stainless Steel and Nickel Inside Air (External)

None Alloy Treated Water (rnternal)

Loss of Material Cracking I nitiation and Grovth Pumrp Casing Pressure Boundary Carbon and lowalloy steel Inside Air (External)

None ?????? (Gear box oil pump)Lubricating Oil (Internal)

Loss of Material Stainless Steel and Nickel Inside Air (External)

None Alloy Treated Water 0 nternal) Cracki ng I niti ati on and Grovfih Loss of Material Restriding Orifice lPressure Boundary, Throttle Stl Steel andNickel l Insde Air (External)

None Treated Water 0 nternal) Cracking I nitiation and Grodh Loss of Material.CoI trOI Rod DOrle GTr Rptoff Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 2 Sample System / Structure Screening Form PLI-03 Rev.2 Page 20 of 22 Component Type krtemded Fmnction IlMerial Ewironment l Aging ffect Requiring IAbnagementt Strainer Filter Stainless Steel and Nickel Treated Water (Internal and Loss of Material Alloy E xternml)Cracking Initiation and GrovTh Strainer Body Pressure Boundary Carbon and lowalloy steel Inside Air (External)

None ???Treated Water Q nternal) Loss of Material Stainless Steel and Nickel Insde Air (External)

None Alloy Treated Water Q nternal) Cracking Initiation and GrovTh Loss of Material Valve Body Pressure Boundary Brass Inside Air (External)

None Treaed Wter(3 nerna) Lss o Matria Treated Wet er Q riternal)Loss of Material Carbon and lowalloy steel Inside Air ( Internal & None???External)Treated Wat er 0 nternal)Loss of Material Cot aol Rod D re sWt m Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 2 Sample System / Structure Screeni Component Type Intended Fumetion, A/terial Environment Aging Effect Requiting Ivknagement Valve Body Pressure Boundary Stainless Steel and Nickel Inside Air (External)

None Aloy Treated Water J rternal) Loss of Material Cracking Initiation and Grovth Corn tro Rod DOre Sy1tm P.Psoft Oyster Creek License Renewal Project Project Level Instruction 3 Exhibit 3 Screening Process Flowchart 6.0 OBTAIN an in scope LR system boundary drawing& SELECT that system from the LR Database pulldown menu 6.1 IDENTIFY passive, long-lived component types in the LR system and SELECT from the LR Database pulldown menu 6.2 IDENTIFY intended function(s) for each component type and SELECT from the LR Database pulidown menu 6.3 IDENTIFY material(s) for each component type and intended function combination and SELECT from the LR Database puildown menu 6.4 IDENTIFY internal and external environments for each component type and material combination and SELECT from the LR Database pultdown menu 6 A L NO r I-NO~ n op YES Xrenn Coml YES All component types in system screened?6.6 PRINT, REVIEW and APPROVE hard copy screening form from LR Database 6.5 IDENTIFY the aging effects requiring management for each material and environment combination and SELECT from the LR Database putidown menu Exelon Corporation PLI-04 Rev. 02 Sheet I of II Project Level Instruction 4 Boundary Drawings Oyster Creek Nuclear Generating Station License Renewal Exelon Corporation PLI-04 Rev. 02 Sheet 2 of 11 APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Al Fzulvio Don Warfel Date 1/13/04 1/13/04 1/13/04 01 Kevin Muggleston Stu Getz Al Fulvio Date 8/16/05 8/16/200S 8/16/05 02 Shannon Rafferty John Ihifnagel Don Warfel Date 9/8/05 9/8/05 9/8/05 PLI-04 Rev. 02 Sheet 3 of 11.l REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)I Updated references, added new system flags, clarified boundary flag use.2 Updated for formatting reasons.3 4 5 PLI-04 Rev. 02 Sheet 4 of 11 TABLE OF CONTENTS Page A pproval Page.................................................................................................................................2 Revision Summary ............................

3 TABLE OF CONTENTS ...........................

4 1.0 Purpose ..................................

5 2.0 Applicability

..................................

5 3.0 References

..............................

5 4.0 Definitions

..................................

6 5.0 Prerequisites

..............................

6 6.0 Instructions

...............................

6 6.1 Mechanical Systems ..................................

6 6.2 Electrical Systems .................................

8 6.3 Structures

..................................

9 7.0 Review and Approval ..................................

9 Exhibit I -System Boundary Flag Designations........................................................................................................

10 PLI-04 Rev. 02 Sheet 5 of 11 1.0 Purpose The purpose of this project level instruction is to provide guidelines for preparation of License Renewal Drawings for Oyster Creek. This instruction documents a number of standards and conventions to be followed when preparing boundary drawings.

This instruction is intended to assure consistency in quality and appearance of license renewal boundary drawings for Oyster Creek.Note Additional issues may be identified during the development of the boundary drawings, where decisions are made that impact drawing content, format or appearance.

If appropriate, this instruction should be revised to reflect new or changed conventions or standards.

Although not a requirement of the rule, the development of boundary drawings provides additional confirmation of correct system and structure scoping.2.0 Applicability This instruction is for the use of personnel engaged in the preparation of boundary drawings in support of license renewal activities for Oyster Creek. This instruction does not apply to the review and approval or revision control process. Review, approval and revision control are addressed in reference 3.8.3.0 References 3.1 10CFR54.4 Requirements for Renewal of Operating Licenses for Nuclear Power Plants 3.2 NEI 95-10, "Industry Guideline for Implementing The Requirements of 10 CFR Part 54-The License Renewal Rule," Revision 5 3.3 NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" 3.4 PLI-02, Scoping of Systems and Structures 3.5 ISG-9, "Guidance on the Identification and Treatment of Structures, Systems and Components which meet 10CFR54.4(a)(2)" 3.6 PLI-01, Preparation of Project Level Instructions and Position Papers 3.7 ISG-2, "Scoping of Equipment Relied on to Meet the Requirements of the Station Blackout (SBO) Rule (1 0 CFR Part 50.63) for License Renewal (10 CFR 54.4(a)(3))" 3.8 PLI-1 1, License Renewal Document Control 3.9 PP-03, 54.4(a)(2)

Scoping Criteria 3.10 PP-04, 1 OCFR54.4(a)(3)

Station Blackout Systems 3.11 PP-07, 1 OCFR54.4(a)(3)

Fire Protection Systems PLI-04 Rev. 02 Sheet 6 of 11 4.0 Definitions Definitions are provided in reference 3.6.5.0 Prerequisites This instruction provides guidance to be followed when preparing license renewal boundary drawings for Oyster Creek. Boundary drawings are prepared during the scoping process under PLI-02 (reference 3.4), which includes appropriate prerequisites.

Additional prerequisites are not applicable for this instruction.

6.0 Instructions The numbered steps in this instruction document concepts, conventions, standards and expectations associated with license renewal boundary drawings.

Step numbers are not intended to indicate a specific sequence of actions.6.1 Mechanical Systems Note Each license renewal boundary drawing will have a license renewal engineer assigned primary responsibility.

The responsible engineer will coordinate with others as needed if the drawing includes multiple in-scope systems.6.1.1 The license renewal boundary drawings are prepared from existing flow diagrams.

The layout and level of detail of the drawings will remain essentially as shown on the flow diagrams.6.1.2 Boundary drawings are assigned unique license renewal drawing numbers. The drawing numbers reflect existing flow diagram numbers (i.e., LR-BR-2001), as described in PLI-02 (reference 3.4).6.1.3 As with the current flow diagrams, multiple systems may be shown on an individual boundary drawing.6.1.4 The boundary drawings are intended to assist LRA reviewers in understanding the scope of systems, structures and components included in the license renewal application.

For mechanical systems, the boundary drawings are intended to clearly show the system flow paths, system boundaries, branches and mechanical components that are included in scope.Mechanical system boundary drawings are not intended to show electrical or structural scoping.6.1.5 Mechanical boundary drawings indicate in-scope piping and components by showing the schematic flow paths and component symbols in color. Systems or portions of systems that are required to perform process functions to meet the intended function requirements under 1 OCFR54.4(a)(1) and (a)(3) are colored green. Systems or portions of systems with supporting process functions under 1OCFR54.4(a)(2) are also colored green. Systems or portions of systems that are included in scope only due to spatial or physical interactions under PLI-04 Rev. 02 Sheet 7 of 11 1 OCFR54.4(a)(2), as described in PP-03 (reference 3.9) and ISG-9 (reference 3.5), are colored red.6.1.6 Supplemental drawing information such as component identification names or numbers, line numbers or line specifications, class breaks, instrument location information, etc, will not be colored.6.1.7 Existing revision ballooning will be removed from the drawings.6.1.8 Existing equipment identified as "abandoned in place" may be deleted from the drawings if the equipment is not in scope for potential physical or spatial interaction.

6.1.9 System interfaces between in-scope systems will be identified with boundary flags on the license renewal boundary drawings when appropriate for clarification purposes.

Interface boundary flags are not required where boundaries are obvious or are adequately understood with the existing flow diagram format, such as at an interface with the reactor pressure vessel or at interfaces between instrument air supplies and supplied components.

6.1.10 System boundaries must reflect the system scoping and screening results in Chapter 2 of the LRA. For example, if ECCS suction strainers are scoped and screened as part of the containment structure or torus, then the ECCS piping system boundary should stop at the connection to the torus, and be identified with a boundary flag. Note that if the strainers are scoped and screened with the ECCS system, then no boundary flag is required as the existing flow diagrams adequately show the piping interface with the torus.6.1.11 When system boundary identifications are needed, system flag symbols are used. The system flag symbol is a 2 to 4 character code to identify the system in the boundary flags. Exhibit 1 is a list of system flag symbols. Exhibit 1 includes only mechanical license renewal systems that are anticipated to be in-scope and to appear on a license renewal boundary drawing. The table of system flag symbols will be included on Legend Drawing LR-BR-2001.

6.1.12 Instrument lines that connect to in-scope pressure boundary piping also provide a pressure boundary intended function, and will be shown as in-scope with green or red as appropriate.

6.1.13 Instrumentation connected to the in-scope pressure boundary will be colored in-scope for clarity, even though instrumentation is active and therefore does not require an aging management review.6.1.14 Control scheme representations on the flow diagrams will not be colored as in-scope, regardless of the functions of the control scheme components.

Any control scheme components in the scope of license renewal are either active or are addressed by the electrical commodities approach.6.1.15 Existing drawing continuation arrows will not be revised to indicate the license renewal drawing number convention.

A general note will be provided on the license renewal Legend Drawing LR-BR-2001 to explain the correlation between existing flow diagram drawing numbers and license renewal drawing numbers.6.1.16 Some flow diagrams show interfacing systems and equipment not directly related to the system shown on the flow diagram. This information is provided to make the drawings easier to use and understand.

The interfacing systems and equipment are provided as background information because they also appear on their own respective drawings.

These interfacing lPLI-04 Rev. 02lSheet 8 of 11 systems are sometimes shown with dashed or faint lines on the existing drawings.

For license renewal, this background information will be colored as in-scope when appropriate for clarity. A general note will be provided on the license renewal Legend Drawing LR-BR-2001 to explain how background interfacing systems and equipment are handled on the license renewal drawings.6.1.17 There are cases where the LR boundary is either at a normally open valve or at no valve at all.This is considered acceptable.

The reasoning in each case must be understood and documented in an appropriate position paper, in the system scoping package, or with a note on the boundary drawing.6.1.18 Existing flow diagram notes will be reviewed for applicability to the license renewal drawings.For notes that are not directly applicable to license renewal review (e.g., in-scope material information), the note and note references will be deleted from the drawing. Any clarifying notes appropriate for license renewal will be added to the drawings.6.1.19 Each license renewal drawing will include a note that references the drawing revision that it was created from, e.g., 'This drawing is based on BR-2002 sheet 1 revision 58." 6.1.20 No attempt will be made to explicitly identify in-scope versus out-of-scope insulation on the license renewal drawings.

This issue will be handled in the LRA text as appropriate, and with a general explanatory note on LR-BR-2001.

6.1.21 Electric solenoid operated valves are often used to vent compressed air, such that a required safety function (such as closing an air operated isolation valve) is accomplished by venting.The solenoid valve may be classified safety related to perform this active vent function.

Such a safety related solenoid valve is in the scope of license renewal, but it has no passive intended function since the only safety function is to vent pressure.

The interconnecting tubing in these applications is usually not safety related and not in scope. Solenoid valves that only have an active intended function will not be shown in-scope on the boundary drawings.6.1.22 Oyster Creek flow diagrams typically do not explicitly identify interfacing cooling water systems at process heat exchangers.

Reference to the appropriate cooling water system may be added if appropriate for additional drawing clarity.6.2 Electrical Systems 6.2.1 Aging management reviews and aging management programs for electrical systems are handled by a commodities approach.

Electrical systems and boundaries are not described in the LRA. Established practice has been to include a high level single line diagram, showing the primary electrical distribution layout to the 4KV emergency bus level. It has also become necessary to show the appropriate power paths anticipated to be used during restoration from a station blackout event (PP-04, reference 3.10), as discussed in ISG-2 (reference 3.7), and the off site power sources credited as part of the Fire Protection Plan (as applicable)(PP-07, reference 3.11).6.2.2 A simplified electrical drawing will be prepared to show the arrangement of the electrical distribution system, including interfaces with external power systems. This drawing will clearly show that power distribution systems needed for compliance with the Station Blackout regulation and Fire Protection Plan are included in scope. (See reference 3.3, Section 2.2.3.1, Example 4).

lPLI-04 Rev. 02lSheet 9 of 11 6.2.3 The electrical single-line paths and associated components in the scope of license renewal will be colored green to indicate in-scope.6.2.4 Supplemental drawing information such as component identification names or numbers, wire or terminal numbers, location information, etc, will not be colored.6.3 Structures The boundary drawing for structures will be prepared by highlighting the boundaries of the structures that are in-scope.

The current site plan drawing will be used as the boundary drawing for structures.

7.0 Review and Approval The license renewal engineer will determine when all scoping is complete for the assigned boundary drawing. When scoping is complete, the license renewal engineer will initiate the boundary drawing review and approval process as defined in PLI-1 1, License Renewal Document Control (reference 3.8).

PLI-04 Rev. 02 Sheet 10 of 11 Exhibit 1 -System Boundary Flag Designations System Name Boundary Flag"C" Battery Room Heating & Ventilation CBRV 4160V Switchgear Room Ventilation 4KVV 480V Switchgear Room Ventilation SGRV Battery and MG Set Room Ventilation BMGV Chlorination System CL2 Circulating Water System CW Condensate System CND Condensate Transfer System CT Containment Inerting System CI Containment Spray System CS Containment Vacuum Breakers CVB Control Rod Drive System CRD Control Room HVAC CRV Core Spray System CSS Drywell Floor and Equipment Drains DFED Emergency Diesel Generator and Auxiliary System EDG Emergency Service Water System ESW Feedwater System FW Fire Protection System FP Hardened Vent System HV Heating & Process Steam System HPS Hydrogen & Oxygen Monitoring System HOM Instrument (Control)

Air System IA Isolation Condenser System IC Main Condenser MC Main Fuel Oil Storage & Transfer FO Main Generator and Auxiliary Systems MGA Main Steam System MS Main Turbine and Auxiliary Systems MTA Miscellaneous Floor and Equipment Drain System MFED Nitrogen Supply System NS Noble Metals Monitoring System NMM Nuclear Boiler Instrumentation NBI Post-Accident Sampling System PASS Process Sampling System PS Radiation Monitoring System RMS Radwaste Area Heating and Ventilation System RV Reactor Building Closed Cooling Water System RBCW Reactor Building Floor and Equipment Drains RFED Reactor Building Ventilation System RBV Reactor Head Cooling System RHC Reactor Pressure Vessel RPV Reactor Recirculation System RR Reactor Water Cleanup System RWCU Roof Drains and Overboard Discharge System RDOD Service Water System SW Shutdown Cooling System SDC Spent Fuel Pool Cooling System SFPC PLI-04 Rev' 02 Sheet 11 of 11 Exhibit 1 -System Boundary Flag Designations System Name Boundary Flag Standby Gas Treatment System SGTS Standby Liquid Control System SLC Traveling In-Core Probe System TIP Turbine Building Closed Cooling Water System TBCW Water Treatment

& Distribution System WT Oyster Creek License Renewal Project Project Level Instruction 5 Aging Management Reviews PLI-5 Rev. 2 Page I of 11 Oyster Creek License Renewal Project Project Level Instruction 5 Aging Management Reviews Oyster Creek License Renewal Project Project Level Instruction 5 Aging Management Reviews PLI-5 Rev. 2 Page 2 of 11 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Mark Miller Don Warfel 11-16-04 1 Kevin Muggleston Mark Miller Al Fulvio 8-17-05 2 Shannon Rafferty John Hufnagel Don Warfel 9-08-05 Revision Log Rev. Description of the Change 0 Initial Issue 1 Updated references, Database details and Table Description exhibit 2 Updated for formatting reasons.

Oyster Creek License Renewal Project PLI-5 Rev. 2 Project Level Instruction 5 Page 3 of 11 Aging Management Reviews 1.0 Purpose This instruction describes the procedural requirements for Aging Management Reviews that are prepared for the Oyster Creek License Renewal Project.2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in preparing Oyster Creek License Renewal Aging Management Review documents.

3.0 References 3.1 10 CFR Part 54 -The License Renewal Rule 3.2 NEI 95-10 Rev. 5 -Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule 3.3 ER-AA-1 100 "Implementing and Managing Engineering Programs" 3.4 PLI-1 "Preparation of Project Level Instructions and Position Papers" 3.5 PLI-8 "Aging Management Program Reviews" 3.6 PLI-1 1 "License Renewal Document Control" 3.7 RM-AA-101 "Records Management Program" 3.8 Draft NUREG-1800 Rev. 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", January 2005 3.9 Draft NUREG-1801 Rev. 1, "Generic Aging Lessons Learned (GALL) Report", January 2005 4.0 Definitions None.5.0 Prerequisites None.

Oyster Creek License Renewal Project PLI-5 Rev. 2 Project Level Instruction 5 Page 4 of 11 Aging Management Reviews 6.0 Instructions The Aging Management Review demonstrates that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation.

To accomplish this demonstration, tables are created which summarize the results of the review. Refer to Exhibit 3, Aging Management Review Table Descriptions, for a description of the table contents and format.6.1 Begin the Aging Management review process by selecting an in scope system from the OCLR Database.6.2 Select a component type from the OCLR Database pulldown.6.3 Each component type has one or more combinations of material, environment and aging effect. For each combination, identify a corresponding combination from NUREG-1801 Volume 2. If there is no match, then leave this column blank.6.4 For each combination, select the appropriate Aging Management Program(s) from the OCLR Database pulldown.6.5 For each combination, identify the corresponding NUREG-1801 Volume 1 Item Number. If there is no match, then leave this column blank.6.6 For each combination, identify applicable standard or plant specific notes. A list of the standard notes is given in Exhibit 2. Plant specific notes are manually typed into the field. The plant specific notes are sequentially numbered to differentiate them from the alphabetized standard notes.6.7 Continue the above steps for each component type in the system.6.8 When all of the component types for a given system are completed, then the"Discussion" section of Table 1 is completed for that system.6.9 When all of the systems are completed for a system grouping, then the "Discussion" section of Table 1 is revised to integrate the individual system discussions.

6.10 Print the Aging Management Review results for each system and complete the approvals in accordance with PLI-1.

Oyster Creek License Renewal Project Project Level Instruction 5 Aging Management Reviews PLI-5 Rev. 2 Page S of 11 7.0 Exhibits Exhibit 1 -Aging Management Review Process Exhibit 2 -NUREG-1801 Consistency Notes for Aging Management Review Results Exhibit 3 -Aging Management Review Table Descriptions Oyster Creek License Renewal Project Project Level Instruction 5 Aging Management Reviews Exhibit I -Aging Management Review Process PLI-5 Rev. 2 Page 6 of 11 For each Component TypelMatlVEnvironment/Aging Eftect combo.IDENTIFY&

ENTER corresponding

-NUREG-1801 Vol 2 Item" (If no GALL match, leave blank)For each: Type/MatItlEnvironment/Agrig Eftect combo, IDENTIFY & ENTER corresponding Tabte 1 Item'(1t no GALL match, leave blank)For each Component Type/Mat'V EnvironmenVAging Effect combo, SELECT appropsate

'Aging Management Program'from OB pulidown.Note: There may be more than 1 Oyster Creek License Renewal Project PLI-5 Rev. 2 Project Level Instruction 5 Page 7 of 11 Aging Management Reviews Exhibit 2 -NUREG-1801 Consistency Notes for Aging Management Review Results Standard Notes A. Consistent with NUREG-1801 item for component, material, environment and aging effect.AMP is consistent with NUREG-1801 AMP.B. Consistent with NUREG-1801 item for component, material, environment and aging effect.AMP takes some exceptions to NUREG-1801 AMP.C. Component is different, but consistent with NUREG-1801 item for material, environment and aging effect. AMP is consistent with NUREG-1801 AMP.D. Component is different, but consistent with NUREG-1801 item for material, environment and aging effect. AMP takes some exceptions to NUREG-1801 AMP.E. Consistent with NUREG-1801 item for material, environment and aging effect, but a different aging management program is credited.F. Material not in NUREG-1801 for this component.

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

I. Aging effect in NUREG-1801 for this component, material and environment combination is not applicable.

J. Neither the component nor the material and environment combination are evaluated in NUREG-1801.

Plant-Specific Notes 1. Determined on a plant-specific basis.

Oyster Creek License Renewal Project PLI-S Rev. 2 Project Level Instruction 5 Page 8 of 11 Aging Management Reviews Exhibit 3 -Aging Management Review Table Descriptions NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," contains the staff's generic evaluation of existing plant programs.

It documents the technical basis for determining where existing programs are adequate without modification, and where existing programs should be augmented for the extended period of operation.

The evaluation results documented in the report indicate that many of the existing programs are adequate to manage the aging effects for particular structures or components, within the scope of license renewal, without change. The report also contains recommendations on specific areas for which existing programs should be augmented for license renewal. In order to take full advantage of NUREG-1801, a comparison between the AMR results and the tables of NUREG-1801 has been made. The results of that comparison are provided in the two tables.Table 1 The purpose of Table 1 is to provide a summary comparison of how the facility aligns with the corresponding tables of NUREG-1 801, Volume 1. The table is essentially the same as Tables 1 through 6 provided in NUREG-1801, Volume 1, except that the"Type" column has been replaced by an "Item Number" column and the "Item Number in GALL" column has been replaced by a "Discussion" column.The "Item Number" column provides the reviewer with a means to cross-reference from Table 2 to Table 1.The "Discussion" column is used by the applicant to provide clarifying/amplifying information.

The following are examples of information that might be contained within this column:* "Further Evaluation Recommended" information or reference to where that information is located (including a hyperlink if possible)* The name of a plant specific program being used (and a hyperlink to the program if possible)* Exceptions to the NUREG-1 801 assumptions

• A discussion of how the line is consistent with the corresponding line item in NUREG-1 801, Volume 1, when that may not be intuitively obvious* A discussion of how the item is different than the corresponding line item in NUREG-1801, Volume 1, when it may appear to be consistent (e.g., when there is exception taken to an aging management program that is listed in NUREG-1 801, Volume 1)

Oyster Creek License Renewal Project PLI-5 Rev. 2 Project Level Instruction 5 Page 9 of 11 Aging Management Reviews The format of Table 1 provides the reviewer with a means of aligning a specific Table 1 row with the corresponding NUREG-1801, Volume 1 table row, thereby allowing for the ease of checking consistency.

Table 2 Table 2 provides the detailed results of the aging management reviews for those components identified in LRA Section 2 as being subject to aging management review. There will be a Table 2 for each of the subsystems within a "system" grouping.For example, for a PWR, the Engineered Safety Features System Group contains tables specific to Containment Spray, Containment Isolation, Emergency Core Cooling System, etc.Table 2 consists of the following nine columns:* Component Type* Intended Function* Material* Environment

• Aging Effect Requiring Management

• Aging Management Programs* NUREG-1801 Volume 2 Item* Table 1 Item* Notes Component TVpe The first column identifies all of the component types from Section 2 of the LRA that are subject to aging management review. They are listed in alphabetical order.Intended Function The second column contains the license renewal intended functions (including abbreviations where applicable) for the listed component types. Definitions and abbreviations of intended functions are contained within the Intended Functions table of LRA Section 2.Material The third column lists the particular materials of construction for the component type.Environment Oyster Creek License Renewal Project PLI-5 Rev. 2 Project Level Instruction 5 Page 10 of 11 Aging Management Reviews The fourth column lists the environment to which the component types are exposed.Internal and external service environments are indicated and a list of these environments is provided in the Internal Service Environments and External Service Environments tables of LRA Section 3.Aging Effect Requiring Management As part of the aging management review process, the applicant determines any aging effects requiring management for the material and environment combination in order to maintain the intended function of the component type. These aging effects requiring management are listed in column five.Aging Management Programs The aging management programs used to manage the aging effects requiring management are listed in column six of Table 2.NUREG-1801 Vol. 2 Item Each combination of component type, material, environment, aging effect requiring management, and aging management program that is listed in Table 2, is compared to NUREG-1801, Volume 2 with consideration given to the standard notes, to identify consistencies.

When they are identified, they are documented by noting the appropriate NUREG-1 801, Volume 2 item number in column seven of Table 2. If there is no corresponding item number in NUREG-1801, Volume 2, this row in column seven is left blank. That way, a reviewer can readily identify where there is correspondence between the plant specific tables and the NUREG-1801, Volume 2 tables.Table 1 Item Each combination of component, material, environment, aging effect requiring management, and aging management program that has an identified NUREG-1801 Volume 2 item number must also have a Table 3.x.1 line item reference number. The corresponding line item from Table 1 is listed in column eight of Table 2. If there is no corresponding item in NUREG-1801, Volume 1, this row in column eight is left blank.That way, the information from the two tables can be correlated.

Notes In order to realize the full benefit of NUREG-1801, each applicant needs to identify how the information in Table 2 aligns with the information in NUREG-1 801, Volume 2.This is accomplished through a series of notes. All note references with letters are Oyster Creek License Renewal Project PLI-5 Rev. 2 Project Level Instruction 5 Page 11 of 11 Aging Management Reviews standard notes that will be the same from application to application throughout the industry.

Any notes the plant requires which are in addition to the standard notes will be identified by a number and deemed plant specific.Table Numbering scheme:* Table 3.x.1 -where '3' indicates LRA Section 3; 'x' indicates the subsection number;and '1' indicates the first table type. For example, in the Reactor Vessel, Internals, and Reactor Coolant System section this table would be numbered 3.1.1 and in the Auxiliary Systems section, this table would be numbered 3.3.1. This table type is referred to as"Table 1."* Table 3.x.2.1.y

-where '3' indicates LRA Section 3.0; 'x' indicates the subsection number; '2' indicates the second table type; '1' indicates the summary subsection for materials, environments, aging effects and aging management programs; and 'y'indicates the specific system being addressed.

For example, within Section 3.1 for the Reactor Vessel, Internals, and Reactor Coolant System, the table number for the Reactor Internals would be 3.1.2.1.4; and for the Reactor Vessel would be 3.1.2.1.5.

Also, within Section 3.2 for Engineered Safety Features, this table would be 3.2.2.1.1, for the Containment Spray System; and the next system, Core Spray, has a table numbered 3.2.2.1.2.

This table type is referred to as "Table 2."

Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Rev 2 Sheet I of 16 Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Rev 2 Sheet 2 of 16 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date O M. J. May A. A. Fulvio D. B. Warfel 1/24/05 1 M. J. May S. C. Getz A. A. Fulvio 8/16/05 2 S. Rafferty J. Hufnagel D.B. Warfel 9/08/05 Revision Log Rev. Description of the Change O Initial Issue I Updated revision of NEI 95-10 and added NUREG-1800 to references.

2 Updated for formatting reasons.

Oyster Creek License Renewal Project PLI-6 Rev 2 Project Level Instruction 6 Sheet 3 of 16 Evaluation of Time Limited Aging Analyses 1.0 Purpose This instruction provides instruction for identification and disposition of potential time limited aging analyses (TLAAs) in support of the Oyster Creek License Renewal Project.2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in preparing Oyster Creek License Renewal Project documents.

3.0 Reference 3.1 10 CFR Part 54 -The License Renewal Rule.3.2 NEI 95-10, Revision 5 -"Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule".3.3 PLI-1 "Preparation of Project Level Instructions and Position Papers".3.4 NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", Revision 1, Draft dated January 2005.4.0 Definitions 4.1 Current Licensing Basis (CLB) 10 CFR 50.3 defines the CLB as;"... the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations contained in 10 CFR parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73, 100 and appendices thereto; orders;license conditions; exemptions; and technical specifications.

It also includes the plant-specific design-basis information de-fined in 10 CFR 50.2 as documented in the most recent final safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports." 4.2 CLB Database -A set of indexed documents in Acrobat PDF format documents that represents the Oyster Creek current licensing basis. These documents can be readily searched for key words and phrases. See Exhibit 2 for a list of documents included in the CLB database.4.3 Potential TLAA (PTLAA)A time-dependent analysis, evaluation, calculation, or assumption described, cited, or necessary to support the CLB and whose description in a CLB source document would appear to have the potential to meet all six 10 CFR 54.3(a) criteria for a TLAA. (See TLAA definition below)

Oyster Creek License Renewal Project PLI-6 Rev 2 Project Level Instruction 6 Sheet 4 of 16 Evaluation of Time Limited Aging Analyses 4.4 Time-limited aging analysis (TLAA) -A TLAA as defined in 10 CFR 54.3.6, is a calculation, analysis, or evaluation, which meets all six of the following criteria: "Time-limzited aging analyses, for the purposes of this part [i.e., of 10 CFR 54, the License Renewal Rule], are those licensee calculations and analyses that: (1) Involve systems, structures, and components within the scope of license renewal, as delineated in §54.4(a);(2) Consider the effects of aging;(3) Involve time-limited assumptions defined by the current operating term, for example, 40 years;(4) Were determined to be relevant by the licensee in making a safety determination; (5) Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, and component to perform its intended functions, as delineated in §54.4(b);

and (6) Are contained or incorporated by reference in the CLB.[10 CFR 54.3(a)]4.5 TLAA Disposition The license renewal rule provides for TLAAs to be dispositioned in one of three ways: (c)An evaluation of time-limited aging analyses.(1) A list of time-limited aging analyses, as defined in §54.3, must be provided.

The applicant shall demonstrate that --(i) The analyses remain valid for the period of extended operation;(ii)The analyses have been projected to the end of the period of extended operation; or (iii)The effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

10 CFR 54.21(c)(1) 4.6 License Exemption Review The License Renewal rule require License Exemptions to reviewed for TLAAs A list must be provided of plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on time-limited aging analyses as defined in §54.3. The applicant shall provide an evaluation that justifies the continuation of these exemptions for the period of extended operation." 10 CER 54.21(c)(2) 5.0 Prerequisites None Oyster Creek License Renewal Project PLI-6 Rev 2 Project Level Instruction 6 Sheet 5 of 16 Evaluation of Time Limited Aging Analyses 6.0 Instructions The process of identifying and dispositioning TLAAs consists of the following basic steps.-Identification of Industry Generic TLAA Issues-Identification of Plant Specific Potential TLAA Issues-Evaluation of Potential TLAAs to identify TLAA Applicable to Oyster Creek-Disposition of Each TLAA in Accordance with the License Renewal Rule-Review of License Exemptions

-Documentation of the Evaluation and Disposition Results in a TLAA Report 6.1 Identification of Industry Generic TLAA Issues The industry and NRC have developed a set of issues generally common to each plant applying for license renewal. These generic issues are: Reactor vessel neutron embrittlement Metal fatigue analysis Environmental Qualification (EQ) of electrical equipment Concrete containment tendon pre-stress analyses Containment fatigue These TLAA issues are described in industry guidance documents such as NEI 95-10 and in the NRC standard review plan for license renewal NUREG 1800. Additionally they are addressed in Section 4 of every applicant's license renewal application (LRA). These topics form the core list of potential Oyster Creek TLAAs. Each of them applies to Oyster Creek with the exception of containment concrete pre-stress analysis.

Each of these generic items contains one or more TLAAs and will be addressed by a specific analysis.

They are discussed in Section 4 of the LRA.Review NUREG 1800 and other Applicants to identify generic TLAAs. Add applicable issues to Exhibit 1 " Oyster Creek Potential TLAAs" under the category of "Generic".

6.2 Identification of Plant Specific Potential TLAA Issues 6.2.1 Review of License Renewal Experience Each previous license renewal applicant has also identified a number of TLAAs that are specific to that plant. These can be found in the Plant Specific heading of Table 4.1 in the LRA. These issues have the potential to represent a TLAA for Oyster Creek. Therefore, these plant-specific TLAAs are also added to list of OC potential TLAAs (PTLAA) for further evaluation.

Some of these plant specific issues clearly do not apply to Oyster Creek, for example those pertaining to jet pumps. Not every plant specific TLAA is expected to apply to Oyster Creek, but the identification of the issue provides a good reference point from which to Oyster Creek License Renewal Project PLI-6 Rev 2 Project Level Instruction 6 Sheet 6 of 16 Evaluation of Time Limited Aging Analyses search the Oyster Creek licensing basis for TLAAs.Review the LRA of other BWR applicants (Dresden, Peach Bottom, NMP-1, Browns Ferry and Brunswick) for applicable issues. Add new issues to the Oyster Creek list of potential TLAAs (Exhibit 1) under the category of "Plant Specific".

6.2.2 Expert Review An important element of this process is the utilization of experienced subject matter experts (SME). There are a number of individuals who have an in-depth knowledge of Oyster Creek issues past and present. The knowledge base of the Exelon subject matter experts for the reactor vessel and reactor vessel internals, EQ, and containment is utilized to develop potential TLAAs.Interview SMEs to identify potential TLAA issues. Add new issues the list of OC PTLAAs developed in 6.2.1(Exhibit

1) under the category of "SME".6.2.3 Word Search Process To provide reasonable assurance the list of Oyster Creek PTLAAs is complete, a word search of the CLB is performed to find any other potential TLAAs not previously identified.

An analysis may exist in the CLB that meets the strict definition of a TLAA, but is obscure because it has not been a concern for the plant.To facilitate the word search process a Oyster Creek CLB database was assembled from the documents listed in Exhibit 2. The majority of this database was developed from the licensing correspondence from approximately 1965 to early 2004. The correspondence and other CLB documents have been scanned and indexed electronically and placed in a Adobe Acrobat database.

The database can be searched by key words and phrases.The list of search words is displayed in Exhibit 3. The list focuses on the time limiting and 40-year plant life of the plant aspects of the TLAA definition (criteria 2 & 3 of 10 CFR 54.3). The list is the same set of words recommended in EPRI TR-105090 Table 4.1-4 with a few minor changes.6.2.3.1 Review the document containing the word match ('hit') and determine if the hit presents a PTLAA. An issue is considered a PTLAA if meets TLAA criterion 1 ( in-scope for license renewal);

and if meets either TLAA criterion 2 (considers the effects of aging) or TLAA criterion 3 (involves assumptions containing the life of plant).6.2.3.2 If the 'hit' represents a new PTLAA add the issue to the "List of Oyster Creek PTLAAs" (Exhibit 1), under the source category of "Word Search".

Oyster Creek License Renewal Project PLI-6 Rev 2 Project Level Instruction 6 Sheet 7 of 16 Evaluation of Time Limited Aging Analyses 6.2.3.3 Review licensing correspondence from 2004 to present, following steps 6.2.3.1. and 6.2.3.2.6.3 Evaluation of Potential TLAAs to Identify TLAA Applicable to Oyster Creek 6.3.1 Review each PTLAA listed on Exhibit I against the six TLAA criteria defined in l0CFR 54 to determine if a PTLAA qualifies as a TLAA. Use the CLB Database to find additional information if necessary.

Record the evaluation results on Exhibit 1.6.3.2 Some PTLAAs may require a more detailed evaluation to determine if they qualify as a TLAA. Document these evaluations in the TLAA Report described in Section 6.6.6.3.3 Add each PTLAA that is determined to be a TLAA to the Oyster Creek TLAA List (Exhibit 4).6.4 Disposition of Each TLAA in Accordance with the License Renewal Rule 6.4.1 Evaluate each TLAA in Exhibit 4 and determine the appropriate disposition for each TLAA in accordance withlOCFR54.21(c) as described in paragraph 4.5 above. TLAA can be demonstrated to acceptable for the period of extended operation in three ways:-verify the current analysis is valid for the extended period of operation-extrapolate or re-analyze the results of the current analysis-provide adequate aging management 6.4.2 Record the results of the disposition on Exhibit 1 and Exhibit 4.6.4.3 Provide the following information in accordance with NEI 95-10:-A list of the time-limited aging analyses and exemptions applicable to the plant-A description of the evaluation performed on each plant-specific TLAA and TLAA-related exemption-A general discussion of how the determinations were made-A list of substantiating references and source documents-A discussion of any assumptions or special conditions used in applying or interpreting the source documents 6.5 Review of License Exemptions 6.5.1 Obtain all license exemption pursuant to 10 CFR 50.12 from Licensing.

6.5.2 Review each exemption to determine if it based on a TLAA (defined in 4.4)6.5.3 Place the list of exemptions in the TLAA Report.

Oyster Creek License Renewal Project PLI-6 Rev 2 Project Level Instruction 6 Sheet 8 of 16 Evaluation of Time Limited Aging Analyses 6.5.4 For each exemption based on a TLAA (if any), provide the basis for continuation of the exemption for the period of extended operation, using the approach provided in paragraph 6.4 above.6.5.5 Place these justifications (if any) in the TLAA report.6.6 Documentation of the Evaluation and Disposition Results in a TLAA Report 6.6.1 The disposition of each TLAA shall be documented in a TLAA report.6.6.2 The TLAA report shall contain the sections specified in Exhibit 6. The report format shall be similar to those in previous LRA's so that the text can be readily used in the development of the TLAA Section (Section 4) of the Oyster Creek LRA.6.6.3 The report shall be peer reviewed and approved.7.0 Exhibits Exhibit I Exhibit 2 Exhibit 3 Exhibit 4 Exhibit 5 Exhibit 6 Exhibit 7 List of OC PTLAAs Oyster Creek CLB Database Sources List of Search Words List of OC TLAA TLAA Report Format Flow Chart -Development of Potential TLAA List Evaluation Flow Chart -Evaluation and Disposition TLAA Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Rev I Sheet 9 of 16 Exhibit 1 List of Oyster Creek PTLAAs-Source-- -Description

-TLAA_: Disposition

-Comments Reactor Vessel Neutron Embrittlement Generic 10 CFR 50 Appendix G Reactor Vessel Rapid Failure Propagation and Brittle Fracture Considerations:

Charpy Upper-Shelf Energy (USE) Reduction and Generic Adjusted Reference Temperature Analysis; Operating Pressure-Temperature Limit (P-T Limit) Curves Generic RPV Circumferential Weld Examination Relief Generic Reactor Vessel Axial Weld Failure Probability Metal Fatigue Generic Reactor Vessel Fatigue Analyses Generic Reactor Vessel Intemals Fatigue and Embrittlement Piping and Component Fatigue and Thermal Cycles Generic Fatigue Analyses of the Isolation Condenser System and Components Generic Fatigue Analyses of RCPB Piping; and Design Thermal Cycle Assumptions for Other RCPB lines Generic Assumed Thermal Cycle Count for Allowable Secondary Stress Range Reduction in Piping and Components Generic Effects of Reactor Coolant Environment on Fatigue Life of Components and Piping (Generic Safety Issue 190)Generic Environmental Qualification of Electrical Equipment (EQ)Loss of Pre-stress in Concrete Containment Tendons (The Oyster Creek containment has no pre-stress tendons.)

Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Rev 1 Sheet 10 of 16 Source Description TLAA Disposition Comments Containment Fatigue Analyses Generic Fatigue Analyses of Containment Pressure Boundaries:

Analysis of Suppression Generic Fatigue Analysis of SRV Discharge Lines (Inside the Wetwell) and External Suppression Chamber-Attached Piping, and their Penetrations Generic Fatigue Analysis of SRV Discharge Lines (Inside the Wetwell) and External Suppression Chamber-Attached Piping, and their Penetrations Generic Expansion Joint and Bellows Fatigue Analyscs: Drywell to Suppression Chamber Vent Bellows Generic Expansion Joint and Bellows Fatigue Analyses -Containment Process Penetration Bellows I I I I t I J I J J .1.

Oyster Creek License Renewal Project PLI-6 RevI Project Level Instruction 6 Sheet 11 of 16 Evaluation of Time Limited Aging Analyses Exhibit 2 Oyster Creek CLB Database Sources* Oyster Creek UFSAR* Oyster Creek FDSAR* NUREG 0822 (SEP)* NUREG 1382 ( SER forFTOL)* Tech Specs and Bases* Fire Hazard Analysis* Quality Assurance Plan* COLR* OCDM* Licensing Correspondence (1965 to 2004), including:

-NRC SER's-Tech Spec Amendments

-LERs-Responses to Generic Letters, Bulletins-NRC Inspections

-Violation Responses Oyster Creek License Renewal Project PLI-6 Revl Project Level Instruction 6 Sheet 12 of 16 Evaluation of Time Limited Aging Analyses Exhibit 3 List of Search Words 40 years Life of the Plant Plant life License term Design life Lifetime License period Component life Equipment life License term EFPY Effective Full Power Years Life expectancy Corrosion allowance Qualified life Thermal cycles Fatigue Usage Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Revl Sheet 13 of 16 Exhibit 4 List of Oyster Creek TLAAs TLAA Description Disposition Section Category DecipinCategory

1. Neutron Embrittlement of the Reactor Vessel and Internals 4.2 Upper-Shelf Energy §54.21 (c)(1)(ii) 4.2.1 Adjusted Reference Temperature Analysis §54.21 (c)(1)(ii) 4.2.2 Pressure-Temperature (P-T) Limits §54.21 (c)(1)(ii) 4.2.3 Elimination of Circumferential Weld Inspection

§54.21(c)(1)(ii) 4.2.4 Axial Weld Failure Probability

§54.21(c)(1)(ii) 4.2.5.2.. Metal Fatigue Analysis 4.3 Reactor Vessel Fatigue Analyses §54.21(c)(1)(iii) 4.3.1 Fatigue Analysis of Reactor Vessel Internals 4.3.2 Core Shroud and Repair Hardware §54.21(c)(1)(i) 4.3.2.1 Reactor Coolant Pressure Boundary Piping and Component Fatigue 4.3.3 Analysis Reactor Coolant Pressure Boundary Piping and Components

§54.21 (c)(1)(i) 4.3.3.1 Designed to B31.1, ASME Section III Class 2 and 3, or ASME Section Vill Class B and C Fatigue Analysis of the Isolation Condenser

§54.21 (c)(1)(i) 4.3.3.2 Effects of Reactor Coolant Environment on fatigue life of §54.21 (c)(1)(i) 4.3.4 components and piping and§54.21 (c)(1)(iii)

3. Environmental Qualification (EQ) _____=__Electrical Equipment EQ §54.21 (c)(1)(iii) 4.4 4. Concrete Containment Tendon Prestress Analysis 4.5 5.. Primary Containment, Attached Piping, and Components Ad _____: ____._ 4.6 Suppression Chamber, Vents, and Downcomers, EMRV Discharge

§54.21 (c)(1)(i) 4.6.1 Piping Inside the Suppression Chamber, External Suppression and Chamber Attached Piping, Associated Penetrations, and Drywell-to-

§54.21 (c)(1)(iii)

Suppression Chamber Vent Line Bellows Containment Process Penetration Bellow Fatigue Analysis §54.21(c)(1)(i) 4.6.2 and§54.21 (c)(1)(iii)

6. Other Plant-Specific TLAAs 4.7 Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 RevI Sheet 14 of 16 Exhibit 5 TLAA Report Format 1.2.3.Signature page for preparer and reviewer Table of Contents Introduction and Overview 4. Methodology

5. Disposition of Each TLAA 5.1 Summary of Issue 5.2 Current analysis results 5.3 Disposition Evaluation

6. License Exemptions 6.1 List of Exemptions 6.2 Justifications

7. References Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Rev I Sheet 15 of 16 Exhibit 6 Development of Potential TLAA (PTLAA) List NUREG 1800=a I I J Identify Generic TLAA!s (6.1)14 Identify Plant Specific TLAA's (6.2.1)__ Add to PTLAA Lis --Add new Issues to PTLAA List_Previous LRA's D-QC NMP1 BFN 14 r Perform SME Review to Identify OC Plant specific PTLAA's (6.2.2)Perform Word Search of CLB to Identify OC Plant specific Generic PTLAA's (6.2.3)-Add new Issues to PTLAA List_*-Add new Issues to PTLAA List_PTLAA List (Exhibit 1)

Oyster Creek License Renewal Project Project Level Instruction 6 Evaluation of Time Limited Aging Analyses PLI-6 Rev I Sheet 16 of 16 Exhibit 7 Evaluation and Disposition of TLAA's PTLAA Evaluation (6.3)PTLAA List ( Exhibit 1)-Review next item A No Des issue satisfy all six criteris of e 1 OCFR5054.3(a)

OC TLAA List (Exhibit 4)TLAA DisDosition (6.4)

Oyster Creek License Renewal Project Project Level Instruction 8 Aging Management Program Reviews PLI-8 Rev. 3 Sheet 1 of 8 Oyster Creek License Renewal Project Project Level Instruction 8 Aging Management Program Reviews Oyster Creek License Renewal Project Project Level Instruction 8 Aging Management Program Reviews PLI-8 Rev. 3 Sheet 2 of 8 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Mark Miller Don Warfel 8/19/04 1 Al Fulvio/Lou Corsi Mark Miller Don Warfel 4/20/05 2 Lou Corsi Mark Miller Don Warfel 6/22/05 3 Shannon Rafferty John Hufnagel Don Warfel 9/08/05 Revision Log Rev. Description of the Change 0 Initial Issue 1 Added Guidance contained in Exhibits 2 and 3 and approval process prior to Plant Health Committee 2 Added or updated references to NEI and NUREG 1800 and 1801 3 Updated for formatting reasons.

Oyster Creek License Renewal Project PLI-8 Rev. 3 Project Level Instruction 8 Sheet 3 of 8 Aging Management Program Reviews 1.0 Purpose This instruction describes the procedural requirements for Aging Management Program Reviews that are prepared for the Oyster Creek License Renewal Project.2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in preparing Oyster Creek License Renewal Aging Management Program Review documents.

3.0 References 3.1 10 CFR Part 54 -The License Renewal Rule 3.2 NEI 95-10 Rev. 5 -Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule 3.3 ER-AA-I 100 "Implementing and Managing Engineering Programs" 3.4 ER-AA-2001 "Plant Health Committee" 3.5 PLI-1 "Preparation of Project Level Instructions and Position Papers" 3.6 PLI-5 "Aging Management Reviews" 3.7 PLI-1 1 "License Renewal Document Control" 3.8 RM-AA-101 "Records Management Program" 3.9 Draft NUREG-1800, January 2005 3.10 Draft NUREG-1801, January 2005 4.0 Definitions None.-5.0 Prerequisites None.

Oyster Creek License Renewal Project PLI-8 Rev. 3 Project Level Instruction 8 Sheet 4 of 8 Aging Management Program Reviews 6.0 Instructions 6.1. Obtain an electronic copy of the most recent AMP that was done for the Dresden/Quad Cities LR project to use as a starting point for the review for the Oyster Creek LR project.6.2. Compare the Dresden/Quad Cities NUREG-1801 program description with the actual NUREG to verify that it is exactly the same.6.3. Identify and obtain Oyster Creek AMP related source documents and implementing procedures.

Verify completeness of the list with the site and corporate program owners.Typical documents include: Corporate procedures, site procedures, FASAs, Program Health Reports, SHIP Reports, System Manager Notebooks, Program Notebooks, Program Plans, Chemistry Notebook, NOS assessments, NRC reports, INPO reports. For operating experience, search CAPs.6.4. Revise the Program Elements table to provide the Oyster Creek Basis for consistency with the GALL program description.

6.5. During the writing of the OC Basis, interaction with the site program owner will be necessary to obtain all of the information about how the site implements the program elements.

Determine if the program is in the process of being revised. If it is undergoing revision, determine the timing of the change in relation to the timing of the LRA submittal.

Compare the latest revision with the GALL program description.

6.6. Identify any gaps that may exist between the GALL program description and the current (or planned) implementation of the program at OC. These gaps are called "Exceptions to GALL". Use of the comments field is one way to capture the exceptions.

6.7. Identify options to resolve any "Exceptions to GALL". Draft the LRA Appendix A and Appendix B program description.

See Exhibit 3 for format guidance.6.8. Discuss the "Exceptions to GALL" closure options with the Site Lead License Renewal Engineer.6.9. Discuss the proposed changes with the site program owner to obtain concurrence on the proposed change.6.10. Discuss any new programs or program enhancements that are required for aging management with the affected site department management for approval and consideration for review by the Plant Health Committee.

Oyster Creek License Renewal Project PLI-8 Rev. 3 Project Level Instruction 8 Sheet 5 of 8 Aging Management Program Reviews 6.11. As Aging Management Reviews (see PLI-5) are completed, incorporate their results into the Program document.6.12. Finalize the Program document and LRA Appendix B description.

This requires completion of the Aging Management Reviews that could possibly impact the Program document.

If the results of the Aging Management Reviews change the Program commitments, consider the need for review by the Plant Health Committee.

6.13. Complete the initial approval for the Program document in accordance with PLI-1 1. This approval is to document completion of steps 6.1 through 6.12.6.14. As required, obtain approval by the Plant Health Committee for any required program enhancements.

Note: The following steps may be completed after the LRA is submitted.

6.15. Identify all procedures and implementing activities that are required for the Program.Markup the changes required.

Populate the procedure tracking list. Procedure revisions can be deferred until after NRC reviews of the LRA.Refer to Exhibit 2 Aging Management Activity Implementation for guidance.6.16. Create Commitment Tracking items for each program implementation requirement.

6.17. Complete the Implementing Activities section of the Program document.6.18. Complete the final approvals for the Program document in accordance with PLI-1 1.7.0 Exhibits Exhibit 1 -Aging Management Program Review Process Exhibit 2 -Aging Management Activity Implementation Exhibit 3 -Format of LRA Appendix B Program descriptions Oyster Creek License Renewal Project Project Level Instruction 8 Aging Management Program Reviews PLI-8 Rev. 3 Sheet 6 of 8 Exhibit 1 -Aging Management Program Review Process (i) From O/QC Aging (1 ) Identify and obtain OC (i) Revise the 'Program (I) Interact with site (1 1 Management Activities AMP-related source Elements' table to program owners I SMEs Fill In OC AMP Report, obtain an documents

& _ reflect OC specific & others to obtain Evaluation based on electronic copy of most Implementing Information, needed Info or answers Info obtained from Site recent AMP Evaluareton procedures to create draft to questions for the ~~~ ~C AMP oIneetl OCMEvaiuatlon OC source documents are generally available in EDMS.No o s (01Conduct telecon orlmeeting with site NO stakeholders to AGREE ( ) ( ) Present gap closure approach l Prepare gap closure )Ys approaches to site perIdentify PHC Concur? management (PHC) for (could use comments GALL -OC AMP gaps-concurrence per .f.ield)> / Site Interface Plan_ Initial approvalAMP Only substantive changes Evaluation per PU-11 List Gaps Temporarily document need go to PHC. e.g., List closure options *gaps' in 'Comments YES commitments with a cost Send to site field impact stakeholders (71) Complete Program (31) Identity all corporate

(\j) Create Commitment (1 1)l Element' Table, l and specificsite l lIdentify program calcs l Tracking beans for eachl Complet' Conclusion-'l, procedure annotatlons I that require revision for F procedure annotated I t' Exceptions' , enhancements/Inew the extended period of enhanced/Inew

& 'I1mplementinqg

' Comments'-and l lprocedures required to operation program calc revisionAcitesscio

'References' sections Implement the AMP required Send markups to site TLAA eftort should identily for implementation.

& capture this This can be done 13 Incorporate Program flofn R umta applicability scope from the f L s r esults of the Aging Approve AMP i Management Reviews. lEvaluation per PU-t11lAny changes to the Program commitments may require PHC review.Aging Management Program Review Process Oyster Creek License Renewal Project PLI-8 Rev. 3 Project Level Instruction 8 Sheet 7 of 8 Aging Management Program Reviews Exhibit 2 -Aging Management Activity Implementation Process: Identify the aging management activities required for aging management; e.g. visual inspection, NDE examination, chemistry parameter limits, etc.Find existing procedures, programs, or work orders that implement the activities Verify that the existing procedures include the required scope, monitor the required parameters, and provide appropriate information about the detection of aging effects and acceptance criteria.

Also, ensure that the frequency of the activity will result in adequate aging management If there are no existing procedures for the required activities, then specify a solution; e.g. new procedure, work order, surveillance test, etc.If the existing procedures are lacking, then enhance them If the existing procedures are adequate, then only an annotation is required Procedure implementation guidelines:

The procedures credited for license renewal need to be administratively controlled The procedures need to implement the required aging management activities You are done annotating when you have credited a step that will implement the activity The annotation of the procedure ensures that it will not be deleted or altered without an evaluation of the commitment requirements It is preferable to be able to credit corporate procedures and T&RM's for license renewal Site procedures that implement corporate procedure requirements should be used if the corporate procedure lacks specificity for the required aging management activity Preventive Maintenance work orders can be credited when no procedure requiring the activity exists or when the existing procedure does not provide for the specific aging management activity Oyster Creek License Renewal Project PLI-8 Rev. 3 Project Level Instruction 8 Sheet 8 of 8 Aging Management Program Reviews Exhibit 3 -Format of LRA Appendix B Program descriptions For NUREG-1801 programs, use the following format for LRA Appendix B: Program Description NUREG-1801 Consistency Exceptions to NUREG-1801 Enhancements Operating Experience Conclusion When there are no Exceptions, or Enhancements, include the paragraph heading and say "None".For plant specific programs, use the following format for LRA Appendix B: Program Description Aging Management Program Elements ( 10 elements)Enhancements Conclusion Oyster Creek License Renewal Project Project Level Instruction 11 License Renewal Document Control PLI- 1 Rev. 2 Sheet 1 of 5 Oyster Creek License Renewal Project Project Level Instruction 11 License Renewal Document Control Oyster Creek License Renewal Project Project Level Instruction 11 License Renewal Document Control PLI-1I Rev. 2 Sheet 2 of 5 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Dave Honan Don Warfel 7/12/04 1 George Beck Dave Honan Don Warfel 6/22/05 2 Louis J. Corsi Stu Getz Don Warfel 9/1/05 Revision Log Rev. Description of the Change 0 Initial Issue 1 Add review and approval requirements for Position Papers and Project Level Instructions; update references 2 Revised para. 6.2.2 and 6.2.4 for clarity Oyster Creek License Renewal Project Project Level Instruction 1I License Renewal Document Control PLI- l Rev. 2 Sheet 3 of 5 1.0 Purpose This instruction describes the requirements for approvals and record retention of documents that are prepared for the Oyster Creek License Renewal Project.2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in preparing Oyster Creek License Renewal Project documents.

3.0 References 3.1 10 CFR Part 54 -The License Renewal Rule 3.2 NEI 95-10 Rev. 5 -Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule 3.3 PLI-1 "Preparation of Project Level Instructions and Position Papers" 3.3 PLI-15 "License Renewal Document Change Request Process" 3.4 RM-AA-101 "Records Management Program" 4.0 Definitions Record Copy: The original or copy of an authenticated record or document that is placed on file as the official copy and is turned over to Records Management for retention.

5.0 Prerequisites None.6.0 Instructions 6.1 Project Level Instructions contain the guidance for performing the tasks required to develop the License Renewal Application (LRA) and administrative functions.

The list of Project Level Instructions which control the associated tasks is in PLI-I "Preparation of Project Level Instructions and Position Papers".

Oyster Creek License Renewal Project PLI-II Rev. 2 Project Level Instruction 11 Sheet 4 of 5 License Renewal Document Control 6.2 The following approvals are required for License Renewal products: 6.2.1 Scoping Package: Preparer, Reviewer, Site Reviewer, LR Technical Lead 6.2.2 Screening Package: Preparer, Reviewer, Site Reviewer, LR Technical Lead In some cases, the sign-off of the Aging Management Review form was used as concurrence of the Screening package.6.2.3 Aging Management Reviews: Preparer, Reviewer, Site Reviewer, LR Technical Lead 6.2.4 Aging Management Program Reviews (10 Element):

Preparer, Reviewer, Site Reviewer, LR Technical Lead 6.2.5 TLAA Report: Preparer, Reviewer, Site Reviewer, Site Engineering Director (If new commitment activities are identified), LR Technical Lead 6.2.6 Position Papers: Preparer, Reviewer, Site Reviewer (not required for all Position Papers. Site review may be documented in a PIMS evaluation), LR Technical Lead 6.2.7 Proiect Level Instruction:

Preparer, Reviewer, LR Technical Lead 6.3 The initial issue of an approved document is revision 0. Any subsequent revisions are indexed with integers (i.e. 1, 2, etc.). Revisions are performed in accordance with PLI-15"License Renewal Document Change Request Process".6.4 The approvals for the Site Engineering Director and the LR Technical Lead may be delegated.

6.5 After initial Site Review approvals, subsequent site approvals are only necessary if the change is significant

-i.e. the revision changes the conclusion of whether the system or structure is in scope or changes the commitments for implementing an aging management program.6.6 The Record Copy of License Renewal documents shall be retained in accordance with RM-AA-101 "Records Management Program".

Oyster Creek License Renewal Project Project Level Instruction 11 License Renewal Document Control PLI-11 Rev. 2 Sheet 5 of 5 7.0 Exhibits None Oyster Creek License Renewal Project Project Level Instruction 12 Training of License Renewal Project Team and Site Personnel PLI-12 Rev. 3 Page 1 of 6 Oyster Creek License Renewal Project Project Level. Instruction 12 Training of License Renewal Project Team And Site Personnel Oyster Creek License Renewal Project Project Level Instruction 12 Training of License Renewal Project Team and Site Personnel PLI-12 Rev. 3 Page 2 of 6 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Tom Quintenz Don Warfel 1 George Beck Dave Honan Don Warfel 6/22/05 2 John Hufnagel Dave Honan Al Fulvio 8/18/05 3 Shannon Rafferty John Hufnagel Don Warfel 9/08/05.4. .4-Revision Log Rev. Description of the Change 0 Initial Issue 1 Update references 2 Clarified Applicability Section and Step 6.2 3 Formatting Changes I .I_ _ I Oyster Creek License Renewal Project Project Level Instruction 12 Training of License Renewal Project Team and Site Personnel PLI-12 Rev. 3 Page 3 of 6 1.0 Purpose This instruction provides the guidance and requirements for the training of the License Renewal Project Team and Site personnel.

2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in preparing Oyster Creek License Renewal Project Documents and to Oyster Creek Site personnel in reviewing project products.3.0 References 3.1 10 CFR Part 54 -The License Renewal Rule 3.2 NEI 95-10 Rev. 5 -Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule 3.3 PLI-1 "Preparation of Project Level Instructions and Position Papers" 3.4 Draft NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", January 2005 3.5 Draft NUREG-1801, "Generic Aging Lessons Learned (GALL) Report", January 2005 4.0 Definitions None.5.0 Prerequisites None.

Oyster Creek License Renewal Project PLI-12 Rev. 3 Project Level Instruction 12 Page 4 of 6 Training of License Renewal Project Team and Site Personnel 6.0 Instructions 6.1 Training for License Renewal Project Team members is accomplished in three formats: classroom instruction, reading packages, and peer instruction.

6.2 Classroom instruction is performed by a subject matter expert. There is a prepared lesson plan (or equivalent) which outlines the objectives and scope of the training session 6.3 Reading packages cover the large reference documents for License Renewal. The reader should become familiar with the general format and content of the documents.

The required reading includes: 1. 1OCFR54 2. NEI 95-10 3. NRC SRP NUREG 1800 4. GALL NUREG 1801 5. BWROG Training Manual 6. EPRI Tools -Mechanical, Structural, Electrical 6.4 Peer instruction is performed by team members when they have "piloted" a LR process and can share with the team their lessons learned. Also, team members that have performed the activities for previous license renewal projects will mentor the new project team members in the performance of license renewal activities.

This type of training is basically ongoing throughout the project and is an integral part of the project.6.5 A License Renewal Project Team Qualification form (Exhibit 1) shall be completed for each individual on the team. This form shall be signed by either the License Renewal Manager or the Project Team Technical Lead.6.6 Project team personnel that have participated in previous license renewal projects may be deemed qualified for this project by virtue of that experience.

The previous project would have similar training activities.

This assessment is performed by the License Renewal Manager and is documented on the License Renewal Project Team Qualification form (Exhibit 1).6.7 Site personnel training involves a familiarization with the license renewal activity product that they are reviewing.

This is performed by the Site License Renewal Lead Engineer prior to the review activity.

In addition, more generic license renewal process Oyster Creek License Renewal Project Project Level Instruction 12 Training of License Renewal Project Team and Site Personnel PLI-12 Rev. 3 Page 5 of 6 training is given to the work groups that are involved in the process for the site.Documentation of site training is the responsibility of the Site License Renewal Lead Engineer.

Oyster Creek License Renewal Project Project Level Instruction 12 Training of License Renewal Project Team and Site Personnel PLI-12 Rev. 3 Page 6 of 6 7.0 Exhibits Exhibit 1 License Renewal Project Team Qualification Name: Initial Classroom Training Date: Instructor:

Required Reading completed Date:-Above training is waived because the individual has participated in a previous license renewal project, which had similar training activities:

Previous license renewal project: Oualification certification:

-is qualified to perform activities for the Oyster Creek License Renewal Project Date: Manager or Technical Lead Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 2 Sheet 1 of 81 Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 2 Sheet 2 of 81 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 H. D. Honan Al Fulvio D. B. Warfel 5-28-04 1 L. J. Corsi Stuart Getz D. B. Warfel 9-1-05 2 S. B. Rafferty J. G. Hufnagel D. B. Warfel 9-8-05 Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 2 Sheet 3 of 81 Revision Log I Rev. Description of the Change 0 Initial Issue 1 Revised Attachment A to clarify Aging Management Program Review and License Renewal Application.

2 Formatting and Reference Changes.J_ __ I I Oyster Creek License Renewal Project PLI-15 Rev. 2 Project Level Instruction 15 Sheet 4 of 81 License Renewal Document Change Request Process 1.0 Purpose This instruction describes the process to be used by Exelon to revise previously approved License Renewal documents.

This includes, but is not limited to, Scoping, Screening and Aging Management Review packages, Position Papers, Project Level Instructions, and the Aging Management Program Review documents.

2.0 Applicability This instruction applies to the Oyster Creek License Renewal Project organization personnel engaged in maintaining the accuracy of Oyster Creek License Renewal documents.

3.0 References 3.1 10 CFR Part 54 -The License Renewal Rule 3.2 NEI 95-10 Rev. 54 -Industry Guidance for Implementation of 10 CFR 54 -the License Renewal Rule 3.3 PLI-1 I "License Renewal Document Control" 3.4 Draft NUREG-1800, January 2005 3.5 Draft NUREG-1801, January 2005 4.0 Instructions 4.1 If the need for a license renewal document change is identified, then the cognizant License Renewal Engineer shall initiate a License Renewal Change Request (LRCR, Attachment A). Revisions to license renewal documents may be necessary for any of several reasons, e.g.:* New or revised NRC requirements

• Format, content or process lessons learned on prior work products* Correction of errors or oversights

• Updating Procedures for commitment annotation

• Self Assessment Results* Condition Reports* Plant Modifications Oyster Creek License Renewal Project PLI-15 Rev. 2 Project Level Instruction 15 Sheet 5 of 81 License Renewal Document Change Request Process* NRC Request for Additional Information (RAIs) & Exelon responses* License Renewal Safety Evaluation Report (SER)4.2 Process the LRCR as follows using Attachment A:* Enter a description of the proposed change.* Enter the reason for making the change (change driver) and the reference number of the document driving the change (e.g., CR No.), if applicable.

• Identify all the License Renewal documents that will need to be changed and the nature of the change(s) to each.* Obtain concurrence from the Technical Lead for the proposed changes.* Enter the change in the LRCR Log (Attachment B). Take the next sequential number and record that number on the LRCR.4.3 Implement the proposed change following LRCR approval as follows:* Make change(s) to the effected document(s) or the LR Database, as described in the approved LRCR.* Advance the revision number of the effected document(s) to the next numerical revision level.* Obtain a Peer Review from another License Renewal Engineer.

The peer will verify the proposed changes were accurately incorporated, and verify that all impacted documents have been revised appropriately.

• If the change is considered significant, obtain a concurrence review from the cognizant subject matter expert and / or System Manager. Changes which bring a system into the scope of the Rule or change an aging management program (or its implementing procedures) are considered significant.

Site Engineering Director signature is required if new commitment activities are identified.

• Update the LR Project commitment tracking mechanism (e.g., CTAI) if necessary.

• Obtain the approval of the Technical Lead on the revised document(s) and on the LRCR.* Place a copy of the revised document(s) in the appropriate file. Mark the previous revision "Superseded".

Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 2 Sheet 6 of 81 Attachment A License Renewal Change Reiuest LRCR No. Initiated By: Step Action Completed By /Date 1. Describe the requested change: 2. What is the basis for the change (change driver)?: 3. Describe how this change will effect: 3.1 Position Paper(s): 3.2 Project Level Instruction(s):

3.3 Scoping Package(s):

3.4 Screening Package(s):

3.5 Aging Management Review(s):

3.6 Aging Management Program Reviews (10 Element Form)3.7 License Renewal Database: 3.8 License Renewal Application Section(s): (including Sections 1 through 4 and Appendix A & B)3.9 License Renewal Commitment(s):

4. Obtain Technical Lead concurrence.

5. Enter the Change into the LRCR Log.6. Process the Change: 6.1 Make changes to all effected documents or the LR Database.6.2 Obtain a Peer Review of changed documents that verifies all impacted Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 2 Sheet 7 of 81 Attachment A License Renewal Change Request LRCR No. Initiated By: Step Action Completed._ By /Date documents have been revised & commitment changes identified.

6.3 The change was considered significant (changes the conclusion of the system or structure from in or out of scope of the rule or changes an Aging Management Program) and concurrence review from the site System Manager or SME was obtained.SysMgr/SME:

• Date of Concurrence:

• (Name)*Enter "NA" if the change was not considered significant 6.4 Identify and update the Commitment Tracking Mechanisms (i.e. Action Tracking, Implementing procedure, Predefine, etc.) as necessary:

6.5 Print all affected documents for final approval 6.6 Obtain Technical Lead Approval 6.7 All completed forms have been filed with the affected document (Scoping, Screening

& AMR Packages, etc.).

Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 0 Sheet 8 of 8 Attachment B License Renewal Change Request Log LRCR Init'd Tech Change-Affected Documents (Yes/No):

Doc's Peer Change No. By Lead Rev'd Review Appvd Concur __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Compit PLIs PPs Scoping Screen AMRs AMPR LRA Commit 0001 ___ _ Pkgs -ments 0001 _ _ = =__ _ = = -= =____0002 _== ====__0003 = = = _=_=-__

PP-2, Rev 2 Sheet I of 26 Safety Related Systems and Structures Oyster Creek Nuclear Generating Station License Renewal

.I PP-2, Rev 2 Sheet 2 of 26 Approval Page Revisio Prepared by: Checked by. Approved by: n 00 Louis J. Corsi Mark Miller Don Wadfel Date 1/08/04 1/21/2004 1/21/2004 01 Louis J. Corsi Mark Miller Don Wadfel Date 4/1212005 4/2212005 4/2212005 Louis J. Corsi Date 6/21/2005 I I PP-2, Rev 2 Sheet 3 of 26 I Revision Summary Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)1 Revised to agree with Changes to PP-1 2 Revised to make reference to latest NEI and Draft NUREG 1800 & 1801 3 4 5 PP-2, Rev 2 Sheet 4 of 26 TABLE OF CONTENTS Page IDENTIFICATION OF SAFETY RELATED SYSTEMS AND STRUCTURES Approval Page ................................

2 Revision Summary ............................

3 TABLE OF CONTENTS ............................

4 1.0 Purpose ............................

5 2.0 Scop ............................

5 3.0 Methodology

............................

7 4.0 References

...........................

10 5.0 Attachments

...........................

12 Table 1 (11 Pages) ...........................

12 Table 1 Notes (2 Pages) .23 PP-2, Rev 2 Sheet 5 of 26 1 1.0 Purpose The license renewal rule 10 CFR Part 54 requires the licensee to include in the scope of license renewal review, all safety related systems or structures that fall within the scope of 10CFR54.4(a)(1):

Part 54 Reference§54.4 (a) Plant systems, structures, and components within the scope of this part are -(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined as in 10 CFR 50.49 (b)(1)) to ensure the following functions

-(i) The integrity of the reactor coolant pressure boundary;(ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in § 50.34(a)(1), 50.67(b)(2), or §100.11 of this chapter, as applicable.

This position paper identifies the Oyster Creek Nuclear Generating Station (OCNGS)systems and structures that are included in the scope of license renewal under the above 10CFR54.4(a)(1) safety related scoping criteria.

The required systems and structures are identified in Table 1.Results of this paper (OC safety related systems), along with the output from paper PP-13 (design-basis events), will be used to populate the corresponding license renewal database field. Systems and structures listed will be answered "Yes" to scoping criteria 54.4(a)(1) for Safety Related.This position paper is for the use of personnel engaged in the preparation, review, or approval of scoping evaluations in support of license renewal activities for Oyster Creek.Rational has been provided within this document for positions, which clarify classifications.

This position paper will be used in conjunction with Project Level Instruction PLI-2, "Scoping of Systems and Structures.

This paper documents the technical basis for the license renewal scoping conclusions, along with the methodology and CLB source documents used. It identifies which of the "License Renewal Systems& Structures", are required to support 1 OCFR54.4(a)(1) safety related functions, as described in the CLB.2.0 Scope PP-2, Rev 2 Sheet 6 of 26 The scope of this document are those systems and structures at OCNGS that are identified as safety related and included in the scope of license renewal in accordance with 1 OCFR54.4(a)(1).

Most components at OCNGS can be associated with a system or structure through design drawings or the Component Record List (Ref. 5). License renewal scoping is performed at the system and structure level. The scope of this review is therefore limited to the identification of systems and structures.

The identification of individual components is not within the scope of this position paper.Requirements for Safety Related A safety-related system and structure is within the scope of license renewal if it is relied upon to remain functional during and following design basis events as defined in§50.49(b)(1) to ensure the following functions:

1. The integrity of the reactor coolant pressure boundary;2. The capability to shut down the reactor and maintain it in a safe shutdown condition; or 3. The capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposure comparable to the guidelines in § 50.34(a)(1)

§ 50.67(b)(2) or § 100.11 of this chapter, as applicable.

It is conceivable that, because of plant unique considerations and preferences, some systems, structures and components that do not perform any of the requirements of§54.4(a)(1) may have previously been designated as safety related. Therefore, a system, structure or component may not meet the requirements of §54.4(a)(1) although it is designated as safety related for plant-specific reasons. However, the systems, structures and components would still need to be considered for inclusion into the scope of the Rule using the criteria in §54.4(a)(2) and §54.4(a)(3).

System and structure scoping under 10CFR54.4(a)(2) and 10CFR54.4(a)(3) are addressed in position papers PP-3, 4, 5, 6 and 7.The following table is provided to help reviewers when going through historical documentation.

Oyster Creek previously used quality classifications located in station documents which will be treated as equivalent in accordance with the below table: New QA New QC New Old Old QC Old Class Code Definition Classification Code Definition Q Q Safety NSR 1 Nuclear Related Safety Related A A Augmented RR 2 Regulatory Quality Required N N Non-Safety Other 3 Other IRelated l PP-2,Rev 2 Sheet 7 of 26 At OC, the current licensing basis (CLB) definition of safety related (Q) is provided in reference 6 and is as follows: A structure, system or component shall be classified as Safety Related (Q) if designed to remain functional for all design basis conditions necessary to ensure:* Integrity of reactor coolant pressure boundary,* Capability to shutdown reactor and maintain it in a safe (hot) shutdown condition, or* Capability to prevent or mitigate consequences of accidents which could result in potential off-site exposures comparable to guideline exposures of 1OCFR100 This definition is nearly identical to the definition from 1 OCFR54.4(a)(1), with the following exceptions:

Design Basis Events The Oyster Creek CLB definition refers to "all design basis conditions" while 1OCFR54.4(a)(1) is more specific, referring to design basis events as defined in§50.49(b)(1).

For Oyster Creek license renewal, position paper PP-13 will confirm that all applicable events are addressed.

Exposure Limits The Oyster Creek CLB definition refers to 10CFR100 for accident exposure guidelines.

The license renewal rule also references the guidelines in 1 OCFR50.34(a)(1) and 1 0CFR50.67(b)(2).

The different guidelines appear in three different code sections to address similar accident analyses performed by licensees for different reasons. The guidelines in 1 OCFR50.34(a)(1) and 1 OCFR50.67(b)(2) are applicable to facilities seeking a construction permit and to facilities seeking to revise the current accident source term used in their design basis radiological analyses, respectively, and are not applicable to OCNGS.The Oyster Creek CLB definition of safety related is consistent with the §54.4(a)(1) definition, and applies for purposes of identifying the safety related systems, structures and components that are in the scope of license renewal. This is consistent with NUREG-1800 section 2.1.3.1.1.

Items within the scope of the Quality Assurance Topical Report (QATR) are designated by a quality classification.

This classification process produces a Component Record List (CRL), which identifies the permanent plant structures, systems, and components that are within the scope of the QATR and their specific classification.

New Items to which the QATR applies shall be added to the Component Record List subsequent to their installation.

3.0 Methodology PP-2, Rev 2 Sheet 8 of 26 The Quality Assurance Topical Report (QATR), as referenced in the OCNGS UFSAR, establishes measures that provide a graded approach to quality at Oyster Creek (Reference 4, Appendix F).The scope of the QATR includes, but is not limited to, items and activities related to safe nuclear plant operation, protection of personnel, and protection of the public. To ensure consistency in identifying those items and activities within the scope of the QATR, a classification process has been developed and documented.

Items within the scope of the QATR are classified as "Nuclear Safety Related" (NSR) or"Augmented Quality." The classification process results are documented in the Component Record List (reference 5), which identifies the permanent plant structures, systems, and components that are within the scope of the QATR and their specific classification.

This classification of systems, structures and components at Oyster Creek is documented in the "QA Class" data field in the CRL. The "QA Class" data field is a controlled (design quality) field (reference 9). New Items to which the QATR applies are added to the Component Record List (CRL) subsequent to their installation.

The classification of structures, systems, and components is subject to independent design review as part of the classification process. Specific guidance used for determining the appropriate QA classification is provided in Section 4.2.3 of reference 6.The Oyster Creek UFSAR Section 17 references the Quality Assurance Topical Report which indicates that the Component Record List is the source document for identifying the list of safety related systems and structures.

The first step to create this list was to download all of the Oyster Creek CRL components into to an Access database.

The downloaded list of components was then filtered to identify only the Oyster Creek safety related "Q" components.

The filtered list was then used to place a "Y" next to the appropriate ES-017 system name in Table 1.The systems and structures identified in Table 1 are based on ES-17 system designations.

When performing license renewal scoping in accordance with PLI-02 (reference 11), it will be necessary to first refer to PP-1 to determine which ES-1 7 systems or structures are included in the license renewal system or structure under review. The boundaries of each license renewal system will be determined during the scoping process based on system intended functions and other considerations.

If any of the ES-1 7 systems or structures on Table 1 are included in the license renewal system or structure under review, then the Safety Related scoping question will be answered"Yes.Position paper PP-1 3 was developed to cover the second aspect of 1 OCFR54.4(a)(1) regarding design-bases events (as defined as in 10 CFR 50.49 (b)(1)). The purpose of PP-13 is: (1) To confirm that abnormal operational transients (AOTs) are to be considered when conducting scoping for license renewal; and (2) To identify the OCNGS systems and structures relied on to mitigate the effects of internal and external events including abnormal operational transients, anticipated operational occurrences, and natural phenomena as described in the current licensing basis (CLB).

PP-2, Rev 2 Sheet 9 of 26 The conclusion is that Abnormal Operational Transients and other design-basis events as defined in 10 CFR 50.49(b)(1) are specifically required to be considered in conducting scoping for license renewal.This position paper is considered a "living document" in that the CRL items will change as existing components may be downgraded or upgraded and may impact the system's as identified in this paper.Conservative CRL Classifications The conservative methodology used in this position paper results in a few instances where a system is classified as safety related even though the system has no safety related functions in the CLB. This is the result of some existing conservative system and component classifications in the CRL. The results of the review of these instances are documented in this section or in a scoping template for the system. The systems discussed below do not have any intended functions associated with 1 OCFR54.4(a)(1) license renewal scoping criteria.Containment Leak Rate Testing System 271 This system designation does not represent an actual installed system at Oyster Creek.There are no CRL components in this system except the F MISC 271 system identifier.

This system identifier "component" is conservatively classified as "Q" safety related. There are no safety related functions associated with this system, and so this system is not identified as safety related in Table 1.Drywell Cooling System 838 The Drywell Cooling System is conservatively classified as safety related in the CRL. The system includes the following CRL items classified as safety related: E CBM RF-1-1 480V MCC BREAKER FOR R.B. RECIRCULATION FAN RF-1-1 E CBM RF-1-2 480V MCC BREAKER FOR R.B. RECIRCULATION FAN RF-1-2 E CBM RF-1-3 480V MCC BREAKER FOR R.B. RECIRCULATION FAN RF-1-3 E CBM RF-1-4 480V MCC BREAKER FOR R.B. RECIRCULATION FAN RF-1-4 E CBM RF-1-5 480V MCC BREAKER FOR R.B. RECIRCULATION FAN RF-1-5 F MISC 838 DRYWELL COOLING SYSTEM The first five components are safety related circuit breakers located in safety related motor control centers. They are functionally provided to protect and isolate from the safety related power source, and do not provide a safety function related to the Drywell Cooling system. The breaker safety function is to protect the upstream electrical equipment.

Electrical breakers are active for license renewal (reference 2, NEI 95-10, Appendix B), and are therefore not subject to aging management review.The CRL "component" F MISC 838 is a system identifier representing the Drywell Cooling system. This system identifier "component" is conservatively classified as "Q" safety related. The Drywell Cooling system limits normal operating temperature in the PP-2, Rev 2 Sheet 10 of 26 containment and is used to mix, cool and purge the gases in the containment during normal plant operation (reference 3, Section 6.2.1.1.2).

There are no safety related functions associated with this system (reference 3, Section 9.4.2.2.2), and so this system is not identified as safety related in Table 1.Service Air System 851 The UFSAR discusses the service air and instrument air systems as one system called Service and Instrument Air. UFSAR (reference

3) Section 9.3.1.3 indicates that the Service and Instrument Air System is not safety related, except for those portions associated with operation of certain valves (MSIVs, secondary containment isolation and Reactor Building to Torus Vacuum Breakers).

The safety related portion of the air piping extends from the actuator of these valves to the associated isolation check valve including the piping to the air accumulator for each valve. These safety related parts of the system are supplied from the dried "control" air portion of the system, not from the Service Air system. On low air pressure, the Service Air system is automatically isolated.There are no safety related CRL components in the Service Air system, except the F MISC 851 system identifier.

This system identifier "component" is conservatively classified as "Q" safety related. The Service Air system is therefore not identified as safety related in Table 1.The QCL and CRL need to be revisited since it states, "the Service Air System does not perform a safety function.

It is being administratively classified NSR because the system includes containment isolation valves V-6S-0133 thru 0138 that isolate and must maintain containment integrity." The CRL currently shows that the valves are 0 and have been renumbered to System 241 -Containment Spray System.4.0 References

1. 10 CFR Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants.2. Nuclear Energy Institute (NEI), NEI 95-10, Industry Guideline on Implementing the Requirements of 10 CFR Part 54, Revision 5.3. OCNGS UFSAR, Revision 13, April 2003.4. NO-AA-1 0, Quality Assurance Topical Report 5. Oyster Creek Component Record List (CRL)6. EP-01 1 Methodology for Assigning and Maintaining the Quality Classification of Components.

7. Oyster Creek Generating Station Procedure ES-012, CRL Component ID, Data Format and Structure.

8. ES-017, Identification of Oyster Creek Plant Systems 9. EP-035, CRL Control 10. PP-13, Abnormal Operational Transients

11. PLI-02, Scoping of Systems and Structures

12. QCL 0-651-0002

13. QCL 0-651 -0009 14. GE 237E566, Sheet 1, RPS Elementary Diagram 15. QCL 0-624-0000 PP-2, Rev 2 Sheet 11 of 26 16. Draft NUREG 1800, January 2005 17. Draft NUREG 1801, January 2005 I PP-2, Rev 2 Sheet 12 of 26 I 5.0 Attachments Table 1 SYSTEM SYSTEM NAME Safety Related CODE 080 SYSTEM FOR ISI AND FAC INSPECTIONS Y (Note 1)100 STRUCTURES

& CIVIL WORK 101 EQUIPMENT SUPPORTS 102 BUILDING FOUNDATIONS 103 STRUCTURAL STEEL 104 PIPING AND PIPE SUPPORTS Y 105 STRUCTURAL WALLS 106 LADDERS, RAILS, STAIRS, & MISC 110 SITE PREPARATION 120 SITE IMPROVEMENTS/FACILITIES 121 STORM SEWERS AND YARD DRAINAGE 122 LANDSCAPING 123 ROADS AND PARKING LOTS 124 FENCING 125 RAILROAD 126 UNDERGROUND 127 CANALS STRUCTURES 131 BLDG 1 -TRAINING (FR)132 BLDG 2-TRAINING (FR)133 BLDG 3 -STORAGE (FR)134 BLDG 4 -STORAGE (FR)135 BLDG 5 -GARAGE (FR)136 BLDG 6 -WAREHOUSE (FR)137 BLDG 7 -WAREHOUSE (FR)138 BLDG 8 -TOOL STORAGE (FR)139 BLDG 9 -STORAGE (FR)140 BLDG 10 -STORAGE (FR)141 BLDG 11 -WAREHOUSE (FR)142 BLDG 12-TRAINING (FR)143 BLDG 13 -STORAGE (FR)144 BLDG 14-TRAINING (FR)145 BLDG 17 -COMBUSTIBLES (FR)146 BLDG 18 -CHEM LAB (FR)147 BLDG 20-CONCRETE TEST LAB (FR)148 BLDG 24 -COMMUNICATIONS (FR)151 TURBINE BUILDING 152 TURBINE GENERATOR PEDESTAL 153 REACTOR BUILDING Y 154 OLD RADWASTE BUILDING 155 NEW RADWASTE BUILDING_

[PP-2, Rev 2 Sheet 13 of 26 SYSTEM SYEM M NAME Safety Related CODESYTMNE 156 MAIN OFFICE BUILDING 157 DIESEL GENERATOR BUILDING Y 158 HEATING BOILER HOUSES 159 NEW FUEL STORAGE VAULT 160 AUXILIARY OFFICE BUILDING _161 SPENT FUEL STORAGE POOL Y 162 MAINTENANCE BUILDING 163 MATERIALS WAREHOUSE 164 STACK Y 165 SITE ADMINISTRATION BUILDING _166 CONSUMABLE MATL/TOOL STRG .167 PRETREATMENT BUILDING 168 INTAKE STRUCTURE

& CANAL _ Y_169 CHLORINATION FACILITY _170 DILUTION STATION 171 CONDENSATE TRANSFER BUILDING 172 EATING AND MEETING BUILDING 173 CLEAN INSTRUMENT SHOP _174 BREATHING AIR COMPRESSOR BUILDING 175 AUGMENTED OFFGAS BUILDING 176 FIRE PUMP HOUSES (ALL)177 SUBSTATION

_178 MAIN GUARD HOUSE 179 NORTH GUARD HOUSE 180 DISCHARGE STRUCTURE

& CANAL 181 WASTE STORAGE FACILITY 182 CONTAMINATED INSTRUMENT SHOP 183 FISH SAMPLE POOL BUILDING 184 SITE EMERGENCY BUILDING 185 NEW SAMPLE PUMP HOUSE 186 EXPANDED SAFETY SYS FACILITY 187 DRYWELL AND TORUS Y 188 MICROWAVE BLDG (FR)189 NEW OFFICE BUILDING SPECIAL PURPOSE ROOMS 191 CONTROL ROOM Y 192 CABLE SPREADING ROOM Y 193 NEW CABLE SPRD RM & BRIDGE TNL Y 194 SWITCHGEAR ROOM (480V) Y 195 SWITCHGEAR ROOM (4160V) Y 196 BATTERY ROOM A&B Y 197 BATTERY ROOM C Y IRX PLANT SYSTEMS I PP-2, Rev 2 Sheet 14 of 26 I SYSTEM SYSTEM NAME Safety Related CODE____ ESF & RX AUXILIARY SYSTEMS 211 EMERGENCY ISO CONDENSERS Y 212 CORE SPRAY & AUTO-DEPRESS SYSTEM Y 213 LIQUID POISON SYSTEM Y 214 SHUTDOWN COOLING SYSTEM Y 215 CLEANUP DEMINERALIZER SYSTEM Y 216 REACTOR HEAD COOLING SYSTEM Y RX COOLANT SYSTEM & COMPONENTS 221 REACTOR VESSEL Y 222 REACTOR INTERNALS Y 223 RECIRCULATION SYSTEM Y 224 RECIRCULATION PUMPS M/G SETS _225 CONTROL ROD DRIVE SYSTEM Y 226 FUEL ELEMENTS/CONTROL BLADES Y RADIOACTIVE WASTE MGMT SYSTEMS 231 AUGMENTED OFF-GAS SYSTEM 232 LIQUID RADIOACTIVE WASTE SYS 233 SOLID RADIOACTIVE WASTE SYS 234 RADWSTE VOLUME REDUCT/SOLIDIFCAT CONTAINMENT SYSTEMS 241 CONTAINMENT SPRAY SYSTEM Y 242 CONTAINMENT INERTING SYSTEM Y 243 DRYWELL & SUPRESSION SYSTEM Y 244 CONTAINMENT PENETRATIONS Y 245 DRYWELL PERSONNEL AIRLOCK Y 246 PENETRATION PRESSURIZATION SYSTEM FUEL SYSTEMS 251 SPENT FUEL POOL COOLING SYSTEM Y 252 REACTOR FUEL HANDLING EQUIPMENT 253 FUEL RACKS 254 HIGH DENSITY POISON FUEL RACKS 255 AUG SPENT FUEL POOL COOLING Y 257 CASK DROP PROTECTION SYSTEM REACTOR SERVICE SYSTEMS 261 CRD DRIVE REBUILDING FACILITY 262 MAINTENANCE

& LIFTING EQUIPMENT REACTOR PLANT INSPECTION SYSTEMS 271 CONTAINMENT LEAK RATE TESTING Note 2

.I PP-2, Rev 2 Sheet 15 of 26 I...SYSTEM SYSTEM NAME Safety Related CODE _ _ _ _ _ _ _______RADIOLOGICAL FACILITIES 281 HEALTH PHYSICS & CHANGE FACILITIES 282 SHIELDING 283 COUNT ROOM & TLD FACILITIES 284 RESPIRATOR CLEANING FACILITY TURBINE PLANT SYSTEMS 301 MAIN TURBINE 302 MAIN CONDENSER 303 MOISTURE SEPARATORS 304 REHEATERS TURBINE AUXILIARY SYSTEMS 311 TURBINE LUBE OIUPURIFICATION 312 TURBINE STEAM SEAL SYSTEM 313 TURNING GEAR & LIFT PUMP 314 MHC FRONT STANDARD 315 MAIN TURB EXHAUST HOOD SPRAY TURBINE GENERATOR SERVICE SYSTEMS CONDENSER AUXILIARY SYSTEMS 331 STEAM JET AIR EJECTORS/OFF-GAS 332 MECHANICAL VACUUM SYSTEM 333 VACUUM PRIMING SYSTEM STEAM & FEEDWATER SYSTEMS STEAM SYSTEMS 410 STEAM SYSTEMS 411 MAIN STEAM SYSTEM Y 412 REHEAT STEAM SYSTEM 413 EXTRACTION (BLEED) STEAM SYSTEM=___ FEEDWATER

& CONDENSATE SYSTEMS _421 CONDENSATE SYSTEM 422 FEEDWATER SYSTEM Y 423 CONDENSATE DEMINERALIZER SYSTEM 424 CONDENSATE TRANSFER SYSTEM Y FEEDWATER HEATER DRAINSNENTS 431 HTR DRAINS, VENT/PRESS RELIEF AUX. BOILERS & AUX. SYSTEMS 441 AUXILIARY BOILER 442 MIAIN FUEL OIL STORAGE/TRANSFER_

PP-2, Rev 2 Sheet 16 of 26 SYSTEM SYSTEM NAME Safety Related CODE _ _ _ _ _ _ _443 FUEL OIL METERING/FILL SYSTEM 444 AUX BOILER STEAM/CONDENSATE 445 HEATING & PROCESS STEAM SYSTEM WATER/WASTE TREATMENT SYSTEMS WATER TREATMENT

& DISTRIBUTION 521 PRETREATMENT SYSTEM 522 MAKEUP DEMINERALIZER SYSTEM 523 DEMINERALIZED WATER TRANSFER Y (Note 3)OPEN CYCLE COOLING WATER SYSTEM 531 ISERVICE WATER SYSTEM 532 EMERGENCY SERVICE WATER SYSTEM Y 533 SCREEN WASH SYSTEM 534 NRW SERVICE WATER SYSTEM 535 CIRCULATING WATER SYSTEM 536 DILUTION SYSTEM CLOSED CYCLE COOLING WATER SYSTEM 541 RX BLDG CLOSED COOLING WATER Y 542 TURB BLDG CLOSED COOLING WATER 543 NRW CLOSED COOLING WATER 544 AUG OFF-GAS CLSD COOLING WATER SAMPLING SYSTEMS 551 REACTOR SAMPLING SYSTEM 552 TURBINE SAMPLING SYSTEM 553 RADWASTE SAMPLING SYSTEM 554 COMPOSITE SAMPLE SYSTEMS 555 POST-ACCIDENT SAMPLING SYSTEM Y 556 H2 DETECTION/SAMPLING SYSTEMS 557 GAS SAMPLE SYSTEMS ICHEM ADD & CHEMISTRY CONTROL 561 CHLORINATION SYSTEMS 562 AUX BOILER CHEM ADD SYSTEM 563 ACID ADDITION SYSTEM 564 CAUSTIC ADDITION SYSTEM 565 TBCCW CHEMICAL ADDITION SYSTEM 566 RBCCW CHEMICAL ADDITION SYSTEM 567 RX H2 WATER CHEMISTRY 568 RX WATER ZINC INJECTION SUMPS & WASTE COLLECTION 571 TURB BLDG FLOOR & EQUIP DRAINS PP-2, Rev 2 Sheet 17 of 26 SYSTEM SYSTEM NAME Safety Related C O D E _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _572 RX BLDG FLOOR & EQUIP DRAINS 573 DRYWELL FLOOR & EQUIP DRAINS Y 574 RADWASTE FLOOR & EQUIP DRAINS 575 LAUNDRY AND LABORATORY DRAINS 576 ROOF DRAINS/OVERBRD DISCHG SYSTEM 577 MISCELLANEOUS BUILDINGS SUMPS 578 CONDENSATE TRANSFER BLDG SUMPS 579 MISCELLANEOUS OIL DRAINS SEWAGE/INDUST WSTE TREATMENT 581 SEWAGE LIFT STATION/SYSTEM CHEMICAL CLEANING SYSTEM 591 CHROMATE REMVL- NOT FUNCTIONAL 592 DECON FACILITIES-TOOL STATIONS 593 CHEM CLEANING/DECON FLUID SYSTEM INSTRUMENTATION/CONTROL SYSTEMS INSTRUMENT/CONTROL FACILITIES 611 MAIN CONTROL ROOM PANELS Y (Note 5)612 RADWASTE CONTROL ROOM PANELS 613 AOG OFF-GAS CONTROL RM PANELS 614 LOCAL CONTROUINSTRUMENT RACKS Y (Note 5)615 REMOTE SHUTDOWN PANEL Y 616 PLANT ANNUNCIATOR SYSTEMS 618 RELAY PANELS AND CABINETS Y (Note 5)POWER CYC CONTROLS/INSTRUMENTS 621 CORE MONITORING SYSTEM Y 622 REACTOR PLANT INSTRUMENTATION Y 623 TRAVELING IN-CORE PROBE SYSTEM Y 624 TURB GEN CONTROL/MONITORING Y (Note 6)625 FEEDWATER CONTROL SYSTEM Y 626 REMOTE SHUTDOWN CTRUINSTR 627 RECIRCULATION SYSTEM FLO CONTROL 628 REACTOR MANUAL CONTROL SYSTEM 629 RX OVERFILL PROTECTION (ROPS) Y POWER CYCLE PROTECTION SYSTEMS 641 REACTOR PROTECTION SYSTEM Y 642 ENG SAFEGUARDS ACTUATION Y 643 ALTERNATE ROD INSERTION (ATWS)DATA ACO/COMPUTER SYSTEM 651 PLANT COMPUTER SYSTEM Y (Note 4)

PP-2, Rev 2 Sheet 18 of 26 SYSTEM SYSTEM NAME Safety Related CODE __652 SEQUENCE OF EVENTS RECORDER 653 ROD WORTH MINIMIZER 654 CORE PARAM/FUEL MGMT COMPUTER 655 SAFETY PARAMETER DISPLAY SYSTEM 656 ENVIRONMENT TEMP MONITORING 657 EMERGENCY DIESEL GEN DATA ACQUISITIONS Y PLANT MONITORING SYSTEMS 660 PLANT MONITORING SYSTEMS 661 RADIATION MONITORING SYSTEM Y 662 METEOROLOGICAL MONITORING SYSTEM 664 POST-ACCIDENT MONITORING SYSTEM Y 665 FIRE DETECTION SYSTEMS _666 HYDROGEN & OXYGEN MONITORING Y SECURITY SYSTEMS 690 SECURITY SYSTEMS 691 SECURITY COMPUTER SYSTEM ELECTRICAL POWER SYSTEMS 701 SWITCHYARD FACILITIES PLANT ELECTRICAL GENERATION 711 MAIN GENERATOR 712 MAIN GENERATOR EXCITATION 713 GENERATOR STATOR COOLING 714 GENERATOR STATOR COOLING SYSTEM 715 HYDROGEN SEAL OIL SYSTEM 716 GENERATOR GAS CONTROL SYSTEM 717 ISOLATED PHASE BUS SYSTEM __ ELECTRICAL TRANSMISSION 721 230KV BUS, LINES/ASSOC EQUIP 722 34.5KV BUS, LINES/ASSOC EQUIP 723 MAIN & AUXILARY TRANSFORMERS 724 STARTUP TRANSFORMERS DISTRIBUTION SYSTEMS 731 416V AC DISTRIBUTION SYSTEM Y 732 480V AC DISTRIBUTION SYSTEM Y 733 120VAC VITAL POWER SYSTEM Y 734 MISC POWER/LIGHTING PANELS 735 125V STATION DC SYSTEM Y 736 24/48V INSTRUMENT POWER DC SYSTEM Y 737 480/208/120V UTILITY NON-VITAL l PP-2,Rev 2 Sheet 19 of 26 SYSTEM SYSTEM NAME Safety Related CODE EMERGENCY POWER SYSTEMS 741 DIESEL G EN/EQUI P(ELECTRICAL)

Y 742 PLNT COMP/TECH SUPP CTR UPS 743 STATION BLACKOUT & SUPPORT SYSTEMS__ ELECTRICAL PROTECTIVE SYSTEMS 751 GROUNDING SYSTEM 752 LIGHTNING PROTECTION SYSTEM 753 CATHODIC PROTECTION SYSTEM 754 ELECTRICAL HEAT TRACE SYSTEMS PLANT LIGHTING SYSTEMS 761 NORMAL LIGHTING & CONVENIENCE 762 EMERGENCY LIGHTING SYSTEM 763 SECURITY LIGHTING ELECTRICAL COMODITIES 770 CABLE, RACEWAY & CONDUIT 771 CONDUIT Y (Note 5)772 CABLE TRAYS Y (Note 5)773 UNDERGROUND DUCT BANKS 774 PRI CONTAINMENT ELECT PENETR Y (Note 5)775 CABLE ROUTING AND TERMINATION (Non Y System Engineered Item_ _PLANT COMMUNICATION SYSTEMS 781 PLANT TELEPHONE SYSTEMS 782 PUBLIC ADDRESS/PAGE SYSTEM 783 SOUND POWERED PHONE SYSTEM 784 ENS (NRC) & EMERG. TELEPHONE 785 SURVEILLANCE/INSTRUMENT PHONE 786 WORK SHIFT ANNUNCIATOR SYSTEM 787 RADIO COMMUNICATIONS SYSTEM 788 DRYWELL VIDEO MONITORING MISCELLANIOUS PLANT SYSTEMS 801 MACHINE SHOP FIRE PROTECTION SYSTEMS 811 FIRE PROTECTION WATER SYSTEM 812 FIRE PROTECTION C02 SYSTEM 813 FIRE PROTECTION HALON SYSTEM 814 FIRE BARRIERS/DIKES/PENETRATIONS 815 FIRE PROTECTION WATER SYSTEMS -FORKED I PP-2, Rev 2 Sheet 20 of 26 I SYSTEM SYSTEM NAME Safety Related CODE _ _ _ _ _ _ _RIVER 816 FIRE PROTECTION HALON SYSTEM-BUILDING 14 SIMULATOR 817 FR SITE FIRE ALARM DETECT SYSTEM 818 FR SITE FIRE DAMPER AND PENENTRATIONS 819 FR SITE MISC FIRE EQUIPMENT

__ HVAC SYSTEMS 821 TURB BLDG VENTILATION 822 RX BLDG VENTILATION Y 823 MAIN OFFICE BUILDING HVAC Y 824 AUXILIARY OFFICE BUILDING HVAC 825 MATERIALS WAREHOUSE HVAC 826 CONTROL ROOM HVAC Y 827 MAIN GUARD HOUSE HVAC 828 NORTH GUARD HOUSE HVAC 829 MAINTENANCE BUILDING HVAC 830 CLEAN INSTRUMENT SHOP HVAC 831 COMPUTER ROOM HVAC 832 EATING & MEETING BUILDING HVAC 833 MOBILE MAINT FACILITY HVAC 834 OLD RADWASTE BUILDING HVAC _835 NEW RADWASTE BUILDING HVAC 836 HEATING BOILER HOUSE HVAC 837 AUGMENTED OFF-GAS BLDG HVAC 838 DRYWELL COOLING SYSTEM Note 2 839 C BATTERY ROOM HVAC 840 CHLORINATION BUILDING HVAC 841 WASTE STORAGE FACILITY HVAC 842 CONTAMINATED I&C SHOP HVAC 843 SITE EMERGENCY BUILDING HVAC 844 MISCELLANEOUS HVAC _846 OFFICE BLDG CHILLED WATER SYSTEM 847 MACHINE SHOP & STORAGE BUILDING HVAC 848 FR SITE BLDG 14 SIMULATOR COMPRESSED AIR & GAS SYSTEMS 851 SERVICE AIR SYSTEM Note 2 852 INSTRUMENT (CONTROL)

AIR Y 853 BREATHING AIR SYSTEM 854 NITROGEN SUPPLY SYSTEM Y Note 7 855 DOMESTIC WATER COMPRESSED AIR 856 RADWASTE SERVICE AIR 857 RADWASTE CONTROL AIR 858 CHEMICAL LAB AUXILIARY GASES PP-2, Rev 2 Sheet 21 of 26 SYSTEM SYSTEM NAME Safety Related CODE DIESEL GENERATOR SYSTEMS 861 DIESEL GEN/EQUIP (MECHANICAL)

Y 862 DIESEL GEN FUEL OIL STOR/TRANSFER Y SYSTEM PLUMBING SYSTEMS 871 DOMESTIC WATER SYSTEM 872 PLUMBING & DRAINAGE SYSTEMS 873 EYEWASH STATIONS (PORTABLE)

CRANES/MATL HANDLING EQUIP_881 TURBINE BLDG 150/40-TON CRANE 882 REACTOR BLDG 100/5-TON CRANE 883 TB ROOF/HEATER BAY CRANE 884 NRW BUILDING CRANES/HOISTS 885 MAINTENANCE BUILDING CRANE 886 WASTE STORAGE FACILITY CRANE 887 INTAKE STRUCTURE CRANE 888 MISCELLANEOUS AUXILIARY CRANES ELEVATORS AND MANLIFTS 891 ELEVATOR, TURBINE BUILDING 892 ELEVATOR, REACTOR BUILDING 893 ELEVATOR, OFFICE BUILDING 894 MANLIFTS SPECIAL-NO COMPONENTS ASSIGNED 910 PROTECTIVE COATINGS 911 FIRE HAZARDS ANALYSIS 912 SIMULATORS 913 MEASURING AND TEST EQUIPMENT 915 INDEPENDENT SPENT FUEL STORAGE 920 DECOMMISSIONING MECHANICAL 921 DECOM ALT SPENT FUEL POOL CLNG 922 DECOM AIR COOLED COOLING WATER 930 DECOMMISSIONING ELECTRICAL 931 DECOMMISSIONING ELECT 4160V 932 DECOMMISSIONING ELECT 480V 933 DECOMMISSIONING ELECT 120V 999 DUMMY CHARGE NUM JO CLOSING NA Hardened Vent System NA Noble Metals Monitoring System NA Offgas Building Floor and Equipment Drains NA Torus Water Storage and Transfer NA Ultimate Heat Sink PP-2, Rev 2 Sheet 22 of 26 PP-2, Rev 2 Sheet 23 of 26 Table 1 Notes 1. This ES-1 7 system number represents plant activities and does not include systems, structures or components.

2. See position paper Section 3 (Conservative CRL Classifications) for a detailed discussion of this system.3. Demineralized Water Transfer System 523 The Demineralized Water Transfer System is conservatively classified as safety related in the CRL. The system includes the following CRL items classified as safety related: P V V-12-217 DEMINERALIZED WATER DRAIN VALVE @PENETRATION X-023 P V V-12-60DEMINERALIZED WTR DRYWELL SUPPLY ISOLATION VALVE P P 523 DEMINERALIZED WATER TRANSFER SYSTEM-PIPING F MISC 523 DEMINERALIZED WATER TRANSFER SYSTEM-12,WD The first two components are manual safety related valves associated with the primary containment penetration X-23. The safety function of these valves is imposed by the primary containment function.

These valves do not provide a safety function related to the Demineralized Water Transfer system.The CRL "component" P P 523 is a generic component representing the Demineralized Water Transfer system piping. The Demineralized Water Transfer system pumps, valves and other components are not classified as safety related.With the exception of piping associated with the above containment penetration, the Demineralized Water Transfer system piping does not have any safety related functions and does not need to be classified as safety relayed.The CRL "component" F MISC 523 is a system identifier representing the Demineralized Water Transfer system. This system identifier "component" is conservatively classified as "Q" safety related. There are no safety related functions associated with this system (reference 3, Section 9.2.3.2.3).

4. Plant Computer System 651 The Plant Computer System is conservatively classified as safety related in the CRL. The system includes the following CRL items classified as safety related: E MISC PC1 ANALOG ISOLATOR CABINET+ 'LAMBDA' POWER SUPPLY E PNL PC2 DIGITAL ISOLATOR TERMINAL CABINET (IN NCSR)

PP-2, Rev 2 Sheet 24 of 26 E MISC PC3 ANALOG ISOLATOR CABINET+ 'LAMBDA' POWER SUPPLY E PNL PC4 DIGITAL ISOLATOR TERMINAL CABINET E PNL PNL-651-1 ANALOG ISOLATION SUB-SYS SEC 2/3 OF TRW CNTRLS CAB E PNL PNL-651-2 DIGITAL ISOLATION SUB-SYS SEC 5 OF TRW CNTRLS CAB F MISC 651 PLANT MONITORING COMPUTER SYSTEM The first 4 CRL items, panels PC1, 2, 3 and 4, are classified safety related based on the safety function of the isolators inside the cabinets.

The isolators are connected to safety related inputs. They serve as isolation devices and prevent failures in the plant computer from degrading the safety function of safety related items. The isolator safety function is to protect the upstream electrical equipment.

Electrical isolators are active for license renewal (reference 2, NEI 95-10, Appendix B), and are therefore not subject to aging management review. The host system 651 has no safety function (reference 12).Similarly, panels PNL-651-1 and PNL-651-2 are conservatively classified safety related. The quality classification report (reference

13) for these panels indicates that the system does not perform a safety function, but interfaces with safety related systems. The system was conservatively classified safety related, based on the safety related isolators in panels PC1, 2, 3 and 4 described above. These isolators are the only safety related components in the system.The CRL "component" F MISC 651 is a system identifier representing the Plant Computer system. This system identifier "component" is conservatively classified as "0" safety related. There are no safety related functions associated with this system (reference 12,13).5. These items are treated under electrical commodities.

6. System 624 Turbine Gen Control/Monitoring The Turbine Gen Control/Monitoring System is conservatively classified as safety related in the CRL. The system includes the following CRL items classified as safety related: V-58-9 PSL-A ISOLATION VALVE V-58-14 PSL-D ISOLATION VALVE V-58-13 PSL-C ISOLATION VALVE V-58-1 1 PSL-B ISOLATION VALVE V-58-10 PSL-A DRAIN VALVE 624 TURBINE GENERATOR CONTROL & E/H CONTROL SYSTEM PP-2, Rev 2 Sheet 25 of 26 The valves are instrument valves associated with turbine hydraulic system low pressure switches that open on low pressure to signal a turbine trip to RPS.Failure of the valve passive pressure boundary would result in the trip so these valves do not have a pressure boundary intended function.

Although these valves are conservatively classified Q to allow flow to the RPS instruments, these valves do not have a safety related function and do not need to be included in the scope of license renewal.The CRL "component" 624 is a system identifier representing the Turbine Gen Control/Monitoring system. This system identifier "component" is conservatively classified as "Q" safety related based on the above valves. There are no other safety related functions associated with this system (reference 14, 15).7. System 854 Nitrogen Supply System -The Nitrogen Supply System license renewal system functionally includes the TIP indexer nitrogen purge line. This line includes safety related containment isolation valves, which, prior to 1998, were included in PIMS under the non-safety related Nitrogen Supply PIMS system number 854. Although functionally these valves support the Nitrogen Supply System TIP indexer nitrogen purge, they were reassigned in PIMS to the Containment Inerting PIMS system number 242 because this system was classified as safety related. This change was documented in QCL Report No. 0-242-0012.

The Nitrogen Supply System functionally supports, and works in conjunction with, the Containment Inerting System.

Criteria for Scoping Systems and Structures PP-03 Re Relied upon to Demonstrate Compliance Sheet 1 o With 10 CFR 54.4 (a)(2)Criteria for Scoping Systems and Structures Relied Upon to Demonstrate Compliance With 10CFR54.4 (a)(2)Oyster Creek License Renewal Project Criteria for Scoping Systems and Structures Relied upon to Demonstrate Compliance With 10 CFR 54.4 (a)(2)PP-03 Rev. 3 Sheet 2 of 15 Approvals Revision Prepared by: Checked by: Approved by: 00 A. M. Ouaou T. E. Quintenz D ate _ _ _ _ _ _ _ _ _ _ _ _01 A. M. Ouaou K. Muggleston D. B Warfel Date 02 A. M. Ouaou K. P. Muggleston D. B. Warfel Date 03 A. M. Ouaou K. P. Muggleston D. B. Warfel Date Criteria for Scoping Systems and Structures Relied upon to Demonstrate Compliance With 10 CFR 54.4 (a)(2)Revision Summary Rev. No. Required Changes to Achieve Revision _ I 0 Initial Issue 1 Revised to include 1 OCFR54.4(a)(2) scoping criteria for OC SSCs 2 -Incorporate LRCR #151, add criterion 6 in LRA page 2.1-21 3 Incorporate LRCR #190 Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 4 of 15 With 10 CFR 54.4 (a)(2)TABLE OF CONTENTS Approval Page .............

2 Revision Summary .............

3 Table of Contents ............

4 1.0 Purpose 5 2.0 Scope 5 3.0 Definitions 5 4.0 Methodology 6 4.1 10 CFR 54.4 (2) Requirements 6 4.2 NRC Staff Position on 1OCFR54.4(a)(2)

Scoping Criterion 6 4.3 Implementation of 1OCFR54.4(a)(2)

Requirements for OC 7 4.4 Non Safety Related Mitigative SSCs Identified in the CLB 8 4.4.1 Missile Barriers 8 4.4.2 Flood Barriers 8 4.4.3 Spray Shields 8 4.5 Non Safety-Related Piping Connected to Safety-Related Piping 8 4.6 Spatial Interaction:

Non Safety-Related Piping Not Directly Connected 9 to Safety-Related Piping 4.6.1 Systems and components Containing Air/Gas 9 4.6.2 Systems and Components containing Fluid or Steam 10 4.6.2.1 High Energy Lines (HEL) 10 4.6.2.2 Moderate/Low Energy Lines (M/LE) 11 4.7 Seismic Il/I Large and Small Bore Piping 12 4.8 Cranes and Hoists 13 5.0 References 14 Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 5 of 15 With 10 CFR 54.4 (a)(2)1. Purpose This position paper provides criteria for identifying Oyster Creek Nuclear Generating Station (OCNGS) systems, structures, and components (SSCs) required to be included in the scope of license renewal to satisfy 1 OCFR54.4(a)(2) requirements.

The paper documents technical basis for license renewal scoping conclusions, along with the methodology and Current Licensing Bases (CLB) documents used to develop the criteria.The position paper is for use by personnel engaged in the preparation, review, or approval of scoping evaluations in support of OCNGS license renewal activities.

This position paper will be used in conjunction with PLI-02, "Scoping of Systems and Structures" 2. Scope This position paper applies to all non safety-related Systems, Structures, and Components (SSCs) whose failure could prevent satisfactory accomplishment of the applicable functions of the SSCs identified under 1 OCFR54.4(a)(1).

3. Definitions Anchor -A seismic anchor or three mutually perpendicular restraints as defined in Specification SP-1 302-12-294.

Hazard -Non-safety related SSC whose failure could result in a spatial or structural interaction with safety related active or passive SSC.Safety Related System -Refer to PP-02, 54.4(a)(1)

Safety Related Systems Spatial interaction

-This term refers to the effect(s) of non-safety related system, structure or component (SSC) failure on safety related component, such as Pipe Whip, Jet Impingement, General flooding, Spray, and displacement/Falling Structural interaction

-Occurs in situations where a non-safety related piping system physically connects to a safety related system and the non safety related system is relied upon to provide physical support to the safety related system up to and including an anchor, as defined in the current CLB.Target -Active and passive components that perform an intended function described in 10CFR54.4 (a)(1).

Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 6 of 15 With 10 CFR 54.4 (a)(2)4. Methodology 4.1 1 OCFR54.4 (a) Requirements Section 54.4(a)(2) of License Renewal Rule, requires that all non-safety related systems, structures, and components (SSCs) whose failure could prevent satisfactory accomplishment of the applicable functions of SSCs identified under 1 OCFR54.4 (a)(1) be included in the scope of license renewal. The Statements of Consideration (SOC) of the Rule provides additional guidance related to this scoping Criterion.

Specifically SOC states that " To limit this possibility for the scoping category relating to non safety-related systems, structures, and components...

An applicant for license renewal should rely on the plant's Current Licensing Basis (CLB), actual plant-specific experience, industry-wide experience, as appropriate, and existing engineering evaluations to determine those non safety-related systems, structures, and components that are the initial focus of the license renewal review.Consideration of hypothetical failures that could result from system interdependencies that are not part of the CLB and that have not been previously experienced is not required" (Ref. 5.5)4.2 NRC Staff Position on 1OCFR54.4(a)(2)

Scoping Criterion The NRC Staff issued Interim Staff Guidance, ISG-09, to document its position on scoping requirements for 1 OCFR54.4(a)(2).

The guidance requires that a distinction be made, when demonstrating that failures of non safety-related SSCs would not adversely impact on the ability to maintain intended functions, between non safety-related SSCs that are connected to safety-related system and, non safety related SSCs that are not connected to safety-related systems. For a non safety-related SSC that is connected to a safety-related SSC, the non safety-related SSC should be included in within the scope of license renewal up to the first seismic anchor past the safety/non-safety interface.

For non safety-related SSCs which are not connected to safety-related piping or components or are beyond the first seismic anchor past the safety/non-safety interface, but have a spatial relationship such that their failure could adversely impact on the performance of a safety-related SSC's intended function, the applicant has two options when performing its scoping evaluation; a mitigative option or a preventive option. When mitigative features (e.g., pipe whip restraints, jet impingement shields, spray and drip shields, seismic supports, flood barriers) are provided to protect safety-related SSCs from failures of non safety-related SSCs, this demonstration should show that mitigating devices are adequate to protect safety-related SSCs from failures of non safety-related SSCs regardless of failure location (consideration can be give to the likelihood of failure at a particular location based on sound engineering judgment).

If this level of protection can be demonstrated, then only the mitigative features need to be included within the scope of the scope of license renewal. However, if an applicant cannot demonstrate that the mitigative features are adequate to protect safety-related SSCs from the consequences of Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 7 of 15 With 10 CFR 54.4 (a)(2)failures of non safety-related SSCs, then the applicant should utilize the preventive option, which requires that the entire non safety-related SSC be brought into the scope of license renewal.4.3 Implementation of 1 OCFR54.4(a)(2)

Requirements for OCNGS License Renewal The identification of SSCs that satisfy 10CFR54.4(a)(2) criterion is based on the review of applicable CLB documents, plant specific and industry operating experience.

The preventive option described in ISG-09 is primarily utilized to demonstrate that safety related SSCs are adequately protected from failure of non safety-related SSCs. A limited number of non safety-related mitigative features, such as missile barriers, flood barriers, and spray shields, are credited in the CLB (Ref. 5.1, 5.2), for the protection of safety related SSCs. These mitigative features are also included in the scope of license rule per 1 OCFR54.4 (a)(2) and evaluated as structural components.

The spaces approach is utilized for scoping of non safety-related SSCs to satisfy 10CFR54.4(a)(2) and ISG-09 criteria.

The approach consists of identifying structures that house safety related SSCs based on the CLB safety classification of the structure (e.g. Seismic Class I), by reviewing the CRL component location field, and by reviewing design drawings.

As a result the following license renewal structures are identified as containing safety related SSCs.* Primary Containment

• Reactor Building* Emergency Diesel Generator Building* Exhaust Tunnel* Heating Boiler House (old boiler house)* Office Building (rooms that house safety related SSCs only)'* Turbine Building A general walkdown of other plant structures, by experienced design engineering and license renewal personnel, was performed to confirm that only these structures house safety related SSCs.For each structure listed above, a conservative approach is taken by including the entire structure, structural components, and component supports in the scope of license renewal. Structures and structural components classified safety related in the CLB are included in the scope of 10 CFR 54.4(a)(1), and non-safety related structures, structural components, and component supports are in scope for 10 CFR 54.4(a)(2).

Scoping of mitigative features described in NRC Staff ISG-09, non-safety related piping connected to safety related piping, spatial interaction (spray), seismic Il/I, and Cranes and hoists housed inside the structures is discussed in detail below.' Battery Room, 480V Switchgear room, and Recirculation MG-Set Room Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 8 of 15 With 10 CFR 54.4 (a)(2)4.4 Non Safety-Related Mitigative SSCs Identified in The CLB 4.4.1 Missiles Barriers.

SSCs that provide missile barrier protection are mostly classified safety related structures in the CLB and are in scope of license renewal per 1 OCFR54.4(a)(1).

However some non safety-related walls of the turbine building are credited for missile protection of the control room, and the 4160 switchgear room (Ref. 5.1, Section 3.5.1.3 and Table 3.5-1) and calculation No. 72-01-01 (Ref. 5.25).These walls are in scope of license renewal per 1 OCFR54.4 (a)(2).4.4.2 Flood Barriers.

Non safety-related flood protection features, such as walls, dikes, curbs, and seals, are included in the scope of license renewal per 1 OCFR54.4(a)(2).

These features are evaluated as a commodity with structures in which they're located.CLB References.

UFSAR (Ref. 5.1, Section 2.4, 3.4) and NUREG-1382 (Ref. 5.20, Section 3.4) require that safety related SSCs be protected against external design basis flood (probable maximum precipitation).

Flood level is established to be elevation 23.5 feet. Internal flooding is discussed throughout the UFSAR (e.g., HELB, actuation of fire protection system, etc.), in NUREG-1382 (Ref. 5.20, Section 3.4), and in Fire Hazard Analysis Report (Ref. 5.2, Appendix A, E.3). Non safety-related design features (walls, slabs, curbs, drains, and seals) are credited for protecting safety-related SSCs from external and internal flooding.

The features are included in the scope of 10CFR54.4(a)(2).

4.4.3 Spray Shields. Spray shields are included in the scope of license renewal per 1 OCFR54.4(a)(2).

Spray shields are included as a commodity with structures in which they're located.CLB References.

Spray shields are provided in the CLB (ref. 5.2, Appendix A, E.3)to protect safety-related components from inadvertent operation or failure of fire protection water system.4.5 Structural Interaction:

Non Safety-Related Piping Connected to Safety-Related Piping The design basis for OCNGS piping systems is based on ANSI B31.1, 1955 Edition, with supplements, addenda and applicable code cases as of 1966. Consistent with this Code requirements, the original design specifications required a dynamic analysis for Class 1 pipe 10 inches IPS and larger, and a static analysis using seismic design coefficients for the smaller pipe. Above ground large pipe systems, within the scope of NRC IE Bulletin 79-14, were evaluated based on ANSI B31.1 1983 Edition through winter 1984 Addenda. Stress analysis was conducted using full three-dimensional models, with modal combinations and directional combination in accordance with Regulatory Guide 1.92. For these systems, pipe stress analysis is based on criteria documented in engineering specifications (Ref. 5.7, 5.22).Specification (Ref. 5.7) requires that mechanical boundaries, as well as, structural Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 9 of 15 With 10 CFR 54.4 (a)(2)boundaries be established.

The mechanical boundaries typically occur at a valve or another mechanical component.

The structural boundaries extend beyond the mechanical boundaries to incorporate an anchor or three mutually perpendicular restraints.

For other large and small piping systems, there are no specific requirements in the CLB for anchors or three mutually perpendicular restraints.

Therefore scoping methodology for non-safety related piping connected to safety related piping is based on the criteria below. However the application of the criteria is limited because most non-safety related piping systems connected to safety related piping systems are in scope of 1 OCFR54.4(a)(2) for spatial interaction (e.g.leakage/spray).

4.5.1 If a non-safety related piping system is connected to a safety related piping system, the non-safety related system is conservatively assumed to provide structural support to the safety related system. This applies to water, steam, oil, and air/gas piping systems. Instead of attempting to locate seismic anchors or three mutually perpendicular restraint, the entire non-safety related system is included in the scope of 1 OCFR54.4(a)(1) or 1 OCFR54.4(a)(2), or the system boundary is extended to one of the following:

4.5.1.1 Major plant equipment, such as pumps, heat exchangers, or turbines.

The equipment is included in scope of 1 OCFR54.4(a)(2) 4.5.1.2 Anchored to a wall or slab. The wall or slab are included in scope of 1 OCFR54.4(a)(1) or (a)(2).4.5.1.3 The non-safety related line exits a structure and then routed underground 4.5.1.4 Up to a flexible hose or flexible joint that is not capable of load transfer.4.5.1.5 Locate a seismic anchor or a three mutually perpendicular restraint using design drawings or by a walkdown 4.5.1.6 The end of the piping run (e.g., vent and drain lines)4.6 Spatial Interaction:

Non Safety-Related Piping Not Directly Connected to Safety-Related Piping 4.6.1 Systems and Components containing Air/Gas. Air and gas systems (non-liquid) have been determined not to have spatial interactions with safety-related SSCs (Ref.5.4). Thus the systems (except those portions required for structural support) are not included in the scope license renewal for 1 OCFR54.4(a)(2).

Thus the systems have no leakage boundary function; but have a structural support function.

Supports for air and gas systems in areas with the potential for seismic interaction (seismic 11/l), are included in the scope of 10CFR54.4(a)(2).

Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 10 of 15 With 10 CFR 54.4 (a)(2)Basis: Operating experience reviews, industry and plant specific, of non-liquid containing systems did not identify failures, which are aged related (Ref. 5.4, Appendix F, Para. 5.2.2.1).4.6.2 Systems and components containing water, oil, or steam. Non safety-related piping and components, containing water, oil, or steam, which are not connected to safety-related SSCs may have a spatial interaction such that their failure could adversely impact the performance of safety-related SSCs. For high energy lines (HEL), the interaction is a result of pipe whip, jet impingement, spray or leakage, and flooding.For medium/low energy lines (MILE), the interaction is a result of spray or leakage, and flooding.

Pipe whip, jet impingement, spray and leakage are addressed below.4.6.2.1 High Energy Lines (HEL). All OCNGS high-energy lines inside or outside primary containment are included in the scope of 10CFR54.4(a)(1) or (a)(2), depending on their safety classification.

That is, HEL classified safety related are in scope for 1 OCFR54.4 (a)(1), and non-safety related HEL are in scope for 1 OCFR54.4 (a)(2).Piping systems, which are considered high energy lines in the UFSAR (Ref. 5.1, Sections 3.6, 3.11) and design calculations (Ref. 5.12, 5.24) are,* Recirculation piping* Main steam* Feedwater* Isolation Condenser* Core spray* Reactor Water Cleanup CLB

Reference:

The review of UFSAR (Ref. 5.1, Sections 3.6, 3.8, 3.1 1), SEP documents (Ref. 5.18, 5.19), NUREG-1382 (Ref. 5.20), calculations (Ref. 5.12, 5.24), and pipe whip study report (Ref. 5.14) concluded that OCNGS original design did not rely solely on mitigative features, such as pipe whip restrains or Jet impingement barriers, to mitigate the effects of high energy line break (HELB).Instead, the primary containment vessel, and safety related SSCs inside or outside primary containment were evaluated for the effects of HELB without pipe whip restraints and jet impingement barriers.

The evaluation relied on system separation, redundancy, and preventive measures (Inservice Inspections) to show that systems required for safe shut down will not be affected by HELB. The piping systems were selected for evaluation for the following reasons (ref. 5.14),* They are subjected to reactor pressure (1050 psia);* A break could result in blowdown of the entire primary coolant system; and* They include all of the larger diameter pipes inside the containment and consequently would contain the greatest available energy to penetrate the containment in the event of a pipe rupture.The 275-psia pressure and the 200 0 F temperature, typically used for HELB classification are not referenced in OCNGS CLB. However systems that operate at a pressure of 275-psia and 200 0 F are considered HELB and included in the scope license renewal.

Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 11 of 15 With 10 CFR 54.4 (a)(2)It is conservatively assumed that any mitigative features provided in the CLB are not adequate to protect safety related SSCs from a postulated HELB. Thus, the preventive option is selected to ensure this protection consistent with ISG-09.4.6.2.2 Moderate/Low Energy (MILE). Moderate or low energy piping systems are defined as systems not meeting OCNGS HELB criterion.

Exelon then elected to conservatively include in the scope of 10CFR54.4(a)(2) all non safety-related M/LE piping systems and components that contain a water, oil, or steam located inside the following license renewal structures.

• Primary Containment

• Reactor Building* Emergency Diesel Generator Building* Exhaust Tunnel* Heating Boiler House (old boiler house)* Office Building (rooms that house safety related SSCs only)2* Turbine Building Each structure is discussed below to identify M/LE systems that are excluded from the scope of 1 OCFR54.4(a)(2) and provide basis for their exclusion.

In addition the basis for excluding non safety-related M/LE systems located at the Intake Structure and Canal and in the yard area is discussed below.4.6.2.2.1 Primary Containment

-Non safety-related M/LE systems inside the primary containment are conservatively assumed to have a leakage boundary function and included in scope of 1 OCFR54.4 (a)(2)4.6.2.2.2 Reactor building -Non safety-related M/LE systems inside the reactor building are conservatively assumed to have a leakage boundary function and included in the scope of 1 OCFR54.4(a)(2) excluding the drywell chilled water piping (Drywell Cooling system) and the torus water storage and transfer system. The drywell chilled water piping is only used during refueling outages and the torus water storage and transfer system is used on rare occasions to drain or transfer water from the torus to the torus water storage tank. Both systems are empty during normal plant operation and consequently have no potential long-term spatial interaction due to spray or leakage with safety related SSCs.4.6.2.2.3 Emergency Diesel generator Building -Non safety-related M/LE systems inside the building are conservatively assumed to have a leakage boundary function and included in scope of 1 OCFR54.4 (a)(2)4.6.2.2.4 Exhaust Tunnel -Non safety-related M/LE systems inside the Exhaust Tunnel are conservatively assumed to have a leakage boundary function and included in scope of 10CFR54.4 (a)(2)2 Battery Room, 480V Switchgear room, and Recirculation MG-Set Room Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 12 of 15 With 10 CFR 54.4 (a)(2)4.6.2.2.5 Heating Boiler House (Old boiler house) -Non safety-related M/LE systems inside the old boiler house are conservatively assumed to have a leakage boundary function and included in scope of 1 OCFR54.4 (a)(2)4.6.2.2.6 Office Building -Non safety-related M/LE systems inside the battery room, 480V Switchgear room, and recirculation MG-Set room are in scope of 1OCFR54.4 (a)(2). Other rooms in the building do not contain safety related components.

4.6.2.2.7 Turbine Building -All non safety-related M/LE systems inside the turbine building are conservatively assumed to have a leakage boundary function and in scope of 1 OCFR54.4(a)(2).

4.6.2.2.8 Miscellaneous Yard Structure (yard area) -Non safety-related MUE systems in yard areas are buried underground or have no spatial interaction with safety related SSCs. In addition safety related components in the yard area are designed to operate in a wet environment (rain) and will not be impacted by spray.4.6.2.2.9 Intake Structure and Canal -Non safety-related MUE systems located at the intake structure have been determined not to have a leakage boundary function, thus not included in the scope of 1 OCFR54.4(a)(2).

The intake structure is an open structure subject to outside weather conditions.

Thus the safety related systems located at the intake structure are designed to operate in a wet environment (rain) and will not be impacted by spray from adjacent non safety-related piping systems.4.7 Seismic Il/I Large and Small Bore Piping. Non safety-related piping systems designed to Seismic Class II requirements could hypothetically fail and fall on or otherwise physically impact safety related SSCs, during a design basis seismic event. However, based on the rationale provided below, the piping is not required to be included in the scope of 1OCFR54.4 (a)(2). However its supports need to be intact in order to prevent physical impacts on safety related SSCs during a seismic event and as result must be included within the scope of 1 OCFR54.4(a)(2) (Ref. 5.4, Appendix F, Para. 5.2.2.3).Supports for non safety-related SSCs located inside areas that contain safety related SSCs are conservatively included in the scope of license renewal for 1 OCFR54.4(a)(2).

Basis. Seismic Il/I piping is not required to be included in the scope of the Rule based on the following rationale (Ref. 5.4, Appendix F, Para. 5.2.2.3).* No experience data exists of welded steel pipe segments falling due strong earthquake motion Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 13 of 15 With 10 CFR 54.4 (a)(2)* Falling of piping segment is extremely rare and only occurs when there is a failure or unzipping of the supports* These observations hold true for new and aged pipe Therefore, as long as the supports for piping systems are intact, falling or physical impact of piping sections is not credible.4.8 Cranes and Hoists. Safety and non safety-related Cranes, monorails, and hoist in scope of NUREG-0612 are in scope of the Rule. Other Non safety-related cranes, monorails, and hoists located in areas containing safety related SSCs are included in the scope of 1 OCFR54.4(a)(2) if it is determined that their failure could impact an intended function.Basis. NRC issued NUREG-0612 to provide guidelines for preventing heavy load drops that might affect safety-related equipment or cause fuel damage that would result in significant off site release. Compliance with the NUREG is described in UFSAR Section 9.1.4.2.3.

Cranes, monorails, and hoist, which satisfy heavy load requirements of NUREG-0612, are within the scope of license renewal. Other monorails and hoists, located in areas containing safety-related SSCs, but do not meet NUREG-0612 heavy load criteria, are also included in scope of Rule since their failure could adversely impact a safety related intended function.

Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 14 of 15 With 10 CFR 54.4 (a)(2)5.0 References 5.1 Oyster Creek Nuclear Generating Station, Updated Final Analysis Report, Rev. 13 5.2 Oyster Creek Nuclear Generating Station, Fire Hazards Analysis Report, Document No. 990-1746 Revision 12, Appendix A (item E.3)5.3 10 Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants 5.4 Nuclear Energy Institute (NEI), NEI 95-10, Industry Guidelines on implementing the Requirements of 10CFR Part 54, Revision 5 5.5 NRC Staff Interim Guidance (ISG-09), dated March 15, 2002 "License Renewal Issue: Guidance on the Identification and Treatment of Structures, Systems, and Components which Meet 1 OCFR54.4(a)(2)", Christopher I. Grimes to Alan Nelson 5.6 Engineering Standard ES-001, Oyster Creek Engineering Classification, Rev. 10 5.7 Specification SP-1302-12-294, Oyster Creek Nuclear Generating Station, Technical Specification for Oyster Creek Generating Station Pipe Stress Analysis, Rev. 1 5.8 Oyster Creek Nuclear Generating Station, Line List Specification, SYS-LL-OC-1 5.9 ASA B31.1, Code for Pressure Piping, 1955 Edition with Supplements, Addenda and Code Cases through September 1966.5.10 Letter from D.A. Ross (JCP&L) to Boyce H. Grier (U.S NRC), Oyster Creek Nuclear Generation Station Docket No. 50-219, IE Bulletin 79-14 & 79-14, Rev. 1), dated August 31, 1979.5.11 Letter from Patrick R. Simpson (Exelon) to Document Control Desk (U.S. NRC), Additional Information the Review of the License Renewal Applications for Quad Cities Nuclear Power Station, Units 1 and 2 and Dresden Nuclear Power Station, Units 2 and 3, dated October 3, 2003.5.12 Calculation No. C-1302-104-E310-077, HELB Location Inside Containment based on NRC Generic Letter 87-11 Criteria.5.13 MPR Associates Calculation 083-252-2, "Development of Small Bore Piping Deadweight and Seismic Walkdown Screening Criteria", Revision 0.5.14 MPR Associates Report No. MPR-285, "Oyster Creek Pipe Whip Study", dated May 7, 1971, revised July 28, 1971.5.15 Technical Data Report, TDR No. 1236, "Oyster Creek Small Bore Piping Inspection Program", Revision 0.5.16 Technical Data Report, TDR No. 3004, "Oyster Creek Small Bore Piping Inspection Project -Phase Two", Revision 0 5.17 NUREG-0822, "Integrated Plant Safety Assessment Systematic Evaluation Program", Oyster Creek Nuclear Generating Station, Docket No. 50-219, January 1983.5.18 NUREG-0822 Supplement 1, "Integrated Plant Safety Assessment, Systematic Evaluation Program", Oyster Creek Nuclear Generating Station, Docket No. 50-219.July 1988.5.19 NUREG-1 382, "Safety Evaluation Report Related to the Full Term Operating License for Oyster Creek Nuclear Generating Station", Docket No. 50-219, January 1991.5.20 5.21 SE No. SE-945100-091, "Engineering Safety/Environmental Determination and 50.59 Review" Rev. 1.

Criteria for Scoping Systems and Structures PP-03 Rev. 3 Relied upon to Demonstrate Compliance Sheet 15 of 15 With 10 CFR 54.4 (a)(2)5.21 SP-1302-12-208, Rev. 0, "1985 IE Bulletin 79-02/14 Inspection Program Design Input for Piping Stress Analysis", October 1985.5.22 Burns & Roe specification No. S-2299-60, "Piping, Reactor Building -Phase I & II -Main Mechanical Equipment Installation and Miscellaneous Equipment", dated 8/66.5.23 Calculation No. C-1302-822-5450-052, "RB Response to HELB without Blowout Panels", Rev. 2 5.24 PLI-02, "Scoping of System and Structures", Rev. 2 5.25 Oyster Creek Component Record List (CRL)

Position Paper 4, Rev 2 Sheet 1 of 191-O Systems and Structures Relied upon to Demonstrate Compliance With 10 CFR 50.63 -Station Blackout Oyster Creek Nuclear Generating Station Position Paper 4, Rev 2 Sheet 2 of 19 APPROVAL PAGE Prepared by: Checked by: Approved by: Date: Date: Date:

Position Paper 4, Rev 2 Sheet 3 of 19 REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)1 Added Instrument Air bottles for operation of Isolation Condenser makeup valves.2 Delete non-system ES-17 numbers, add recirculation system for pressure boundary, Remote Shutdown for indication, Radio Communications for plant operators, and 480V Switchgear Room Ventilation, 41 60V Switchgear Room Ventilation and Battery & MG Set Room Ventilation systems, incorporated site review comments, other editorial changes.3 4 5 Position Paper 4, Rev 2 Sheet 4 of 19 TABLE OF CONTENTS Page Approval Page ......................................................

2 Revision Summary ......................................................

3 TABLE OF CONTENTS ......................................................

4 1.0 Purpose ......................................................

5 2.0 Scope ......................................................

5 3.0 Station Blackout Requirements

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5 4.0 Methodology

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7 4.2 Systems Credited for Safe Shutdown in Response to an SBO Event .................................

8 4.3 Systems Credited for Restoration of Offsite or Onsite Power .............................................

8 4.4 Structures Credited in Mitigating an SBO Event ......................................................

9 4.5 Conservative Results Evaluation

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9 5.0 References

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12 Table I -Systems and Structures Credited to Cope with an SBO Event .................................

14 Table II -Systems Credited for Safe Shutdown during Station Blackout .................................

15 Table IIl -Systems Required To Recover from a Station Blackout Event ...............................

17 Table IV -Structures Required for Station Blackout Event .....................................................

18

---Position Paper 4, Rev 2 Sheet 5 of 19 1.0 PURPOSE The License Renewal Rule, 1 OCFR 54 (Reference 1), requires identification of those systems, structures and components relied on in the safety analysis or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for station blackout (1 OCFR 50.63) be included in the scope of licensing renewal. This position paper identifies the Oyster Creek Nuclear Generating Station (OCNGS) systems and structures relied on to demonstrate compliance with 10 CFR 50.63.This position paper is for the use of personnel engaged in the preparation, review, or approval of scoping evaluations in support of license renewal activities for Oyster Creek.This paper documents the technical basis for the license renewal scoping conclusions, along with the methodology and CLB source documents used. It identifies which of the"License Renewal Systems & Structures" identified in PP-01 is required to support 1 OCFR50.63 Station Blackout functions as described in the CLB. Results will be used to populate the corresponding license renewal database field. Systems and structures listed will answer "Yes" to scoping criteria 54.4(a)(3) for 1 OCFR50.63.

This position paper also provides a source of CLB references that can be reviewed to confirm or establish the license renewal system boundaries associated with this regulated event.2.0 SCOPE The Scope of this Position Paper is those systems and structures specifically required for responding to and recovering from a station blackout in accordance with the requirements of 1 OCFR50.63.

The scope of this review is limited to the identification of systems and structures.

The scoping function is performed at the system and structure level. Identification of individual components is not within the scope of this position paper.3.0 STATION BLACKOUT REQUIREMENTS I OCFR50, Section 50.63, requires that each light-water-cooled nuclear power plant be able to withstand and recover from a Station Blackout (SBO) of a specified duration.

The Regulation identifies factors that must be considered in specifying the station blackout duration.

Section 50.63 also requires that, for the station blackout duration the plant must be capable of maintaining core cooling and appropriate containment integrity.

Utilities are expected to have the baseline assumptions, analyses and related information used in the coping evaluation available for NRC review.Section 50.63 requires that each licensee submit the following information: (i) Proposed station blackout duration, including a justification for the selection based on the redundancy and reliability for the onsite emergency AC power sources, the expected frequency of loss of offsite power, and the probable time needed to restore offsite power;(ii) A description of the procedures that will be implemented for SBO events for the duration and for recovery there from; Position Paper 4, Rev 2 Sheet 6 of 19 (iii) A list and proposed schedule for any needed modifications to equipment and associated procedures necessary for the specified SBO duration.NRC Regulatory Guide 1.155, "Station Blackout", describes a means acceptable to the NRC staff for meeting the requirements of 10 CFR 50.63. Regulatory Guide 1.155 states that NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors", provides guidance that is in large part identical to the RG 1.155 guidance and is acceptable for meeting 10 CFR 50.63, and notes where the regulatory guide takes precedence.

Oyster Creek was evaluated against the requirements of the SBO Rule using guidance from NUMARC 87-00. NUMARC 87-00 Section 3 was used to determine an SBO coping duration of four hours. The coping duration of four hours is the time to restore offsite power or onsite emergency power.In order to comply with the SBO Rule, Oyster Creek has added an Alternate AC (AAC)Power Supply System to the existing plant configuration.

This AAC power capability will be provided by either one of the two non-class IE combustion turbines that are located at the Forked River site adjacent to the Oyster Creek site. This AAC source supplies power to Oyster Creek via a connection to the non-IE 41 60V "1 B" switchgear.

This AAC power source will be available within one hour of the onset of the SBO and will have sufficient capacity and capability to operate systems required for coping with the SBO for the remaining three hours.The Oyster Creek Current Licensing Basis (CLB) for a Station Blackout event is documented in the Updated. Final Safety Analysis Report (Reference 2), Technical Data Report TDR No. 1099 (Reference

3) and the applicable references to these documents.

The AAC approach uses equipment that is capable of being electrically isolated from offsite and emergency onsite power sources. Coping with the SBO using the AAC approach entails a short period of time without AC power (up to one hour for Oyster Creek), while operators initiate actions to power SBO safe shutdown loads from the AAC source. Once the AAC source is available the plant transitions to the AAC state and provides the ability to maintain safe shutdown until offsite or emergency onsite AC power becomes available.

Compliance with the SBO Rule requires that the plant operators take the actions listed below.* Response to an SBO Event* Safe Shutdown of the Plant under SBO Conditions

• Recovery from an SBO event by restoration of offsite power or emergency onsite power The systems required to respond to, cope with and recover from an SBO event are delineated in Tables 1,11, III of this position paper. Table IV lists those structures required for compliance with the SBO Rule.

Position Paper 4, Rev 2 Sheet 7 of 19 4.0 METHODOLOGY The methodology used in identifying those systems and structures required to respond to, cope with, safely shutdown and recover from a station blackout event at Oyster Creek is documented in TDR 1099. The basis for selection of components, SBO equipment determination, a description of the AAC configuration, a list of affected plant procedures and tables of components required to respond to the SBO event are also documented in TDR 1099.If CLB reference sources in the tables identified components only, the system number was documented by identifying the system to which the component belonged and listing the system in the table with the component.

Those systems, structures and components (SSCs) required to demonstrate compliance with the Commission's regulations for Station Blackout (1 OCFR 50.63) are located in various systems and structures both in the plant and offsite at the Forked River site. The identification of those systems and structures required to demonstrate compliance with 1 OCFR 50.63 are categorized as follows: 1. Systems and structures required to respond to and cope with an SBO event.These systems are required for the first hour of the station blackout event.2. Systems and structures required to bring the plant to a safe shutdown condition and maintain the plant in that condition (long term cooling).

For Oyster Creek safe shutdown is defined as hot shutdown conditions (Ref.3).3. Systems and structures required to recover from an SBO event. These systems are required to restore either offsite power or emergency onsite power for an SBO event.Station Blackout systems, structures and components are a mix of safety and non-safety related systems, structures and components.

Station Blackout systems, structures and components are not required to be safety related to perform the function of mitigating a Station Blackout event.There has been no attempt to limit or reduce the license renewal boundary of those systems or structures that use only a part of the system (e.g.; components) or portion the structure (e.g.; rooms or areas) to support the SBO function, provide the SBO mitigating function, bring the plant to safe shutdown conditions, or restore offsite or onsite power during an SBO event. The references for the components, partial systems or structures reference(s) used to cope with an SBO event are listed in the Reference column of each Table I through IV.4.1 SYSTEMS CREDITED FOR RESPONDING TO AN SBO EVENT Identification of systems and structures credited for response to and coping with an SBO event are obtained from a review of the Current Licensing Bases (CLB) documents that describe the SBO event, and response equipment required to mitigate the event for the coping period. Identification of these systems and structures required to respond to an SBO event were obtained by reviewing the UFSAR, Technical Data Report TDR 1099, Position Paper 4, Rev 2 Sheet 8 of 19 Component Record List, and drawings (flow sheets and electrical diagrams).

The results of these document reviews were verified by comparing them with the OCNGS SBO Compliance Package to the NRC (References 5, 6) and the NRC Safety Evaluation Report (Reference 7). The results of the review for SBO response and coping systems is documented in Table I. The specific CLB reference identifying the system as required for SBO is listed in the "Reference" column of Table I. Other information is also listed that gives reference to the system description or function.4.2 Systems Credited for Safe Shutdown in Response to an SBO Event Those systems and structures required for safe shutdown of the plant were obtained from a review of the UFSAR, TDR 1099 safe shutdown load Table 5 (equipment required to safely shut the plant down based on SBO conditions) and drawings (flow diagrams and electrical diagrams).

The results of these document reviews were verified by comparing them with the OCNGS SBO Compliance Package to the NRC (References 5, 6) and the NRC Safety Evaluation Report (Reference 7). If differences were discovered in the documentation, the OCNGS SBO Compliance Package to the NRC (References 5, 6) and the NRC Safety Evaluation Report (Reference

7) governed.

The results of the review for SBO safe shutdown systems are documented in Table II. The specific CLB references identifying the system is listed in the CLB Ref. column of Table II. Other information is also listed that gives reference to the system description or function.4.3 Systems Credited for Restoration of Offsite or Onsite Power The Station Blackout event is defined as the loss of offsite and onsite ac electric power to the essential and non-essential switchgear buses in a nuclear power plant. It does not include the loss of ac power fed from inverters by station batteries nor loss of ac power from an SBO defined alternate ac power source. The NRC staff's position specifically stated in Interim Staff Guidance ISG-2 (Ref. 4) is that qualifying the alternate ac power source as a means for recovery from an SBO event is not intended within the context of the SBO rule. Further, ISG-2 states that within the context of the rule, only offsite power and onsite power are credited as a means of recovering from an SBO event; and both must therefore be included within the scope of license renewal.ISG-2 also states that the use of an offsite system as a means of recovering from an SBO is not construed by the NRC staff to be the only means of recovery from an SBO event. It is not possible to determine prior to an actual SBO event which source of power can be returned first. As a result, 10 CFR 50.63(c)(1)(ii) and its associated guidance in RG 1.155, Section 1.3 and Section 2, requires procedures to recover from an SBO that include restoration of offsite and onsite power.OCGS has procedures to cope with, withstand and recover from a Station Blackout event.Procedure ABN-37, titled Station Blackout was written and put into place to cope with, withstand and recover from an SBO event. An attachment ABN-37-1 0 of procedure ABN-37specifies the actions required to restore offsite power to the 41 60V buses. Coordination of the switchover from AAC power to offsite or onsite power is also delineated in this Position Paper 4, Rev 2 Sheet 9 of 19 procedure.

The restoration of offsite and onsite power and the specific power paths are covered in operating procedures 337 and 338.Based on the above information, OCNGS meets the requirements of the SBO rule for restoration of offsite and onsite power and will include the NRC staff guidance as specified in ISG-2 for SBO by including the offsite power and onsite power systems into the scope of license renewal for the Oyster Creek Nuclear Generating Station. This Position Paper demonstrates compliance with both the rule and ISG-2 by including the offsite and onsite power systems in Table IlIl of this Position Paper.Those systems and structures credited for recovering from an SBO event by restoring Offsite or Emergency onsite power (recovery) were obtained from a review of the UFSAR Section 8.2 (Offsite Power Description Section), UFSAR Section 8.3 (Onsite Power Systems), TDR 1099, and electrical diagrams.

The results of the review for SBO power restoration systems is documented in Table l1l. The specific CLB references identifying the system is listed in the "Reference" column of Table l1l. Other information is also listed that gives reference to the system description or function.4.4 Structures Credited in Mitigating an SBO Event Table IV is a list of structures relied upon to demonstrate compliance with 10 CFR 50.63.These structures are considered in the scope of SBO because the structures contain safety related SBO equipment or supporting systems requiring protection from normal or severe weather conditions (e.g.; hurricanes).

The source documents used to identify these structures are TDR 1099, UFSAR, Modification Design Descriptions and Engineering Standard ES-17.Structures required to demonstrate compliance with 1 OCFR 50.63 are listed in Table IV.Those structures identified in Table IV satisfy the following criteria: 1. Structures housing or protecting SBO mitigating systems from severe weather (ie: hurricanes).

2. Structures housing or protecting SBO mitigating systems from normal weather conditions.

4.5 Conservative Results Evaluation The CLB documents associated with Station Blackout at Oyster Creek include analyses, calculations and various correspondences.

In some cases, the analyses include conservative approaches or assumptions that go beyond the requirements of the Station Blackout Rule. For license renewal, only those SSCs that are relied upon to demonstrate compliance with the SBO Rule should be included in scope. The Standard Review Plan for License Renewal (reference

39) states: "The applicant is required to identify the SSCs whose functions are relied on to demonstrate compliance with the regulations identified in 10 CFR 54.4(a)(3) (that is, Position Paper 4, Rev 2 Sheet 10 of 19 whose functions were credited in the analysis or evaluation).

Mere mention of an SSC in the analysis or evaluation does not necessarily constitute support of an intended function as required by the regulation." Below are systems that are mentioned in the CLB documents for Oyster Creek SBO, but are not required to perform a function necessary to demonstrate compliance with the SBO Rule. These systems are not included in the results tables as systems required for SBO.A discussion and justification is provided for each excluded system.Containment Sprav System 241 The Containment Spray System is included in the Oyster Creek Station Blackout Evaluation TDR-1 099 (reference

3) in order to demonstrate the ability to cope with a stuck open EMRV concurrent with the SBO event. This is a conservative evaluation that goes beyond the requirements of the SBO Rule. From reference 40: "Station blackout means the complete loss of alternating current (ac) electric power to the essential and nonessential switchgear buses in a nuclear power plant (i.e., loss of offsite electric power system concurrent with turbine trip and unavailability of the onsite emergency ac power system). Station blackout does not include the loss of available ac power to buses fed by station batteries through inverters or by alternate ac sources as defined in this section, nor does it assume a concurrent single failure or design basis accident." It is not necessary to assume a stuck open EMRV during the station blackout event.There is no mention of crediting the Containment Spray system in any of the docketed NRC correspondence or the NRC Safety Evaluation Report for Oyster Creek SBO. The Containment Spray System credited to mitigate this combination of events does not need to be included in the scope of license renewal under 10 CRF 54.4(a)(3) scoping criteria for SBO.Emergency Service Water 532 The Emergency Service Water system is only required to support the Containment Spray system, which is credited only when a stuck open EMRV is assumed concurrent with an SBO event. As discussed above, this assumption is beyond the requirements of the Station Blackout Rule. There is no mention of crediting the Emergency Service Water system in any of the docketed NRC correspondence or the NRC Safety Evaluation Report for Oyster Creek SBO. The Emergency Service Water system does not need to be included in the scope of license renewal under 10 CRF 54.4(a)(3) scoping criteria for SBO.Condensate System 421 The Condensate System will be available following startup and tie-in of the AAC power source. However, the use of the Condensate System for reactor coolant inventory makeup is not described in the OC submittals (reference

5) and in supplementary submittals (reference 6). The use of the Condensate System for reactor coolant inventory makeup is not described in the NRC SERs (reference 8). The NRC SER clearly states that the use of one control rod drive pump will be sufficient for reactor inventory makeup.

Position Paper 4, Rev 2 Sheet 11 of 19 Therefore, the Condensate System does not need to be included in the scope of license renewal under 10 CRF 54.4(a)(3) scoping criteria for SBO.Feedwater System 422 The Feedwater System will be available following startup and tie-in of the AAC power source. However, the use of the Feedwater System for reactor coolant inventory makeup is not described in the OC submittals (reference

5) and in supplementary submittals (reference 6). The use of the Feedwater System for reactor coolant inventory makeup is not described in the NRC SERs (reference 8). The NRC SER clearly states that the use of one control rod drive pump will be sufficient for reactor inventory makeup. Therefore, the Condensate System does not need to be included in the scope of license renewal under 10 CRF 54.4(a)(3) scoping criteria for SBO.Non-essential Systems Powered from the AAC Reference 3 identifies a number of systems that can be powered from the AAC and utilized by plant operators when coping with and recovering from a station blackout.However, the use of these systems is not described in the OC submittals (reference

5) and in supplementary submittals (reference 6). The use of these systems is also not described in the NRC SERs (reference 8). Therefore, these systems that will be powered and available from the AAC do not need to be included in the scope of license renewal under 10 CRF 54.4(a)(3) scoping criteria for SBO: Reactor Water Cleanup 215 *Spent Fuel Pool Cooling 251 *Service Water System 531 Reactor Building Closed Cooling Water System 541 Turbine Building Closed Cooling Water System 542 Security Lighting 763 Reactor Building Ventilation System 822 Old Radwaste Building HVAC 834 Drywell Cooling 838 *Turbine Building C-Battery Room Ventilation 839 Instrument (Control)

Air System 852 (except bottled supply to Isolation Condenser makeup valves V-1 1-34 and V-1 1-36)* TDR 1099 TbI 4 Microwave Building (Forked River Site) 188 This building contains equipment that provides automatic start of FRCTs one hour after SBO event has begun. However, automatic start is not required for SBO. The FRCTs can be started locally. Arrangements have been made with First Energy to provide manning of the combustion turbines, in the event the microwave building is not available.

Position Paper 4, Rev 2 Sheet 12 of 19 5.0 References

1. 10 CFR Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants.2. Oyster Creek Nuclear Generating Station UFSAR, Rev. 13, April 3, 2003.3. TDR 1099, Oyster Creek Technical Data Report, Rev. 3, January 1 St 1998 titled"Station Blackout Evaluation".

4. ISG-2, Scoping of Equipment Relied on to meet the Requirements of the Station Blackout (SBO) Rule (10CFR Part 50.63) for License Renewal (10CFR50.54(a)(3))

5. GPUN letters dated April 17,1989 and March 3 0 th 1990, to NRC;

Subject:

OC Compliance with SBO Rule.6. GPUN letters dated October 7t 1991, and December 4 th 1991, to NRC and October 2 2 nd 1992; subject: OC Compliance with SBO Rule, Supplementary Information.

7. NRC Regulatory Guide 1.155, "Station Blackout" 8. NRC Safety Evaluation Report Letters, dated August 2 3 rd 1991, February 1 2 th, 1992 and November 23,1992, subject: NRC SER of OC Compliance with SBO Rule.9. MDD-OC-743-A, Div I, titled "Division I Modification Design Description for OCNGS-Tie in of Forked River Combustion Turbines For Use As An Alternate AC Source To Mitigate A Station Blackout Event".10. MDD-OC-743-A, Div II, titled "Division II Modification Design Description for OCNGS-Tie IN of Forked River Combustion Turbines For Use As An Alternate AC Source To Mitigate A Station Blackout Event".11. SDD OC-700A, Div I System Design Description for OCNGS-Forked River Combustion Turbines For Use As An Alternate AC Source To Mitigate A Station Blackout Event".12. Controlled Database, (PIMS) Oyster Creek Component Record List (CRL)13. BR 2003 sht. 1, rev. 83, Condensate/Feed System Flow Diagram 14. BR 2004 sht. 2, rev. 82, Condensate Transfer System Flow Diagram 15. BR 2005 sht. 2, rev. 86, Reactor and Turbine Building Service Water Flow Diagram 16. BR 2005 sht. 4, rev. 73, Emergency Service Water System Flow Diagram 17. BR 2006 sht. 1, rev. 72, Reactor Building Closed Cooling Water Flow Diagram 18. BR 2006 sht. 3, rev. 56, Reactor Building Closed Cooling Water Flow Diagram 19. BR 2006 sht. 4, rev. 63, Turbine Building Closed Cooling Water Flow Diagram 20. BR 2006 sht. 5, rev. 56, Turbine Building Closed Cooling Water Flow Diagram 21. BR 2009 sht. 1, rev. 43, Turbine Building H & V Flow Diagram 22. BR 2010 sht. 3, rev. 23, Office Building HVAC (480V Switchgear Room)23. BR 2010 sht. 4, rev. 26, Control and Cable Spreading Rooms HVAC Flow Diagram 24. BR 2010 sht. 5, rev. 21, Battery and MG Set Room Ventilation Flow Diagram 25. BR 2011 sht. 1, rev. 40, Drywell Cooling System Flow Diagram 26. BR 2011 sht. 2, rev. 58, Reactor Building Ventilation Flow Diagram 27. BR 2012 sht. 1, rev. 14, Old Radwaste Building H & V Flow Diagram 28. BR 2013 sht. 1, rev. 67, Service Air System Flow Diagram 29. GE148F262, sht. 1 rev. 50, Emergency Condenser Flow Diagram 30. GE148F740 sht. 1, rev. 43, Containment Spray System Flow Diagram 31. GE885D871 sht. 1, rev. 71, Core Spray System Flow Diagram Position Paper 4, Rev 2 Sheet 13 of 19 32. GEl 12C2650 sht. 15, rev. 14, Main Control Room Panels, Electrical Connection Diagram, Panel 5F/6F 33. GE846D919 sht. 2, rev. 7, Assembly, Panel 5F/6F 34. Engineering Standard ES-1 7, Identification of Oyster Creek Plant Systems 35. Procedure 2000-OPS-3024.1 Oa, rev. 11 titled Electrical Distribution-41 60VAC Diagnostic

&Restoration Actions, 36. Procedure ABN-37, rev. 0, titled Station Blackout 37. Procedure 337, rev. 57, titled 4160 Volt Electrical System 38. Procedure 338, rev. 57, titled 480 Volt Electrical System 39. Draft NUREG-1 800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, January 2005 40. 10CFR50.2, Definitions

41. Procedure PLI-02, Scoping of Systems and Structures

42. Procedure PP-01, License Renewal Systems and Structures

43. TDR 975, Loss of HVAC during an OCNGS Station Blackout 44. TDR 976, Loss of Spent fuel Pool Cooling during an OCNGS Station Blackout 45. Memo 5350-95-019, OCNGS Station Blackout Ambient Temperature (TDR 1099, Section Xl, recommendation 2)46. TDR 1094, Oyster Creek Station Blackout Loads Control Circuit Analysis Position Paper 4, Rev 2 Sheet 14 of 19 TABLE I -SYSTEMS AND STRUCTURES CREDITED TO COPE WITH AN SBO EVENT (10 CFR 50.63 Credited Systems -1' hour)ES-1 7 SSystem ystem Function Reference Number 104 Piping and Pipe Supports Pressure Boundary for UFSAR (Ref. 2), Sections (Support System for all Fluids; Structural 3.2 thru 3.8; TDR 1099 SBO fluid systems) Support for Pressure Table 4 (Ref. 3)Boundary 211 Isolation Condenser Decay Heat Removal UFSAR Sections 6.3.1.1 System and Isolation Provides Isolation (Ref. 2); TDR 1099 Table 4, Condenser Shell Side Condenser Shell Side Section V; (Ref. 3)Water Level Indication Water Level Indication LI-IG0007B (Panel 1 F/2F)223 Reactor Recirculation Provides pressure System piping boundary flow path to the Isolation Condenser.

735 125V Station DC System Powers SBO UFSAR Section 8.3.1.1, (B & C Batteries, panels, Response Equipment (Ref. 2); TDR 1099 Section MCCs & distribution for the first hour. IV (Ref. 3).centers)Reactor Plant Provides Reactor TDR 1099 Table 4 622 Instrumentation Water Level Indication 626 Remote Shutdown Reactor TDR 1099 (Ref 3)Water/Isolation Condenser Level Indication 733 120V AC Vital Power Powers critical 120 UFSAR Section 8.3.1.1.4 System VAC Instrumentation, (Ref. 2);controls and CLR (Ref. 11); TDR 1099 Auxiliaries Table 4 & 6 762 Emergency Lighting Illuminates SBO TDR 1099 Table 5 (Ref. 3);System Response Equipment TDR 1094, Attachment A (Ref. 4).787 Radio Communications Supports QCL 0-787-0000 communication ABN-37 between operators Position Paper 4, Rev 2 Sheet 15 of 19 TABLE II -SYSTEMS CREDITED FOR SAFE SHUTDOWN DURING STATION BLACKOUT ES-17 System System Description System Function Reference Number '____-______X_____________-_

104 Piping and Pipe Pressure Boundary for UFSAR (Ref. 2), Sections 3.2 thru Supports Fluids; Structural Support 3.8; TDR 1099 Table 4 (Ref. 3)(Support System for for Pressure Boundary all SBO fluid systems)211 Isolation Condenser Decay Heat Removal; UFSAR Sections 6.3.1.1 (Ref. 2);System and Isolation Provides Isolation TDR 1099 Table 4,Section V; (Ref.Condenser Shell Side Condenser Shell Side 3)Water Level Indication Water Level Indication LI-IG0007A

& Ll-IG0007B (Panel 1 F/2F)212 Core Spray System & Isolation Condenser UFSAR Sections 6.3.1.3 (Ref. 2);ADS Shell Side Make-up TDR 1099 (Ref. 3) Table 4,Section V; Ref. 30 223 Reactor Recirculation Provides pressure System piping boundary flow path to the Isolation Condenser.

225 Control Rod Drive Reactor Makeup UFSAR Sections 4.6.1.2 &System (CRD Pump) 6.3.1(Ref.

2); TDR 1099 (Ref. 3)Table 4,Section V 424 Condensate Transfer Source of Inventory UFSAR Section 10.4.7 (Ref. 2); Ref.System (CST) Make-up for RPV and IC 13 TDR 1099 Table 6 (Ref. 3);622 Reactor Plant Monitors Core for UFSAR Section 7.6.1.1.1

&Instrumentation adequate cooling, 7.6.1.1.2, (Ref. 2); Table 7.5-3 &7.6-2; TDR 1099 Table 4 (Ref. 3)626 Remote Shutdown Reactor Water/Isolation TDR 1099 (Ref 3)Condenser Level Indication 731 4160 V Distribution Restoration of Onsite or UFSAR Section 8.3.1.1.1, & 8.3.11 System Offsite Power, Powers (Ref. 2); TDR 1099 Table 5 (Ref. 3);SBO Response TDR 1094, Attachment A (Ref. 4)Equipment after 15' hour, powered by AAC 732 480 V Distribution Restoration of Onsite or UFSAR Section 8.3.1.1.2

& 8.3.1.2, System Offsite Power, Powers (Ref. 2); TDR 1099 Table 5 (Ref. 3);SBO Response TDR 1094, Attachment A (Ref. 4).Equipment after 1 st hour, powered by AAC 733 120V AC Vital Power Powers critical 120 VAC UFSAR Section 8.3.1.1.4 (Ref. 2);System Instrumentation, controls CLR (Ref. 11); TDR 1099 Table 4 &and Auxiliaries 6

Position Paper 4, Rev 2 Sheet 16 of 19 ES-17 System System Description

` System Function Reference Number 734 120/208V Non- Control power for 4160V TDR 1094 Essential Distribution Ventilation 735 125V Station DC Powers SBO Response UFSAR Section 8.3.1.1, (Ref. 2);System Equipment for the first TDR 1099 Section IV (Ref. 3).(MG Set Battery hour, and provides Charger A & B; C control power for the Battery Charger coping period duration.C1 /C2)743 Station Blackout Powers 4160V bus 1 B UFSAR Section 8.3.4 (Ref. 2); TDR Combustion Turbines via Switchgear cubicle 1099 Section IV & IX (Ref. 3); );& Supplemental 1 BO after first hour of MDD-OC-743-A Div II (Ref. 8);Systems located at SBO event MDD-OC-743-A Div I (Ref. 7); TDR Forked River (includes 1094 Attachment A, (Ref. 4).turbine lube oil system, fuel system, DC power system, SBO Transformer) 787 Radio Supports communication QCL 0-787-0000 Communications between operators ABN-37 821 4160V Switchgear Provides ventilation for TDR 1099 (Ref 3), TDR 975, Memo Room Ventilation equipment cooling 5350-95-019 (Ref 44)823 480 V Switchgear Provides ventilation for TDR 1099 (Ref 3), TDR 975, Memo Room Ventilation equipment cooling 5350-95-019 (Ref 44)823 Battery and MG Set Provides ventilation for TDR 1099 (Ref 3), TDR 975, Memo Room Ventilation equipment cooling 5350-95-019 (Ref 44)826 Control Room Provides ventilation for UFSAR Sections 6.4.1 & 9.4.1 Ventilation cooling equipment (Ref.2); TDR 1099 Table 4 & 6 (Ref.3)852 Instrument Air Provides control air to TDR-1 099 Table 6 (Ref. 3)operate isolation BR-2004 sheet 2 (Ref. 14)condenser makeup valves V-1 1-34, V-1 1-36.

Position Paper 4, Rev 2 Sheet 17 of 19 TABLE Ill -SYSTEMS REQUIRED TO RECOVER FROM A STATION BLACKOUT EVENT ES 17 System Structure Description System Function Reference Number 701 Switchyard Facilities Restoration of Offsite Power (recovery References 35, 36, 37 from an SBO)721 230 KV Bus, Lines and Restoration of Offsite Power (recovery UFSAR Sections 8.1.2, 8.2.1 Assoc. Equipment, from an SBO) & 8.2.1.1 (Ref. 2); TDR 1099 Protective Relays & Section IV; References 35, Controls 36, 37 722 34.5 KV Bus Lines and Restoration of Offsite Power (recovery)

UFSAR Sections 8.1.2, 8.2.1 Assoc. Equipment, from an SBO & 8.2.1.2 (Ref. 2): TDR 1099 Protective Relays & Section IV (Ref. 3);Controls References 35, 36, 37 724 Startup Transformers, Restoration of Onsite and Offsite Power UFSAR Sections 8.1.2, 8.2.1, Protective Relays & (recovery from an SBQ) 8.2.1.1 & 8.3.11 (Ref. 2); TDR Controls 1099 Section IV; References 35, 36, 37 731 4160 V Distribution Restoration of Onsite or Offsite Power, UFSAR Section 8.3.1.1.1, &System Powers SBO Response Equipment after 8.3.11 (Ref. 2); TDR 1099 1 st hour, powered by AAC Table 5 (Ref. 3); TDR 1094, Attachment A (Ref. 4);References 35, 36, 37 732 480 V Distribution Restoration of Onsite or Offsite Power, UFSAR Section 8.3.1.1.2

&System Powers SBO Response Equipment after 8.3.1.2, (Ref. 2); TDR 1099 1 st hour, powered by AAC Table 5 (Ref. 3); TDR 1094, Attachment A (Ref. 4);References 35, 36, 37 741 Emergency Diesel Restoration of Onsite Power (recovery UFSAR Section 8.3.2.1 (Ref.Generators and from an SBO) 2); TDR 1099 Section IX.2 Auxiliaries (Ref. 3); References 35, 36, 37 Position Paper 4, Rev 2 Sheet 18 of 19 TABLE IV -STRUCTURES REQUIRED FOR STATION BLACKOUT EVENT ES-17 System Sstructure Structure'Function Reference Number Description 101 Equipment Structurally supports equipment within UFSAR Section 3.8 & 3.9 Supports the Scope of 1 0.CFR 50.63 (Ref. 2)151 Turbine Building Protects Safety Related 4160V UFSAR Section 6.4, 8.3.2 Switchgear, DC Distribution Center C, & 2.3.1.2.1 (Ref. 2), TDR Electrical Equipment, Condensate 1099 Table 6 (Ref 3);Pumps and Control Room (Mechanical TDR 1094 Attachment A and Electrical Equipment required to (Ref. 4)mitigate Station Blackout event) from hurricane and tornado events.153 Reactor Building Protects Safety Related Core Spray, UFSAR Section 6.4. & 8.3 Containment Spray, CRD Pumps & 2.3.1.2.1 (Ref. 2), TDR RBCCW pumps and related Electrical 1099 Table 6 (Ref 3);Equipment (Mechanical Equipment TDR 1094 Attachment A required to mitigate Station Blackout (Ref. 4)event) from hurricane and tornado events.156 Main Office Protects safety related DC Distribution UFSAR Sections 6.4, Building Center B, Battery B and associated 8.3.2.1 & 2.3.1.2.1; (Ref.chargers (Mechanical and Electrical 2), TDR 1099 Table 6 Equipment required to mitigate an SBO (Ref 3); TDR 1094 event) from hurricane and tornado Attachment A (Ref. 4)events.157 Diesel Generator Protects safety related Diesel UFSAR Sections 3.3, 3.7 Building Generators (equipment that could be & 3.8 (Ref. 2)used to restore onsite power following an SBO event) from hurricane and tornado events.171 Condensate Provides protection for condensate Transfer Building transfer equipment credited for SBO.177 Substation The 34.5kV Oyster Creek substation is UFSAR Section 8.1 & 8.2 the power source for restoration of (Ref. 2)Onsite & Offsite Power.773 Underground Provides protection from the weather, UFSAR Section 8.3.4 Duct Banks erosion and galvanic corrosion of (Ref. 2) MDD-OC-743-A FRCT Transformer Power Cables, Div II (Ref. 8)

Position Paper 4, Rev 2 Sheet 19 of 19 ES-17 System !' Structure

-7Structure Function .0 .Reference Number Description Protective Relaying Cables, Control/Instrumentation Cables None Forked River Provides protection from the weather Combustion for personnel, FRCTs and associated Turbine Buildings equipment.

.Exelon C'orporation PP-5 Rev. 01 Sheet I of 10141)10 l Systems and Structures Relied upon to Demonstrate Compliance With 10 CFR 50.62 -ATWS Oyster Creek Nuclear Generating Station License Renewal I Exelon Corporation PP-5 Rev. 01.Sheet 2 of 10 1i j I APPROVAL PAGEI Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Mark Miller Don Warfel Date 1/20/04 1/20/04 1/20/04 01 Kevin Mliwleston Mark M'Jiller Don _Warfei Date 4/26/2005 4/26/2005 4/26/2005 02 1D a te I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

PP-5 Rev. 01 Sheet 3 of.10 144 l-REVISION

SUMMARY

Rev i I Required Changes to Achieve Revision 0 N/A (Initial Issue)1 2 3 4 5 PP-5 Rev. 01 Sheet 4 of 1011410l TABLE OF CONTENTS Page Approval Page.2............

...... 2 Revision Summay .3 TABLE OF CONTENTS .4 1.0 Purpose..2.0 Scope.5 3.0 Methodology

.5 4.0 References.8 5.0 Attachments.9 Attachment 1 -Systems Required for ATWS .9 Attachment 2 -Structures Required for ATWS .10 PP-5 Rev. 01 Sheet 5 of 1.0 Purpose License Renewal Rule, 10 CFR Part 54, requires that all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for anticipated transients without scram (10 CFR 50.62, ATWS) be included in the scope of license renewal. (1OCFR54.4(a)(3))

This position paper identifies the Oyster Creek Nuclear Generating Station systems and structures relied on to demonstrate compliance with the ATWS rule. The ATWS rule does not require an analysis or demonstration of the ability to cope with an ATWS event, but instead requires the installation of specific systems and equipment to reduce the risk from ATWS. For license renewal, the ATWS scope applies only to these specific systems and their associated supporting or protective structures.

The required systems are identified in Attachment

1. The required structures are identified in Attachment

2. This position paper will be used in conjunction with Project Level Instruction PLI-2, "Scoping of Systems and Structures." This position paper is for the use of personnel engaged in the preparation, review, or approval of scoping evaluations in support of license renewal activities for Oyster Creek. This paper documents the technical basis for the license renewal scoping conclusions, along with the methodology and CLB source documents used. It identifies which of the "License Renewal Systems & Structures" identified in PP-01 is required to demonstrate compliance with 1OCFR50.62 ATWS requirements, as described in the CLB. Results will be used to populate the corresponding license renewal database field. Systems and structures listed will answer "Yes" to scoping criteria 54.4(a)(3) for ATWS (reference 11).2.0 Scope The scope of this document is considered to be those systems and associated supporting or protective structures that are required for the Oyster Creek Nuclear Generating Station to comply with the requirements of 10 CFR50.62, the ATWS rule.Components at Oyster Creek Nuclear Generating Station can be associated with a system or structure through design drawings or the Component Record List (Ref. 3). License renewal scoping is performed at the system and structure level. The scope of this review is therefore limited to the identification of systems and structures.

The identification of individual components is not within the scope of this position paper.3.0 Methodology Regulatory requirements for ATWS are contained in 10CFR50.62.

Anticipated Transient Without Scram (ATWS) means an anticipated operational occurrence (as defined in IOCFR50 Appendix A)followed by the failure of the reactor trip portion of the reactor protection system. For boiling water reactors (BWR), the following requirements apply:

PP-5 Rev. 01 Sheet 6 of 10114040 1. Each BWR must have an alternate rod injection (ARI) system with redundant scram air header exhaust valves. The ARI system must be independent of the existing reactor trip system.2. Each BWR must have a standby liquid control system with defined boron injection capabilities.

Standby liquid control system automatic initiation is not required for plants issued a construction permit before July 26, 1984, unless already installed.

3. Each BWR must have equipment to trip the recirculation pumps automatically under conditions indicative of an ATWS.The ATWS rule itself dictates the systems that are required for a boiling water reactor. Oyster Creek compliance with IOCFR50.62, including the required Oyster Creek systems, is described in UFSAR Section 15.8. The CRL (reference

3) contains a controlled data field to identify components credited for ATWS. The ATWS data field is a "Design Quality" field (reference 5), which means the data is controlled and has been verified accurate.

Guidance for design control of this data field is provided in reference 8.Systems and structures in the scope of license renewal under 10 CFR 54.4(a)(3) criteria associated with ATWS are not subject to 10 CFR 54.4(a)(2) system review, for evaluating the failure of non-safety related systems and their impact on satisfying intended functions to meet 10 CFR 54.4(a)(1)(i), (ii), or (iii). The ATWS rule does not require detailed analysis of ATWS event scenarios, but instead prescribes the specific systems that must be installed or upgraded to comply with the regulation.

For license renewal, the scope of systems "relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for anticipated transients without scram" are those systems prescribed in the rule.Attachment 1 is a list of those systems that are credited for mitigation of an ATWS event. The Oyster Creek UFSAR and the Component Record List are the source documents for identifying systems credited for ATWS. The first step to create this list was to download all of the Oyster Creek CRL components from the CRL to an Access database.

The downloaded list of components was then filtered to identify only the Oyster Creek ATWS components, based on the controlled "Design Quality" (see reference

5) CRL ATWS data field. The filtered list was then sorted by system to obtain the list of systems identified in Attachment

1. System identification is based on the names and groupings in Engineering Standard ES-17 (reference 4). The Attachment 1 list is consistent with the description of ATWS compliance in the UFSAR Section 15.8. The Attachment 1 systems can be confirmed by review of the identified CLB references.

Technical Data Reports TDR-693 and TDR-793 (references 6 and 7) document technical assessments of the ATWS rule and how it applies and is implemented at Oyster Creek. These documents were reviewed to confirm the list of systems in Attachment 1.The ATWS Rule was published as 1OCFR50.62 in 1984. Prior to publication of the ATWS Rule, General Electric performed an ATWS study for Oyster Creek (reference 13, March 1975). The purpose of this study was to evaluate ATWS consequences at Oyster Creek, to assist the NRC in evaluating whether there is a need for plant changes to resolve the ATWS issue. The study PP-5 Rev. 01 Sheet 7 of 10 11010 demonstrated that the postulated ATWS event would not have unacceptable consequences at the Oyster Creek plant if the recirculation pumps are tripped and if the Standby Liquid Control system is manually initiated within 5 minutes. No credit is taken for Alternate Rod Insertion (ARI) initiation in the analysis.

This study confirms that the systems required for a BWR under 1OCFR50.62 and identified in Attachment 1 are adequate to reduce the risk from an ATWS event.I The structures within the scope of 1OCFR50.62 ATWS are identified in Attachment

2. These structures were identified from a review of the systems identified in Attachment

1. Structures that provide physical support or shelter for the systems in Attachment 1 are included in the scope of license renewal and are identified in Attachment

2. These mechanical portions of these systems are known to be located in the Primary Containment or Reactor Building, and the electrical logic and controls are located in the Main Control Room (Turbine Building).

A review of the physical location fields in the CRL (an "information only" data field) provided additional assurance that these ATWS system components are located in the identified structures.

The systems identified in Attachment 1 are based on ES-17 system designations.

When performing license renewal scoping in accordance with PLI-02 (reference 10), it will be necessary to first refer to PP-1 (reference

11) to determine which ES-17 systems are included in the license renewal system under review. If any of the ES-17 systems on Attachment 1 are included in the license renewal system under review, then the ATWS scoping question will be answered "Yes." The structures identified in Attachment 2 are based on the structure identification from PP-I.

PP-5Rev.01 Sheet 8 of 10 141l 4.0 References

1. 10 CFR 50.62, "Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants" 2. Oyster Creek Nuclear Generating Station, Updated Final Safety Analysis Report, Revision 13 3. Oyster Creek Component Record List (CRL)4. Engineering Standard ES-17, Revision 22, Identification of Oyster Creek Plant Systems 5. EP-035, Revision 8, CRL Control 6. TDR 693, Assessment of NRC ATWS Rule 7. TDR 793, Alternate Rod Injection (ARI) Technical Assessment Report for ATWS Rule 8. EP-01 1, Revision 11, Methodology for Assigning and Maintaining the Quality Classification of Components

9. GE 148F7714, Revision 44, Flow Diagram, Reactor Vessel Level/Pressure/Temperature Instruments

10. PLI-02, Scoping of Systems and Structures

11. PP-1, License Renewal Systems and Structures

12. AR A2079502-3, A2079501-4, for update of CRL ATWS field 13. NEDO-20848, Anticipated Transient Without Scram, Study for the Oyster Creek Nuclear Generating Station, March 1975 PP-5 Rev. 01 Sheet 9 of 10144-0 I 5.0 Attachments Attachment 1 -Systems Required for ATWS System lES-17 1 Reference

/ Comments Standby Liquid Control System 213 UFSAR 15.8.2 (Ref. 2), CRL (Ref. 3)Reactor Plant Instrumentation 622 CRL (Ref. 3)Alternate Rod Insertion System 643 UFSAR 15.8.1, 3.9.4.4, 7.3.1.1.6 (Ref. 2), CRL (Ref. 3)Recirculation Pump Trip 642 UFSAR 15.8.3 PP-5 Rev. 01 Sheet 10 of I 10140 4 Attachment 2 -Structures Required for ATWS Primary Containment Reactor Building Turbine Building Component Supports Commodity Group I Exelon Corporation PP-6 Rev. 01 Sheet I of 12 Systems and Structures Relied upon to Demonstrate Compliance With 10 CFR 50.49 -Environmental Qualification Oyster Creek Nuclear Generating Station License Renewal Exelon Corporation PP-6 Rev. 01 Sheet 2 of 12 APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Mark Miller Don Warfel Date 1/8/04 1/8/04 1/13/04 01 Kevin Muggleston Mark Miller Don Warfel Date 6/21/04 6/21/04 02 D ate I _ _ __ _ _ __ _I__ _ _

PP-6 Rev. 01 I Sheet 3 of 12.l REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)1 Incorporated comments from Oyster Creek EQ SME A. Hertz.2 3 4 5 PP-6Rev.01l(Sheet 4of 12l TABLE OF CONTENTS Page Approval Page.................................................................................................................................2 Revision Summary ......................................

3 TABLE OF CONTENTS ......................................

4 1.0 Purpose ...............................................

5 2.0 Scope ...............................................

5 3.0 Requirements for Environmental Qualification

..............................................

5 4.0 M ethodology

.... ... ... ... ... ... ... .. ... ... ... ... ... ... ... .. 6 4.1 EQ TLAA Approach for License Renewal ..............................................

8 5.0 References

..............................................

10 Table 1 -Systems Subject to IOCFR50.49 EQ Requirements

..........

1....................................

1 Table 2 -Structures Associated with EQ Environment Boundaries

..............................................

12 PP-6 Rev. 01 Sheet 5 of 12 1.0 Purpose License Renewal Rule, 10 CFR Part 54, requires that all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for environmental qualification (1 OCFR50.49

-EQ) be included in the scope of license renewal. (1 OCFR54.4(a)(3))

This position paper identifies the Oyster Creek Nuclear Generating Station systems and structures relied on to demonstrate compliance with the EQ rule. The required systems are identified in Table 1, and the required structures are identified in Table 2. This position paper will be used in conjunction with Project Level Instruction PLI-2, "Scoping of Systems and Structures." This position paper also documents the Time Limited Aging Analysis (TLAA) approach that will be used to address environmental qualification for license renewal.This position paper is for the use of personnel engaged in the preparation, review, or approval of scoping evaluations in support of license renewal activities for Oyster Creek. This paper documents the technical basis for the license renewal scoping conclusions, along with the methodology and CLB source documents used. It identifies which of the "License Renewal Systems & Structures" identified in PP-01 are included in the scope of license renewal based on 1OCFR50.49 (EQ) compliance as described in the CLB. Results will be used to populate the corresponding license renewal database field. Systems and structures listed will answer "Yes" to scoping criteria 54.4(a)(3) for EQ.2.0 Scope The scope of this position paper is those systems at Oyster Creek Nuclear Generating Station that contain electrical equipment subject to the requirements of 1 OCFR50.49, the EQ rule. Also included in the scope of this position paper are those structures that provide the physical boundaries of the postulated harsh environments and contain environmentally qualified electrical equipment.

Components at Oyster Creek Nuclear Generating Station can be associated with a system or structure through design drawings or the Component Record List (Ref. 3). License renewal scoping is performed at the system and structure level. The scope of this review is therefore limited to the identification of systems and structures.

The identification of individual components is not within the scope of this position paper.3.0 Requirements for Environmental Qualification Regulatory requirements for environmental qualification are contained in 10CFR50.49.

This regulation applies to electric equipment important to safety, the scope of which is defined in the regulation (1 OCFR504.49(b)(1), (2) and (3)) as follows: I PP-6 Rev. 01 Sheet 6 of 12 I (1) Safety-related electric equipment.(i) This equipment is that relied upon to remain functional during and following design basis events to ensure (A) The integrity of the reactor coolant pressure boundary;(B) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (C) The capability to prevent or mitigate the consequences of accidents that could result in potential off site exposures comparable to the guidelines in §50.34(a)(1), §50.67(b)(2), or§100.11 of this chapter, as applicable.(ii) Design basis events are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure functions (b)(1)(i) (A) through (C) of this section.(2) Nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions specified in subparagraphs (b)(1) (i)(A) through (C) of paragraph (b)(1) of this section by the safety-related equipment.

(3) Certain post-accident monitoring equipment.

As indicated in 10CFR50.49(c), environmental qualification of electric equipment important to safety located in a mild environment are not included in scope. A mild environment is an environment that would at no time be significantly more severe than the environment that would occur during normal plant operation, including anticipated operational occurrences.

The design basis accident environmental parameters and associated zone boundaries are identified in Oyster Creek Engineering Standard ES-027 (Reference 7).4.0 Methodology The Oyster Creek Environmental Qualification (EQ) program includes safety-related electrical equipment, non-safety-related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions of the safety-related equipment, and certain post-accident monitoring equipment, as defined in 1 OCFR50.49(b)(1), 10CFR50.49(b)(2), and 10CFR50.49(b)(3) respectively.

The Oyster Creek UFSAR (reference

2) Section 3.11.1.1.1 indicates that the scope of the electrical equipment and components that must be environmentally qualified for use in a harsh environment is identified in the EQ Master List, GPUN document No. 990-1464 (reference 5). This document is a database listing of equipment and components, and includes fields that identify specific equipment information such as manufacturer, plant location and qualification level. The EQ Master List data has been migrated to the Oyster Creek Component Record List (reference 3). The CRL includes an Environmental Qualification data field, and this field is now used to identify the EQ components.

The EQ data field is a "Design Quality" field (reference 6), which means the data is

[PP-6Rev.

01 Sheet 7 of 12 controlled and has been verified accurate.

Guidance for design control of this data field is provided in reference 8.The systems within the scope of 1 OCFR50.49 environmental qualification requirements are identified in Table 1. The first step to create this system list was to download all of the Oyster Creek CRL components from the CRL to an Access database.

The downloaded list of components was then filtered to identify only the Oyster Creek EQ components, based on the controlled "Design Quality" CRL EQ data field described above. The filtered list was then sorted by system to obtain the list of systems identified in Table 1. System identification is based on the names and groupings in Engineering Standard ES-17 (reference 4). As an additional confirmation, the Table 1 list was compared to the EQ Master List (reference

5) to verify that the EQ Master List did not include any systems not identified in the CRL. Individual CLB references for each system in Table 1 is not required, as the entire table is based on the above review of references 3 and 5. Validating the identified EQ systems can be done by verifying that the system is identified as EQ in the Oyster Creek CRL.The structures within the scope of 1 OCFR50.49 environmental qualification requirements are identified in Table 2. These structures were identified from a review of Engineering Standard ES-027, (reference 7), and have been validated by review of all EQ component location codes in the CRL. This engineering standard defines the Design Basis Event (DBE) environmental parameters for environmental qualification purposes.

Structures that provide the physical boundaries for the postulated harsh environments and contain environmentally qualified electrical equipment are included in the scope of license renewal and are identified in Table 2. Individual CLB references for each structure in Table 2 is not required, as the entire table is based on the above review of reference

7. Validating the identified EQ structure can be done by verifying that the structure provides a harsh environment boundary in reference 7.As stated above, the purpose of this position paper is to identify the systems and structures that are required to be included in the scope of license renewal under 1 OCFR54.4(a)(3) for demonstration of compliance with environmental qualification regulations.

These systems and structures are identified in Table 1 and Table 2, respectively.

The inclusion of a system or structure in Table 1 or Table 2 does not signify that all components or all portions of that system or structure are required to demonstrate compliance with EQ regulations.

The appropriate system and structure boundaries for license renewal scope are identified during the scoping process in accordance with PLI-2. The CLB references provided in this position paper will need to be reviewed if it is necessary to determine the specific portions of a system or structure that is in scope for EQ. However, for systems in Table 1 where only a very limited portion of the system is subject to 1 OCFR50.49 requirements, a comment is included in the Table to clarify the limited scope. Such limited scope comments are not provided if much of the system is likely to be included in the scope of license renewal anyway for other reasons, such as 1 OCFR54.4(a)(1) or (a)(2). The limited EQ scope described in the comments is based on a review of the scope of components identified as EQ in the CRL for the system.Systems and structures in the scope of license renewal under the 1 OCFR54.4(a)(3) criteria associated with environmental qualification are not subject to 10 CFR 54.4(a)(2) support system review, for evaluating the failure of non-safety related support systems and their impact on satisfying intended functions to meet 10 CFR 54.4(a)(1)(i), (ii), or (iii). Non-safety related support systems, if any, would be included in the scope of the Oyster Creek EQ program by regulation under 10CFR50.49(b)(2)

EQ scope criteria.

The entire scope of systems, structures and PP-6 Rev. 0 llSheet 8 of 12 l components in the Oyster Creek EQ Program (references 3, 5, and 7) were considered in this position paper.The systems identified in Table 1 are based on ES-1 7 system designations.

When performing license renewal scoping in accordance with PLI-02 (reference 10), it will be necessary to first refer to PP-1 to determine which ES-1 7 systems are included in the license renewal system under review. If any of the ES-1 7 systems on Table 1 are included in the license renewal system under review, then the EQ scoping question will be answered "Yes." The structures identified in Table 2 are based on the structure identification from PP-1.4.1 EQ TLAA Approach for License Renewal For license renewal, the aging effects of the EQ electrical equipment are addressed as a Time Limited Aging Analysis (TLAA) and will be managed during the extended period of operation under 10 CFR 54.21 (c)(1)(iii).

In some cases, reanalysis of EQ aging evaluations will be performed to extend the qualification life of the electrical equipment.

The reanalysis of an aging evaluation is normally performed to extend the qualification by reducing excess conservatism incorporated in the prior evaluation.

Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of the Oyster Creek EQ program. While a component life limiting condition may be due to thermal, radiation, or cyclical aging, the vast majority of component aging limits are based on thermal conditions.

Conservatism may exist in aging evaluation parameters, such as the assumed ambient temperature of the component, unrealistically low activation energy, or in the assumed application of a component (de-energized versus energized).

The reanalysis of an aging evaluation is documented according to Oyster Creek quality assurance program requirements, which requires the verification of assumptions and conclusions.

Important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). These attributes are discussed below.Analytical Methods The Oyster Creek EQ program analytical models used in the reanalysis of an aging evaluation are the same as those previously applied during the prior evaluation.

The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation.

The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component.

For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.Data Collection and Reduction Methods Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior aging evaluation is the chief method used for a reanalysis.

PP6Rev.01 lSheet 9 of 12 Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in several ways, including monitors used for technical specification compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running).

A representative number of temperature measurements are conservatively evaluated to establish the temperature used in an aging evaluation.

Plant temperature data may be used in an aging evaluation in different ways, such as (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperature for an evaluation.

Any changes to material activation energy values as part of a reanalysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cycling aging.UnderlVing Assumptions The Oyster Creek EQ Program EQ component aging evaluations contain sufficient conservatism to account for most environmental changes occurring due to plant modification and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.

Acceptance Criteria and Corrective Actions Under the Oyster Creek EQ Program, the reanalysis of an aging evaluation could extend the qualification of the component.

If the qualification cannot be extended by reanalysis, the component is refurbished, replaced, or requalified prior to exceeding the period for which the current qualification remains valid. A reanalysis is to be performed in a timely manner (that is sufficient time is available to refurbish, replace, or requalify the component if the reanalysis is unsuccessful).

PP-6 Rev. 01 Sheet 10 of 12 5.0 References

1. 10 CFR 50.49, "Environmental qualification of electric equipment important to safety for nuclear power plants" 2. Oyster Creek Nuclear Generating Station, Updated Final Safety Analysis Report, Revision 13 3. Oyster Creek Component Record List (CRL)4. Engineering Standard ES-17, Revision 22, Identification of Oyster Creek Plant Systems 5. 990-1464, Revision 11, Oyster Creek Electrical Equipment Environmental Qualification Master List 6. EP-035, Revision 8, CRL Control 7. Engineering Standard ES-027, Revision 4, Environmental Parameters

-Oyster Creek NGS 8. EP-01 1, Revision 11, Methodology for Assigning and Maintaining the Quality Classification of Components

9. PP-1, License Renewal Systems and Structures

10. PLI-02, Scoping of Systems and Structures

11. AR A2080015 to remove EQ pull boxes from system 661 and delete EQ from system 641 12. 1 OCFR54.4 Requirements for Renewal of Operating Licenses for Nuclear Power Plants

[PP-6 Rev. 01 Sheet 1I of 12 I Table 1 -Systems Subject to 10CFR50.49 EQ Requirements System ES-17 I Comments (Note 1)Isolation Condenser 211 Core Spray System & ADS System 212 Shutdown Cooling System 214 Cleanup Demineralizers System 215 Reactor Head Cooling System 216 Control Rod Drive System 225 Containment Spray System 241 Containment Inerting System 242 Containment isolation valves-G!y Drywell and Suppression System 243 Main Steam System 411 Emergency Service Water System 532 RBCCW System 541 Containment isolation valves and breaker for shutdown cooling outlet valve V-5-106___Y.PASS System 555 Containment isolation valve V-40-6-GIy.

Drywell Floor and Equipment Drains 573 Containment isolation valves-eony Remote Shutdown Panel 615 Panel LSP-1AB2-9ony Reactor Plant Instrumentation 622 Engineered Safeguards Actuation System 642 Post-Accident Monitoring System 664 Hydrogen and Oxygen Monitoring System 666 480V System 732 120V AC Vital Power System 733 125V Station DC System 735 Cable, Raceway and Conduit System 770 This is not a system. The CRL contains only electrical commodity items (cables).Primary Containment Electrical 774 This system is included with structures Penetrations under "Containment Common Components" as documented in position paper PP-1 (Ref 9).Cable Routing and Terminations 775 This is not a physical plant system and does not include any installed plant components.

Reactor Building Ventilation System 822 Instrument (Control)

Air System 852 I I A &Note 1: See the CRL (reference

3) for complete list of EQ components in the sVstem.Note 2: The CRL includes EQ circuit breakers in the Recirculation system 223. These breakers are considered to be electrical components of the 480 Volt system 732.I PP-6 Rev. 01 Sheet 12 of 12 I Table 2 -Structures Associated with EQ Environment Boundaries Primary Containment Reactor Building Turbine Building Exhaust Tunnel (known as SGTS Tunnel in reference 7)Containment Common Components (Primary Containment Electrical Penetrations, see Table 1)EQ Barriers -4160 Volt Switchaear Room I Exelon Corporation PP-7 Rev. 03 Sheet I of 25 Systems and Structures Relied upon to Demonstrate Compliance With 10 CFR 50.48 -Fire Protection Oyster Creek Nuclear Generating Station License Renewal Exelon Corporation PP-7 Rev. 03 Sheet 2 of 25 APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Stu Getz Don Warfel Date 1/13/04 1/13/04 1/15/04 01 Kevin Muggleston Stu Getz Don Warfel Date 7/1/04 7/1/04 7/1/04 02 Kevin Mugglesion Stu Getz Don Warfel Date 4/25/05 4/25/05 4/25/05 l____Kevin Muggleston Sty Get I Don Warfel 51Da2e3/OS 512315s__-_ _- 4 Formatted I

PP-7 Rev. 03l Sheet 3 of 25 l REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)I Incorporate peer review (C. Pragman, M. Carlson) comments, added fire protection power supply systems.2 Correct errors in Table 4, add Roof Drains and Overboard Discharge and Chlorination Facility.lCredit RPV for FSSD, clarif Reactor Head Vent valve scopin. pen Item 403.4 5 PP-7 Rev. 03 -ISheet 4 of 25 lTABLE OF CONTENTS Pag~e Approval Page ......2....... ............................

..... ...... 2 Revision Summary .............................................................

3 TABLE OF CONTENTS ..... ...................

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4 1.0 Purpose ..........................................................................

5 2.0 Scope ...... ...................................................................

5 3.0 Fire Protection Requirements

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5 4.0 Methodology

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7 4.1 Systems Credited for Fire Safe Shutdown ..........................................................................

8 4.2 Systems Credited for Fire Detection and Suppression

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9 4.3 Additional Systems Credited in Commitments Made in Response to Appendix A of BTP APSCB 9.5-1 ..........

10 4.4 Structures Relied Upon to Demonstrate Compliance with 10 CFR 50.48 ............................................................

I 11 5.0 References

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13 Table I -Systems Credited for FSSD With Associated FSSD Functions

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15 Table 2 -Systems Credited for Fire Detection and Suppression

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19 Table 3 -Additional Systems Credited in Commitments Made in Response to Appendix A of BTP APSCB 9.5-1.20 Table 4 -Consolidated Table of Systems Relied Upon to Demonstrate Compliance with 10 CFR 50.48 ..........

....... 21 Table 5 -Structures Required to Demonstrate Compliance with 10 CFR 50.48 ........................................................

23 Table Notes ....... ..................................................................

24

[PP-7 Rev.03 l Sheet 5 of 25 1.0 Purpose License Renewal Rule, 10 CFR Part 54, requires that all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48) be included in the scope of license renewal. (1OCFR54.4(a)(3))

This position paper identifies the Oyster Creek Nuclear Generating Station systems and structures relied on to demonstrate compliance with 10 CFR 50.48 (Fire Protection).

The required systems are identified in Table 4 and the required structures are identified in Table 5. This position paper will be used in conjunction with Project Level Instruction PLI-2, "Scoping of Systems and Structures." This position paper is for the use of personnel engaged in the preparation, review, or approval of scoping evaluations in support of license renewal activities for Oyster Creek. This paper documents the technical basis for the license renewal scoping conclusions, along with the methodology and CLB source documents used. It identifies which of the "License Renewal Systems & Structures" identified in PP-01 is required to support IOCFR50.48 Fire Protection functions as described in the CLB. Results will be used to populate the corresponding license renewal database field. Systems and structures listed will answer "Yes" to scoping criteria 54.4(a)(3) for IOCFR50.48.

This position paper also provides a source of CLB references that can be reviewed to confirm or establish the license renewal system boundaries associated with this regulated event.2.0 Scope The scope of this document is those systems and structures that are required for the fire protection program to comply with the fire protection requirements of 10 CFR50.48.

This includes: 1. Systems and structures required for post-fire safe shutdown.2. Systems and structures required for fire detection and suppression.

3. Systems and structures required to meet commitments made to Appendix A of Branch Technical Position Auxiliary Power Conversion System Branch BTP APCSB 9.5-1 (Reference 6).Most components at Oyster Creek Nuclear Generating Station can be associated with a system or structure through design drawings or the Component Record List (Ref. 7). The Component Record List (CRL) is a controlled component database used to identify and track systems, structures and components at Oyster Creek. License renewal scoping is performed at the system and structure level in accordance with project level instruction PLI-2. Therefore, the scope of this review is limited to the identification of systems and structures.

The identification of individual components is not within the scope of this position paper. Individual components or pieces of equipment are identified only when an appropriate system correlation does not exist.3.0 Fire Protection Requirements 10 CFR 50.48 requires each operating nuclear power plant to have a fire protection plan that satisfies the requirements of Criterion 3 of 10 CFR 50 Appendix A.

lPP-7 Rev. 03 l[Shet 6 of 25 Criterion 3 -- Fire Protection; "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room.Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components." 10 CFR 50.48 requires all nuclear power plants licensed to operate prior to January 1, 1979, to comply with Sections IllI.G, III.J and I11.0 of Appendix R to 10 CFR 50.Section III.G requires fire protection features to be provided for those system, structures and components important to safe shutdown.

These features must be capable of limiting fire damage so that: 1. One Train of systems necessary to achieve and maintain hot shutdown conditions from either the main control room or the emergency control station(s) is free of fire damage, and 2. Systems necessary to achieve and maintain cold shutdown from either the main control room or the emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.Section IlI.G also includes requirements for alternative shutdown capability.

Section III.J requires that emergency lighting units with at least 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.Section III.L provides the acceptance criteria for III.G.3.Section 111.0 establishes requirements for oil collection systems for Reactor Coolant Pumps. This section is not applicable to Oyster Creek because the containment is inert during normal operation.

Except for the requirements of Sections III.G, II.J and 111.0, the provisions of 10 CFR 50 Appendix R are not applicable to nuclear power plants licensed to operate prior to January 1, 1979, to the extent that plant fire protection features have been accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports. These "Appendix A" commitments are documented in the Oyster Creek Fire Hazards Analysis Report (Ref. 1). and are part of Oyster Creek's demonstrated compliance with 10 CFR 50.48.

lPP-7 Rev. 03 lSheet 7 of 25 4.0 Methodology The scope of systems and structures considered necessary to demonstrate compliance with 10 CFR 50.48 can be broken down into the following categories:

1. Systems and structures required for post-fire safe shutdown.2. Systems and structures required for fire detection and suppression.

3. Systems and structures required to meet commitments made to Appendix A of Branch Technical Position Auxiliary Power Conversion System Branch BTP APCSB 9.5-1 Fire Protection systems are not safety related, and therefore are not subject to 10 CFR 54.4(a)(2) support system review, i.e., for evaluating the failure of non-safety related support systems and their impact on satisfying intended functions to meet 10 CFR 54.4(a)(1)(i), (ii), or (iii). First-level, primary support systems which are necessary for the functioning of equipment credited in the Fire Hazards Analysis Report or Safe Shutdown Analysis to demonstrate compliance with 10 CFR 50.48 (Fire Protection) are included in scope and are identified in the tables. However, second-, third- and fourth-level support systems, back-up systems and systems or structures whose failure could indirectly cause failure of credited equipment are not within the scope of 10 CFR Part 54 unless such lower-level, back-up or indirect support systems or structures are explicitly credited in a CLB document.The systems and structures required for post-fire safe shutdown are identified from a review of the CLB documents that describe the safe shutdown analysis (see section 4.1 for complete references).

The systems and structures required for fire detection and suppression are identified from review of the UFSAR descriptions (including the Fire Hazards Analysis Report), the Component Record List (CRL) and the plant Flow Diagrams.

The CRL includes a Fire Protection data field and a Fire Safe Shutdown data field. These data fields are "Design Quality" (reference 33), which means the data is controlled and has been verified accurate.

Guidance for design control of these data fields is provided in reference

34. As the final check, the commitments associated with BTP APCSB 9.5-1 were also reviewed to identify any additional fire protection systems and structures not previously identified.

For systems, the results of these three review steps are documented in Tables 1, 2, and 3. The results were documented in separate tables to simplify the review and facilitate future revisions.

Table I is organized according to FSSD Functions, and so it is possible for the same system to be listed under more than one function.

Table 2 identifies the systems required for fire detection and suppression.

It is possible for some of the same systems to be listed on both Table 1 and Table 2. It is important to recognize that Table 3 includes ONLY those systems credited in an "Appendix A" commitment and NOT previously identified in Table I or Table 2. If any systems or equipment are considered for deletion from Tables I or 2 in future revisions to this position paper, the commitments of FHAR Attachment A must also be reviewed.

Tables 1, 2, and 3 include a column to identify the appropriate CLB reference(s), additional note references, or any comments.

Table 4 is a consolidated list of systems from Tables 1, 2, and 3. Table 4 will be used as the input for completing the system scoping review packages.

For structures, the results are provided in Table 5 with the appropriate CLB reference(s) identified.

PP-7 Rev. 03 Sheet 8 of 25 Not all CLB documents use the exact same terminology for the various plant systems and structures.

System identification is based on the names and groupings in Engineering Standard ES-17 (reference 21). Structure identification is based on the names and groupings in Engineering Standard ES-17 (reference

21) or position paper PP-i (reference 28). Some source documents identify credited components without identifying the associated system. In such cases, the CRL (reference

7) was used as the basis to determine the appropriate system number. The system name was then obtained from ES-17, and the system and components are identified in the table.Recent NRC guidance, including NUREG-0800 Section 9.5.1 Appendix C (reference

30) and the Proposed Staff Position on the License Renewal Rule as it Relates to the Fire Protection Rule (reference 31), states that the scope of 10 CFR 50A8 goes beyond the protection of safety related equipment, and also includes fire protection systems, structures and components needed to minimize the effects of a fire and to prevent the release of radioactive material to the environment.

Fire protection system and structure scoping for Oyster Creek is performed consistent with this guidance, as documented in this position paper.The systems identified in Table 4 are based on ES-17 system designations.

When performing license renewal scoping in accordance with PLI-02 (reference 35), it will be necessary to first refer to PP-I (reference

28) to determine which ES-17 systems are included in the license renewal system under review. If any of the ES-17 systems on Table 4 are included in the license renewal system under review, then the Fire Protection scoping question will be answered "Yes." The structures identified in Table 5 are based on the structure identification from ES-17 but also includes additional structural features.

Position Paper PP-01 should be used in conjunction with Table 5.4.1 Systems Credited for Fire Safe Shutdown Table I is a list of those systems that are required for fire safe shutdown (FSSD). The "Specification for Post-Fire Safe Shutdown Program Requirements at Oyster Creek Nuclear Generating Station" (Reference

5) is the source document for identifying systems credited for FSSD. In some cases, the specific systems being credited could not be determined from this specification alone. The INDMS Equipment Report (reference

4) and the Appendix R Safe Shutdown Path drawings (references 8, 9, 10, 11, 12) were used for clarification and additional confirmation of the FSSD systems. Table I also includes identification of the specific shutdown functions that each system is credited to perform for FSSD, including support functions.

In each case, the CLB reference(s) is identified in the Comments / Reference column.As an additional confirmation, the CRL was downloaded into an ACCESS database, and then filtered to identify only the FSSD components, based on the controlled FSSD data field. This review did not identify any additional systems required for FSSD.

iPP-7 Rev. 03 l Sheet 9 of 25 4.2 Systems Credited for Fire Detection and Suppression Table 2 is a list of those systems required for fire detection and suppression.

The systems in Table 2 are identified from a review of the UFSAR (reference 3), Oyster Creek Fire Protection System Flow Diagrams (references 15 -20), the Component Record List (CRL) and Engineering Standard ES-17 (reference 21). The CRL includes a field to identify Fire Protection components, and these components were reviewed to confirm the scope of fire protection systems. The appropriate CLB reference is identified in the Comments I Reference column of Table 2.The fire detection and suppression systems at Oyster Creek are plant-wide systems that protect both in-scope and out of scope plant equipment.

Not all portions of these systems are required to demonstrate compliance with IOCFR50.48.

Some branches of the fire detection and suppression systems protect plant areas in which a fire would not impact any equipment important to safety, or significantly increase the risk of radioactive releases to the environment.

Portions of the fire suppression and detection systems that are not included in the scope of license renewal are identified in the table below.Excluded Portions of Fire Suppression Systems Building / Area Isolation Suppression System Associated Hose Stations /Valve Hydrants Old Warehouse V-9-34 Sprinkler System #5 #24, 25 New Warehouse V-9-150 Sprinkler System #8 #56,57, 58,59, 60, 61, 62 Old QA Storeroom V-9-17 Sprinkler System #6 #1, 2 Maintenance Building V-9-333 Sprinkler System #14 Site Emergency Building V-9-913 Sprinkler System #65, 66, 67, 68 and Hydrants& New Administration

1. 17A, 17B #6, 11 Building Site Emergency Building N/A Halon System N/A Halon System Low Level Radwaste V-9-944 Sprinkler System #69, 70, 71, 72, 73, 74, 77, 80, Storage Facility (LLRW) #18, 19 81, 82, 83 Sprinkler Systems 5. 6. 8. 14. 17A. 17B These sprinkler systems, downstream of the identified isolation valves, are classified as Not Important to Safety (NITS) on the flow diagram (reference

17) and in TDR-622 (reference 29). The CRL (reference

7) does not identify any safety related components in these areas. The Fire Hazards Analysis (reference

1) does not identify any fire safe shutdown (FSSD) equipment in these areas. A fire in these areas does not significantly increase the risk of radioactive releases to the environment.

These identified sprinkler systems in these areas are not included in the scope of license renewal.

lPP-7 Rev. 03 Sheet 10of25 Site Emergency Building Halon System The Site Emergency Building Halon System is classified as Not Important to Safety (NITS) on the flow diagram (reference

20) and in TDR-622 (reference 29). The CRL (reference

7) does not identify any safety related components in this area. The Fire Hazards Analysis (reference

1) does not identify any fire safe shutdown (FSSD) equipment in this area. A fire in this area does not significantly increase the risk of radioactive releases to the environment.

This Halon suppression system is not included in the scope of license renewal.Sprinkler Systems 18. 19 in the LLRW Storaje Facility Fire protection features of the Low Level Radwaste Storage facility (also known as the Waste Storage Facility in ES-17) were determined to be out of scope based on the following analysis in the FHAR (reference 1): "The building has been analyzed for liquid or airborne radioactive releases to the environment without reliance on active or passive fire protection features.

Potential airborne releases were evaluated without reliance on the ventilation systems. Potential contaminated liquids are contained within the building for transport to decontamination processing.

Potential release due to a fire was analyzed with no reliance on fire detection or suppression equipment or activities.

Inadvertent operation of the sprinkler system was analyzed as a potential liquid release of radioactivity or contamination.

In all such cases the radioactive or contamination release was well within the limits of 10 CFR 100. Therefore a fire does not present an unacceptable release to the environment and the active and passive fire protection features of this building are not considered within the scope of BTP APCSB 9.5-1, Appendix A. The active and passive features provided for this building are to protect plant investment, satisfy insurance requirements and comply with building codes only." The LLRW Storage Facility fire suppression and detection systems are not in the scope of license renewal.Further reduction of the scope boundaries of fire detection or fire suppression systems, if needed, should be documented on a case-by-case basis in the appropriate system scoping review package.4.3 Additional Systems Credited in Commitments Made in Response to Appendix A of BTP APSCB 9.5-1 Table 3 is a list of additional systems and equipment that are identified in commitments made in response to BTP APSCB 9.5-1. The Table 3 list was identified by review of the FHAR (reference 1)Attachment A.The FHAR Attachment A includes discussions covering nearly all aspects of the Oyster Creek Fire Protection Program, including detection, suppression and FSSD systems and equipment.

To avoid

[PP-7 Rev. 03 lSheet II of 25 significant duplicate effort, Table 3 only includes system or equipment that was not already identified and included on Table I or Table 2.4.4 Structures Relied Upon to Demonstrate Compliance with 10 CFR 50.48 Table 5 is a list of the structures relied upon to demonstrate compliance with 10 CFR 50.48. The source document used to identify structures is the FHAR. Each Fire Area and Fire Zone was reviewed, and the associated structure was included in scope if it included fire barriers credited to prevent the spread of fires between analyzed fire areas or zones. Structures required to support or house Safe Shutdown systems and equipment, as identified in Section 7 of the FHAR, are also included in scope and identified in Table 5. Excluded structures are discussed below.Table 5 also includes structures that directly support or protect the portions of the fire suppression systems included in the scope of license renewal. With the boundary of the fire suppression systems reduced as described in Section 4.2, the structures included from the FHAR review includes all structures needed to support or protect the in-scope fire suppression components.

Table 5 also lists selected structural component items that were identified during the review.Although these items are not structures, they have been identified here for completeness to assure that they are properly addressed for license renewal.Excluded Structures The Old Radwaste Building (Fire Zone OR-FA-19) was excluded from Table 5. The fire hazard analysis (Reference 1, Section 7) states that this area is separated from the reactor building (railroad airlock) by 15 feet, and from other fire areas by open space of at least 50 feet. The Old Radwaste Building does not contain any fire barriers credited in the fire hazards analysis.

This building does not contain any safety related or safe shutdown equipment.

The structure includes fire detection equipment that alarms locally and in the control room, but does not contain any fire suppression systems within or supported by the structure.

The fire detection system will provide early warning of a fire to allow utilization of manual suppression.

A fire will be contained within the area and have no effect on safe shutdown.The New Radwaste Building (Fire Zone NR-FA-20) was excluded from Table 5. The fire hazard analysis (Reference 1, Section 7) states that this area is separated from other fire areas by open space of at least 50 feet. The New Radwaste Building does not contain any fire barriers credited in the fire hazards analysis.

This building does not contain any safety related or safe shutdown equipment.

The structure includes fire detection equipment that alarms in the control room, but does not contain any fire suppression systems within or supported by the structure.

The fire detection system will provide early warning of a fire to allow utilization of manual suppression.

A fire will be contained within the area and have no effect on safe shutdown.

PP-7 Rev. 03 Sheet 12 of 25 The Augmented Off Gas Building (Fire Zone OG-FA-2 1) was excluded from Table 5. The fire hazard analysis (Reference 1, Section 7) states that this area is separated from other fire areas by at least 50 feet. The Augmented Off Gas Building does not contain any fire barriers credited in the fire hazards analysis.

This building does not contain any safety related or safe shutdown equipment.

The structure includes fire detection equipment, but does not contain any fire suppression systems within or supported by the structure.

The building includes a dry standpipe that can be supplied by a hose connection, and is not normally connected to the fire water system (reference 17). A fire in this area will not affect safe shutdown.The Low Level Radwaste Storage Facility (Fire Zone LL-FA-29) was excluded from Table 5. The fire hazard analysis (Reference 1, Section 7) states that this area is separated from other fire areas by open spaces of at least 50 feet. The Low Level Radwaste Storage Facility does not contain any fire barriers credited in the fire hazards analysis.

This building does not contain any safety related or safe shutdown equipment.

As discussed in Section 4.2, the fire suppression and fire detection systems protecting the LLRW Storage Facility are not included in the scope of license renewal.The Independent Spent Fuel Storage Installation (ISFSI) -Complete Facility (Fire Zone LL-FA-30)was excluded from Table 5. The fire hazard analysis (Reference 1, Section 7) states that this area is separated from other safety related structures by open space of at least 50 feet. The ISFSI does not contain any fire barriers credited in the fire hazards analysis performed under IOCFR50.48.

This structure does not contain any safety related or safe shutdown equipment.

This structure does not contain any fire suppression or fire detection equipment.

This structure contains no flammable or combustible materials.

No specific quantification of fire loading is necessary because the facility is in an open area with nothing to contain the heat release in the event of a fire. The design of the facility precludes addition of anything inside the storage module except the shielded canisters.

The following "outdoor" fire zones are identified in Reference I Section 7. These fire zones are physically separated from the other plant structures.

There are no walls or ceilings that act as fire barriers to other fire zones. Therefore, these fire areas are not structures relied upon to demonstrate compliance with 10 CFR 50.48, and are excluded from Table 5.Fire Area Structure Fire Area LL-FA-32 Low Level Radwaste Storage Facility Yard Area Fire Area OR-FA-33 Old Radwaste/New Radwaste Yard Area Fire Area YARD General Yard Area PP-7 Rev. 03 Sheet 13 of 25 5.0 References

1. Oyster Creek Nuclear Generating Station, Fire Hazards Analysis Report, Document No. 990-1746, Revision 12 2. 10 CFR 50.48, "Fire protection" 3. Oyster Creek Nuclear Generating Station, Updated Final Safety Analysis Report, Revision 13 4. INDMS Equipment Report, EL6642002-017-01, Rev. 0 5. SP-1302-06-013, Revision 1, Specification for Post-Fire Safe Shutdown Program Requirements at Oyster Creek Nuclear Generating Station 6. Appendix A to BTP APCSB 9.5 -1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," dated August 23, 1976.7. Oyster Creek Component Record List (CRL)8. GU 3E-911-41-040, Sheet 1, Rev. 1O, Figure A-i, Appendix R Safe Shutdown -Hot Shutdown Paths -Paths I & 2 9. GU 3E-911-41-041, Sheet 1, Rev. 6, Figure A-I, Appendix R Safe Shutdown -Hot Shutdown Paths -Paths 3 & 4 10. GU 3E-911-41-042, Sheet 1, Rev. I 1, Figure A-2, Appendix R Safe Shutdown -Cold Shutdown Paths -Paths I & 2 11. GU 3E-911-41-043, Sheet 1, Rev. 7, Figure A-2, Appendix R Safe Shutdown -Cold Shutdown Paths -Path 3 12. GU 3E-911-41-044, Sheet 1, Rev. 4, Figure A-I, Appendix R Safe Shutdown -Hot Shutdown Paths -Path 5 13. CC-AA-21 1, Revision 1, Fire Protection Program 14. 2400-APR-3900.0 1, Revision 11, Appendix R Repair Kit Annual Inspection

15. JC 19479, Sheet 1, Revision 37, Fire Protection Water System Flow Diagram 16. JC 19479, Sheet 2, Revision 36, Fire Protection Water System Flow Diagram 17. JC 19479, Sheet 3, Revision 65, Fire Protection Water System Flow Diagram 18. JC 19479, Sheet 4, Revision 29, Fire Protection Water System Flow Diagram 19. JC 19629, Sheet 1, Revision 8, Fire Protection C02 Flow Diagram 20. JC 19629, Sheet 2, Revision 8, Fire Protection Halon Flow Diagram 21. Engineering Standard ES-17, Revision 22, Identification of Oyster Creek Plant Systems 22. 101.2, Revision 50, Oyster Creek Site Fire Protection Program 23. 645.6.003, Revision 16, Fire Hose Station, Hose House and Fire Hydrant Inspection

24. 645.6.006, Revision 14, Fire Hose Hydrostatic Testing 25. 645.6.008, Revision 10, Fire Hose Re-Rack and Blockage Inspection

26. 2400-GMM-3681.04, Revision 3, Inspection and Maintenance of Portable Fire Extinguishers

27. NUREG-0800, Rev. 4, October 2003, Section 9.5.1 Fire Protection Program 28. PP-I, License Renewal Systems and Structures

29. TDR-622, Revision 1, ITS/NITS Classification of Fire Suppression Systems and Fire Detection Systems 30. NUREG-0800, Section 9.5.1, Appendix C, Supplemental Fire Protection Review Criteria for License Renewal, Revision 4, October 2003 31. NRC Letter, P.T. Kuo to NEI, dated November 13,2002, Proposed Staff Guidance on the Scoping of Fire Protection Equipment for License Renewal PP-7 Rev.03 l Sheet 14 of 25 32. AR A2018081, Evaluation 45 to update CRL 33. EP-035, Revision 8, CRL Control 34. EP-O 1, Revision 11, Methodology for Assigning and Maintaining the Quality Classification of Components

35. PLI-02, Scoping of Systems and Structures

36. Procedure 331.1, Revision 15, Control Room and Old Cable Spreading Room Heating, Ventilation and Air Conditioning System 37. 3C-734-11-044, Revision 5, Miscellaneous Power/Lighting Panels Panel Schedule 38. AP PE-521 Sheet 2, Revision 8, Control Module #2, 4160V Switchgear Area 39. AR A2079501, Evaluation 1 40. AR A2079501, Evaluation 7

PP-7 Rev. 03l Sheet 15 of 25 lTable 1 -Systems Credited for FSSD With Associated FSSD Functions FSSD Function ISystem IES17] Comments I Reference Reactor Reactor Protection System 641 FSSD Specification (Ref. 5)Shutdown Control Rod Drive System 225 section 5.2.3.1 Pressure Control EMRVs (including control circuitry) 212 FSSD Specification (Ref. 5)section 5.2.3.2. EMRVs are currently in system 212, Core Spray System and ADS Isolation Condenser System 211 FSSD Specification (Ref. 5)section 5.2.3.2 Inventory Control Rod Drive System 225 FSSD Specification (Ref. 5)Control section 5.2.3.3.1 Core Spray System 212,642 FSSD Specification (Ref. 5)section 5.2.3.3.2.

Core Spray system is currently system 212, Core Spray System and ADS Main Steam System 411 FSSD Specification (Ref. 5)section 5.2.3.3.3 (Note 2)Feedwater System (Not required for 422 FSSD Specification (Ref. 5)IOCFR50.48, see Note 1) section 5.2.3.3.3 (Note 1)Condensate (Not required for 421 FSSD Specification (Ref. 5)I OCFR50.48, see Note 1) section 5.2.3.3.3 (Note I)Recirculation Pumps and M/G Sets (Not 224,642 FSSD Specification (Ref. 5)required for IOCFR50.48, see Note 1) section 5.2.3.3.3 (Note 1)Cleanup Demineralizer System 215 FSSD Specification (Ref. 5)section 5.2.3.3.3.

Called Reactor Water Cleanup System in FSSD Specification (Note 3)EMRVs 212 FSSD Specification (Ref. 5)section 5.2.3.3.3.

EMRVs are currently in system 212, Core Spray System and ADS Reactor Vessel 221 Head Vent valves -FSSD (Note 9) Specification (Ref. 5) section 5.2.3.3.3 Isolation Condenser System 211 Tube Vent Valves -FSSD Specification (Ref. 5) section 5.2.3.3.3 Shutdown Cooling System 214 FSSD Specification (Ref. 5)_section 5.2.3.3.3 Decay Heat Isolation Condenser System 211 FSSD Specification (Ref. 5)Removal Isection 5.2.3.4.1 PP-7 Rev. 03 Sheet 16 of 25 Table 1 -Systems Credited for FSSD With Associated FSSD Functions FSSD Function System ES-17 Comments I Reference ADS 212, 642 FSSD Specification (Ref. 5)section 5.2.3.4.2.

EMRVs, currently in system 212, Core Spray System and ADS Shutdown Cooling System 214 FSSD Specification (Ref. 5)section 5.2.3.4.3 Recirculation System (excludes pumps 223 FSSD Specification (Ref. 5)& MG sets) section 5.2.3.4.3 Process Reactor Plant Instrumentation 622 FSSD Specification (Ref. 5)Monitoring section 5.2.3.5.1 Feedwater Control System 625 FSSD Specification (Ref. 5)section 5.2.3.5.1.

LI-IA0013 Reactor Wide Range Level, INDMS Equipment Report (Ref.4)Drywell and Suppression System 243 FSSD Specification (Ref. 5)section 5.2.3.5.2 Torus level, INDMS Equipment Report (Ref.4)Torus Temperature Monitoring System 664 FSSD Specification (Ref. 5)section 5.2.3.5.2 Torus Temperature, INDMS Equipment Report (Ref. 4)Isolation Condenser System 211 FSSD Specification (Ref. 5)section 5.2.3.5.2.

IC Level Condensate Transfer System 424 FSSD Specification (Ref. 5)section 5.2.3.5.2.

CST Level Support Systems Startup Transformers Protective Relays 724 FSSD Specification (Ref. 5)& Controls -Offsite Power section 5.2.3 credits offsite power as a support system. INDMS Equipment Report (Ref. 4)Switchyard Facilities 701 34.5 KV Bank 5, 6 Electrical Distribution Line Breakers.INDMS Equipment Report (Ref.4)4160V System 731 FSSD Specification (Ref. 5)section 5.2.3 Diesel Generators 741 FSSD Specification (Ref. 5)section 5.2.3 480V System 732 FSSD Specification (Ref. 5)section 5.2.3 125V Station DC System 735 INDMS Equipment Report (Ref.4)

PP-7 Rev. 03 Sheet 17 of 25 Table 1 -Systems Credited for FSSD With Associated FSSD Functions FSSD Function [ System l ES-17 Comments / Reference 120V AC Vital Power Systems 733 INDMS Equipment Report (Ref.4)Main Office Building HVAC 823 Specific HVAC Systems 480V SWGR Room identified From GU 3E-911 Battery Room 040 (Ref. 8) and INDMS Equipment Report (Ref. 4)Control Room HVAC 826 Specific HVAC Systems identified From GU 3E-91141-040 (Ref. 8) and INDMS Equipment Report (Ref. 4)Containment Spray System 241, 642 FSSD Specification (Ref. 5)section 5.2.3.6.3 Emergency Service Water System 532 FSSD Specification (Ref. 5)section 5.2.3.6.4 Reactor Building Closed Cooling Water 541 FSSD Specification (Ref. 5)System section 5.2.3.6.5 Service Water System 531 FSSD Specification (Ref. 5)section 5.2.3.6.6 Condensate Transfer System 424 FSSD Specification (Ref. 5)section 5.2.3.6.7 Instrument Air System 852 BR 2013 sheet 6, INDMS Equipment Report (Ref. 4), FSSD Specification Section 5.2.3.6.7 and 7.2 (Ref. 5) (Note 4)Nitrogen Supply System 854 These systems are not required to function during a fire or survive a fire. However, they are credited with establishing the inert drywell Containment Inering System 242 environment in which a design basis fire cannot occur. (Ref. l, Reactor Building Ventilation System 822 Fire Area RB-FA-2)Fire Protection Water System 811 FSSD Specification (Ref. 5)section 5.2.3.6.8 Diesel Generator Systems 861,741 FSSD Specification (Ref. 5)section 5.2.3.6.9 Diesel Generator Fuel Oil Storage and 862 FSSD Specification (Ref. 5)Transfer System section 5.2.3.6.9 Alternative Remote Shutdown Panel 615 INDMS Equipment Report (Ref.Shutdown 4), FSSD Specification Attachment F (Ref. 5)Remote Shutdown Control and 626 ES-17 (Ref. 21), CRL (Ref. 7)Instrumentation I Local Shutdown Panels 615 FSSD Specification Attachment F I__(Ref. 5)

[PP-7 Rev. 03 llSheet 18 of 25 lTable 1 -Systems Credited for FSSD With Associated FSSD Functions FSSD Function J System lES-17 Comments / Reference imergency Emergency Lighting 762 FSSD Specification Section 6.7 Lighting (Ref. 5)Normal Lighting 761 FSSD Specification Section 6.7 (Ref. 5). Includes AC, Vital AC and DC Lighting discussed in Section 6.7. (Note 5)igh/Low Head Vent Valves V-25-21, V-25-22 221 FSSD Specification Attachment D ressure (Note 9) (Ref. 5)Interface Isolation Condenser Tube Vent Valves 211 V-14-1, V-14-5, V-14-19, V-14-20 These systems are included in MSIVs 411 scope for FSSD functions, as Main Steam Drain Valves V-1-106, V-l- 411 identified elsewhere in this table.107, V-l-l 10, V-I-ll No additional systems are added EMRVs 212 due to these High/Low Pressure Shutdown Cooling Isolation Valves V- 214 Interface locations.

17-19, V-17-54 RWCU Valves V-16-1, V-16-2, V-16-14 215 Core Spray Injection Valves V-20-150, 212 V-20-151, V-20-152, V-20-153 Communications Radio Communications Systems 787 FSSD Specification Section 6.2 Standby Gas Engine Generator 787 (Ref. 5)Repairs Cable, Connectors, Electrical Tape, Tie 911 FSSD Specification Section 9 Wraps, Splice Kits, tubing, tube fittings, (Ref. 5), Appendix R Repair Kit fasteners, hoses, smoke exhauster, flash Annual Inspection (Ref. 14), lights, flexible duct, duct adapter, power Procedure 331.1 (Ref. 36) (Note cord, level indicators 7).1.

hPP-7 Rev. 03[ Sheet 19 of 25 Table 2 -Systems Credited for Fire Detection and Suppression System ES-17 Reference/

Comments Fire Detection Systems 665 UFSAR 9.5.1.2.6 Fire Protection Water System 811 UFSAR 9.5.1.2.3.

Includes diesel driven fire pumps, associated diesel fuel oil tank and fuel supply piping, motor driven fire pumps, underground piping, water storage tank, hydrants, interior hose stations and fixed water suppression systems. (Note 8)Fire Protection C02 System 812 UFSAR 9.5.1.2.4.

Includes Turbine Exciter C02 and 4160V Switchgear Rooms C02 Fire Protection Halon System 813 UFSAR 9.5.1.2.4.

Includes 480V Switchgear Room Halon, A/B Battery Room and Control Room Panel Halon. The Site Emergency Building Computer Room and Electrical Room Halon systems are not in the scope of license renewal, see Section 4.2.Portable Foam Equipment None UFSAR 9.5.1.2.3 Portable Fire Extinguishers None UFSAR 9.5.1.2.5 Dry Chemical Inspection Procedure 2400-GMM-368 1.04 Carbon Dioxide (Note 6)Pressurized Water 480/208/120V Utility (JCP&L) Non-Vital 737 Provides power to the redundant fire pump.Power Miscellaneous Power/Lighting Panels 734 Provides power to 4160V Switchgear vault ventilation controls and fire detection control panels (ref. 37, 38)

PP-7 Rev. 03l Sheet 20 of 25 lTable 3 -Additional Systems Credited in Commitments Made in Response to Appendix A of BTP APSCB 9.5-1 System lES-17 Reference

/ Comments Lightning Protection System 752 Item A.4.Reactor Building Floor and Equipment Drains 572 D.l.l, E.3.a.Roof Drain and Overboard Discharge System 576 D. 1.1, E.3.a.Turbine Building Floor and Equipment Drains 571 D.l .1, E.3.a.Cable Spreading Room Drain Portable smoke removal equipment Item D.4. (Note 7)Portable ventilation equipment Item D.4.a. (Note 7)Main Office Building HVAC 823 Item D.4.g for smoke removal.Cable Spreading Room HVAC Turbine Building Ventilation System 821 Item D.4.g for smoke removal.4160V SWGR Room Ventilation Self Contained Breathing Apparatus (including Item D.4.h. (Note 6)compressor for providing backup 6-hour supply)Portable lights (flashlights)

Item D.5.b. (Note 7)Curbs around stairwells in Reactor Building E.3.a -provide protection from (southeast corner) water damage ShPP-7 Rev. 03 2 I Sheet 21 of 25 lTable 4 -Consolidated Table of Systems Relied Upon to Demonstrate Compliance with 10 CFR 50.48 System Name ES-17 System Number Portable Fire Extinguishers (Note 6) None Portable Foam Equipment None Self Contained Breathing Apparatus (Note 6) None Isolation Condenser System 211 Automatic Depressurization System 212 Core Spray System 212 EMRVs (including control circuitry) 212 Shutdown Cooling System 214 Cleanup Demineralizer System (Note 3) 215 Reactor Vessel 221 (Notc 9)Recirculation System 223 Control Rod Drive System 225 Containment Spray System 241 Containment Inerting System 242 Drywell and Suppression System 243 Main Steam System (Note 2) 411 Condensate Transfer System 424 Service Water System 531 Emergency Service Water System 532 Reactor Building Closed Cooling Water System 541 Turbine Building Floor and Equipment Drains 571 Reactor Building Floor and Equipment Drains 572 Roof Drains and Overboard Discharge 576 Remote and Local Shutdown Panels 615 Reactor Plant Instrumentation 622 Feedwater Control System 625 Remote Shutdown Control and Instrumentation 626 Reactor Protection System 641 Engineered Safeguards Actuation System 642 Torus Temperature Monitoring System 664 Fire Detection Systems 665 Switchyard Facilities 701 Startup Transformers Protective Relays & Controls 724 4160V System 731 480V System 732 120V AC Vital Power System 733 Miscellaneous Power/Lighting Panels 734 125V Station DC System 735 480/2081120V Utility (JCP&L) Non-Vital Power 737 hPP-7 Rev. 03l Sheet 22 of 25 lTable 4 -Consolidated Table of Systems Relied Upon to Demonstrate Compliance with 10 CFR 50.48 Diesel Generators (Electrical) 741 Lightning Protection System 752 Normal Lighting (Note 5) 761 Emergency Lighting 762 Radio Communications Systems 787 Fire Protection Water System (Note 8) 811 Fire Protection C02 System 812 Fire Protection Halon System (Note 8) 813 Turbine Building Ventilation System 821 4160V SWGR Room Ventilation Reactor Building Ventilation System 822 480V Switchgear Room HVAC 823 Battery Room HVAC 823 Cable Spreading Room HVAC 823 Control Room HVAC 826 Instrument Air System (Note 4) 852 Nitrogen Supply System 854 Diesel Generator Systems (Mechanical) 861 Diesel Generator Fuel Oil Storage and Transfer System 862 Portable lights (flashlights) (Note 7) 911 Portable smoke removal equipment (Note 7) 911 Portable ventilation equipment (Note 7) 911 Post FSSD Repair Components (Note 7) 911 PP-7 Rev. 03 2 ISheet 23 of 25 Table 5- Structures Required to Demonstrate Compliance with 10 CFR 50.48 ES-17 STRUCTURE STRUCTURE FUNCTION CLB REFERENCE None Fire Protection Water Supply Impoundment for fire protection water UFSAR (Ref. 3)Pond supply. Section 9.5.1.2.3 None Hose Houses Protection for outdoor fire hose stations.

UFSAR (Ref. 3)Section 9.5.1.2.3 None Fire Protection Shed Houses Deluge System #10 for Station JC 19479 Sh. I (Ref.Blackout Transformer 15)None Curbs around stairwells in Provides protection from water damage FHAR (Ref. 1)Reactor Building (southeast Attachment A, Item corner) E.3.a.None Fire wrap Passive fire protection for cables and equipment None Cabinet seals and water Prevent water intrusion from the fire FHAR (Ref. 1)shields suppression system discharge Attachment A, Item E.3.a.None Structural steel fire resistive Protect structural steel from heat related covering effects.None SGTS and Ventilation Tunnel Structure contains FSSD equipment.

FHAR (Ref. 1) Fire Zone SGTS-FZ-31 101 Equipment Supports Provides support for fire protection equipment.

104 Piping and Pipe Supports Provides support for fire protection piping.151 Turbine Building Structure contains fire barriers, fire FHAR (Ref. 1)protection and FSSD equipment.

153 Reactor Building Structure contains fire barriers, fire FHAR (Ref. 1)protection and FSSD equipment.

156 Main Office Building Structure contains fire barriers, fire FHAR (Ref. 1)protection and FSSD equipment.

157 Emergency Diesel Generator Structure contains fire barriers, fire FHAR (Ref. 1)Building protection and FSSD equipment.

158 Heating Boiler House Structure contains fire suppression for safety JC 19479 Sh. 3 (Ref.related equipment.

17), CRL (Ref. 7)168 Intake Structure and Canal Structure contains fire barriers, fire FHAR (Ref. 1)protection and FSSD equipment.

169 Chlorination Facility Structure contains power supply for FSSD Specification Condensate Transfer System pumps. (Ref. 5) section 5.2.3.6.7 171 Condensate Transfer Building Structure contains FSSD equipment.

FHAR (Ref. 1) Fire Area MT-FA-12 176 Fresh Water Pumphouse Structure houses diesel fire pumps, pond UFSAR (Ref. 3)pumps, associated control equipment and Section 9.5.1.2.3 intake structure.

I 4PP-7 Rev. 03 2 ISheet 24 of 25 lTable 5- Structures Required to Demonstrate Compliance with 10 CFR 50.48 ES-17 STRUCTURE STRUCTURE FUNCTION CLB REFERENCE 176 Redundant Fire Prot. Structure houses emergency motor driven UFSAR (Ref. 3)Pumphouse electric fire pump and associated control Section 9.5.1.2.3 equipment.

Called "New Pumphouse" on JC 19479 Sh. I 187 Primary Containment Structure contains fire barriers and FSSD FHAR (Ref. 1)equipment.

814 Fire Barriers, Dikes and Dikes are credited to contain flammable FHAR (Ref. 1)Penetrations fluids. Barriers and penetrations prevent the Attachment A, Item spread of fire. D. .g, D.2.d.Table Notes 1. The FSSD Specification section 5.2.3.3.3 indicates that the Feedwater pumps and Recirculation pumps are required to trip to support safe shutdown of the plant. If the Feedwater pumps cannot be tripped, the Condensate pumps can be tripped. These pumps are not required to perform a safe shutdown function other than to trip. These systems do not have any other safe shutdown function, and so are not considered as systems relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48). These systems are not included in Table 4.2. The only FSSD function of the Main Steam system is to isolate the reactor coolant pressure boundary by closing the main steam isolation valves. Only the reactor coolant pressure boundary piping, isolation valves and associated controls are required to support fire safe shutdown.

The Main Steam system downstream of the outboard MSIVs and downstream of the steam drain isolation valves is not required to support fire safe shutdown.3. The only FSSD function of the Reactor Water Cleanup system is to isolate the reactor coolant pressure boundary by closing the associated containment isolation valves. Only the reactor coolant pressure boundary piping, isolation valves and associated controls are required to support fire safe shutdown.

The Reactor Water Cleanup system downstream of the outboard isolation valves is not required to support fire safe shutdown.4. The Instrument Air system is credited for safe shutdown in two ways. The FSSD Specification section 5.2.3.6.7 indicates that air accumulators are provided to operate valves V-1 1-34 and V-11-36 to provide makeup to the Isolation Condenser.

The accumulators and associated valves and piping are in the instrument air system as shown on drawing BR 3013 sheet 6. The FSSD Specification also credits instrument air in section 7.2. Instrument air is assumed to be available long enough to ensure a one-time closure (< 4 seconds) of the Feedwater regulating valves following reactor trip. These valves are designed 'fail-as-is" and do not require air pressure to keep them closed. This is a reasonable assumption based on the fact that since the instrument air system is pressurized prior to the fire (since the plant is in operation), it is reasonable to assume it will remain pressurized for a brief period following the initiation of the fire and reactor trip. Likewise, it is not credible to assume an age related failure will occur during this brief period, and so it is not necessary to include the instrument air system in the scope of license renewal because of this assumption in the safe shutdown analysis.

The portion of the PP-7 Rev.03 l Sheet 25 of 25 instrument air system associated with the Isolation Condenser makeup valves air accumulators will be included in the scope of license renewal for 1 OCFR50.48.

5. The portion of the Normal Lighting system in scope is limited to the components and cables described in the FSSD Specification section 6.7.6. The following statement should be included in Section 2.1 of the License Renewal Application regarding this fire protection equipment:

Fire extinguishers, self-contained breathing air packs and fire hoses are within the scope of license renewal, but are not subject to aging management because they are replaced on condition.

These components are periodically inspected in accordance with National Fire Protection Association (NFPA) standards.

These standards require replacement of equipment based on their condition or performance during testing and inspection.

These components are not long-lived and are subject to replacement based on NFPA standards, therefore an aging management review is not required.This statement was used for Peach Bottom and is also true for Oyster Creek. The applicable Oyster Creek inspection procedure for the extinguishers is 2400-GMM-3681.04.

The applicable Oyster Creek inspection procedures for the fire hoses are 645.6.003, 645.6.006, and 645.6.008 (references 23, 24 and 25).7. The following statement should be included in Section 2.1 of the License Renewal Application regarding this fire protection equipment:

Equipment that is stored on site for installation or use in response to a design basis event is considered to be within the scope of license renewal. The stored equipment credited for Appendix R repairs are cable, connectors, electrical tape, tie wraps, splice kits, tubing, tube fittings, fasteners, hoses, smoke exhausters, flash lights, flexible ducts, duct adapters, level indicators and power cords. These components are confirmed available and in good operating condition by periodic surveillance inspections.

Tools and supplies used to place the stored equipment in service are not in the scope of license renewal.A similar statement was used for Peach Bottom and is also true for Oyster Creek. The applicable Oyster Creek inspection procedure for the Appendix R repair equipment is 2400-APR-3900.01.

8. Portions of these systems are not required to demonstrate compliance with 1 OCFR50.48 and do not need to be included in the scope of license renewal. See Section 4.2 for specific system branches that are not included in scope. Further reduction of the scope boundaries of fire detection or fire suppression systems, if needed, should be documented on a case-by-case basis in the appropriate system scoping review package.9. The reactor head vent valves are identified as system 221 'Reactor Vessel" in the CRL. For --Formatted:

Bullets and Numberlngl license renewal, the reactor vessel is evaluated without attached piping and valves. The reactor head vent valves are addressed in the Main Steam svrstem. System 221 and Reactor Vessel will remain in this position paper, as it is appropriate and conservative to credit the reactor vessel for FSSD.

Exelon Corporation PP-8 Rev. 2 Sheet I of 24 Structures, Components, and Commodity Types with Active, Passive, Short-Lived Determination, and Intended Functions Oyster Creek Nuclear Generating Station License Renewal Exelon Corporation PP-8 Rev. 24[Sheet 2 of 24 l APPROVAL PAGE Revision Prepared by: Checked by: Approved by: I 00 I A. M. Ouaou A. A. Fulvio D. B. Warfel Date l 01 A. M. Ouaou S. B. Rafferty D. B. Warfel Date 02 A. M. Ouaou K. P. Muggleston D. B. Warfel Date _

Exelon Corporation PP-8 Rev. 2 Sheet 3 of 24 I REVISION

SUMMARY

Rev -Required Changes to Achieve Revision 0 Initial Issue 1 Added new component types and modified component description for NUREG-1801 consistency.

Revised intended functions.

2 Incorporate LRCR #6, #41, #68, #89, and #124, LROI #1443.3 4 5 Exelon Corporation PP-8 Rev. 2 I Sheet 4 of 24 I I TABLE OF CONTENTS Page Approval Page ............................................................

2 Revision Summary .............................................................

3 TABLE OF CONTENTS ............................................................

4 1.0 Purpose ............................................................................

5 2.0 Scope ...... .....................................................................

5 3.0 1OCFR Part 54 Requirements

............................................................................

6 4.0 Methodology

....... ....................................................................

7 5.0 References

....... ....................................................................

9 Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination

.............

10 Exhibit B -Component and Commodity Intended Functions

...........................................................................

19 Exelon Corporation 1.0 Purpose.PP-8 Rev. 2 Sheet 5 of 24 2.0 The license renewal rule (10 CFR Part 54) Section 54.21(a)(1) requires the integrated plant assessment (IPA) to identify and list those structures and components subject to an aging management review. Section 54.21(a)(3) of the license renewal rule requires that, for each structure and component subject to an aging management review, the integrated plant assessment demonstrates that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

The purpose of this position paper is to establish a list of standard structures, components, and commodity types potentially applicable to Oyster Creek and to determine if the structure, component, or commodity type is active, passive, or short-lived (Exhibit A). The paper also provides a standard list of intended functions from which the intended functions of passive long-lived structures, components, and commodities will be selected (Exhibit B).This position paper is for the use of personnel engaged in the preparation, review, or approval of screening evaluations in accordance with Project Level Instruction PLI-3, "Screening of Systems, Structures, and Commodities." Scope The scope of this position paper is to identify standard structures, components, and commodity types applicable or potentially applicable to screening of structures, systems, and commodities at Oyster Creek Nuclear Generating Station (OCNGS), with active, passive, and short-lived determination.

Additionally a list of standard intended functions, applicable to passive long-lived structures, components, and commodities, which will be used during the screening and aging management review processes, is identified.

If a structure, component, or commodity type identified during the screening process is not included in Exhibit A, the project Technical Lead shall be notified.

Similarly, if an intended function is not included in Exhibit B, but required for a component, structure, or commodity based on its application at OCNGS, the project Technical Lead shall be notified.

This position paper will then be revised to include the newly identified structure, component, or commodity type.

Exelon Corporation PP-8 Rev. 2 Sheet 6 of 24 3.0 10CFR Part 54 Requirements.

§54.21 Contents of application

-- technical information Each application must contain the following information: (a) An integrated plant assessment (IPA). The IPA must --(1) For those systems, structures, and components within the scope of this part, as delineated in§54.4, identify and list those structures and components subject to an aging management review.Structures and components subject to an aging management review shall encompass those structures and components

--(i) That perform an intended function, as described in §54.4, without moving parts or without a change in configuration or properties.

These structures and components include, but are not limited to, the reactor vessel, the reactor coolant system pressure boundary, steam generators, the pressurizer, piping, pump casings, valve bodies, the core shroud, component supports, pressure retaining boundaries, heat exchangers, ventilation ducts, the containment, the containment liner, electrical and mechanical penetrations, equipment hatches, seismic Category I structures, electrical cables and connections, cable trays, and electrical cabinets, excluding, but not limited to, pumps (except casing), valves (except body), motors, diesel generators, air compressors, snubbers, the control rod drive, ventilation dampers, pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans, transistors, batteries, breakers, relays, switches, power inverters, circuit boards, battery chargers, and power supplies; and (ii) That is not subject to replacement based on a qualified life or specified time period.(2) Describe and justify the methods used in paragraph (a)(1) of this section.(3) For each structure and component identified in paragraph (a)(1) of this section, demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

Exelon Corporation PP-8 Rev. 2 Sheet 7 of 24 4.0 Methodology 4.1 Structure, Component, and Commodity Types.NEI 95-10, reference (2), Appendix B, "Typical Structure, Component, and Commodity Groupings and Active/Passive Determination for the Integrated Plant Assessment," provides industry guidance for screening of structures and components against criterion of 10CFR54.21(a)(1)(i).

This guidance is used as a basis for identifying structures, components, and commodity types listed in Exhibit A.Some structures, components, and commodity types are not specifically identified in NEI 95-10 (e.g.reactor vessel internals, containment structure components).

These structures, components, and commodities are derived from the UFSAR and previous license renewal applications.

Exhibit A list was compared to OCNGS CRL component types to confirm the list envelopes components contained in the CRL.4.2 Active or passive determination.

Determination of structure, component, and commodity "active" or "passive" is based on the guidance provided in NEI 95-10, Appendix B. Structures, components, and commodities are passive if they perform their intended function without moving parts or a change in configuration or properties.

In general structures and commodities are passive, whereas components may be classified as active or passive, depending on how they perform the intended function.Exhibit A provides a list of components and commodities that are considered passive (P), active (A), or could be either (P/A). Some components designated as "P", such as valves, pumps, and fans, contain subcomponents that are considered active. These subcomponents are not listed in Exhibit A since they are excluded from aging management review and do not require identification in the license renewal application.

Consequently the "P" designation is based solely on those parts that perform the passive intended function.

That is, the pressure boundary is performed by the valve body, pump or fan casing.Components designated as "A" perform only an active intended function.

Active components are excluded from aging management reviews and do not require identification in the license renewal application.

Components designed as "P/A" may perform a passive or an active intended function depending on component design and its application.

For example a pressure sensor is considered passive only if it is a part of the system pressure boundary; otherwise it is considered active. Thus for components designated as "P/A" in Exhibit A, the user must review design documents to establish whether the sensor is passive, "P" or active, "A" 4.3 Short-Lived Determination.

Passive components that are subject to replacement based on a qualified life or specified time period are considered "Short-Lived".

NEI 95-10, Appendix B, and previous license renewal applications were used as basis for "Short-Lived" determinations indicated in Exhibit A. The user must confirm that structures, components, and commodity types designated as "Short-Lived" are subject to replacement based on a qualified life or specified time period and document the confirmation basis in accordance with PLI-3.

Exelon Corporation PP-8 Rev. 2lSheet 8 of 24 l 4.4 Standard Component and Commodity Intended Functions.

Intended functions are those functions that passive structures, components, and commodities are required to perform to ensure success of system and structure level intended functions during the period of extended operation.

The list of standard intended functions provided in Exhibit B is generated based on the review of previous license renewal applications and NEI 95-10.4.5 Consumables Structures, components, and commodities, which are treated as consumables, need to be identified and considered in the screening and aging management review processes.

According to NUREG -1800 (ref 4), consumables may be divided into the following four categories:

a. Packing, gaskets, component seals, and O-rings b. Structural Sealants c. Oil, grease, and component filters d. System filters, fire extinguishers, fire hoses, and air packs Consumables included in group (a) are considered subcomponents and are not explicitly called out in Exhibit A. Rather, they are implicitly included at the component level (e.g., if a valve is identified in scope, a seal in the valve would also be in the scope as a subcomponent of the valve). Furthermore, packing, gaskets, component seals, and O-ring are excluded from aging management review, as they are not considered pressure boundaries in ASME III or USAS B31.1 or USAS B31.7.Consumables included in group (b) are included in Exhibit A as a commodity and evaluated with the structures that contain them.Consumables included in group (c) are considered short-lived and do not require aging management.

Consumables included in group (d) are typically replaced based on performance or condition monitoring that identifies whether these components are at the end of their qualified lives, and can be excluded from aging management review (AMR) under 10CFR54.21(a)(1)(ii).

The user must identify and document, in accordance with PLI-3, the standards (e.g. NFPA, ANSI) and plant specific procedures that are relied upon for replacement of the components.

Otherwise, the components should be screened as passive and subject to AMR.

Exelon Corporation PP-8 Rev. 2 Sheet 9 of 24 5.0 References

1. 10CFR54.4 Requirements for Renewal of Operating Licenses for Nuclear Power Plants 2. NEI 95-10, "Industry Guideline for Implementing The Requirements of 10 CFR Part 54 -The License Renewal Rule," Revision 5 3. Oyster Creek Component Record List (CRL)4. NUREG-1 800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", Draft Rev. 1, January 2005.5. PLI-03, "Screening of Systems, Structures, and Commodities" 6. EP-035, Revision 8, CRL Control 7. EP-01 1, Revision 11, Methodology for Assigning and Maintaining the Quality Classification of Components

8. NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Draft Rev. 1, January 2005.9. BR 2001 Sheet 1, Revision 20, Mechanical Symbols Exelon Corporation PP-8 Rev. 2 1 Sheet 10 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived Access hole cover P Reactor Pressure Vessel and Internals Control Rod Blades S Document basis for short-lived in accordance with PLI-3 Control Rod Drive A Control Rod Drive Assembly P (Housing and guide tubes)Core Shroud P Core Spray lines, Thermal P sleeves, Spray rings (Sparger), and Spray nozzles Core Plate (Lower core grid) P Core Plate (Lower core grid) P wedges Core Spray Line Spray Nozzle P Elbows _Core Spray Ring (Sparger)

P Repair Hardware Diffuser P (UFSAR Fig 3.9-8)Fuel Support Piece P Incore Neutron Monitor Dry P Tubes & Guide Tubes Insulation P Moisture Separator P Nozzles P Nozzles may be listed by name, identified individually, or_grouped by type.Penetrations P Penetrations may be listed by name, identified individually, or grouped by type.RPV Support Skirt and P attachment welds Shroud Support structure P Shroud Repairs (tie rods and P lug/clevis assemblies)

Vessel Steam Dryer P Top Head enclosure (head & P nozzles)Top Head Flange P Top Head Closure Studs and Nuts P^

.Exelon Corporation PP-8 Rev. 2 Sheet 11 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived Top Head Enclosure Vessel P Flange Leak Detection Top Guide (Upper core grid) P Reactor Vessel Bottom Head P Pressure Vessel Shell Attachment Welds P Internals Vessel Shell Flange P Vessel Shell (upper, upper P intermediate, lower intermediate)

Agitator A Accumulator P Air Compressor A Bird Screen P Closure bolting P Condensing chamber P Cooler P Mechanical System Cranes Components Rail system (Rail plates, clips) P Refueling platform P Hoists (Jib Crane columns, P beams, anchorage)

Hoists (Monorail beams; P Lifting Devices, Plates)Crane (Bridge; Trolley; P girders)Cyclone Separator P Dash pot P Diffuser P Demineralizer P Drain Trap P

.Exelon Corporation PP-8 Rev. 2 Sheet 12 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived

_ =asv ________________

Drip leg P Mechanical Systems Components Eductor P Emergency Diesel Generator A Engines A Enclosure boot P Exhaust Hood P Exhaust silencer P Expansion Joint P Evaporator P Filter P/S See consumables Fire Barriers Fire barrier penetration seals P Fire barrier walls and slabs P Filter housing P Fire door P Fire rated enclosures P Fire Extinguisher S See consumables Fire hydrant P Flame arrestor P Flexible connection P Flexible Hose P Flow element P Flow glass P Flow indicator P Flow meter P Fuel Storage Cask drop protection P cylindrical structure Fuel Pool Gates P Fuel pool liner plate P Fuel Pool Skimmer Surge P tank liner Fuel Grapple/Mast P Fuel Preparation Machine P New Fuel Storage Racks P Spent Fuel Storage Racks IP Exelon Corporation PP-8 Rev. 2 1 Sheet 13 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived Fluid Drive -Reservoir P Mechanical Systems Components Gas Bottles P/S Short-lived if replaced based on a qualified life or specified time period.Gauge Snubber P Gear Box P Gland Seal Blower A Heat Exchanger P Heater housing P Hose manifold P Hose Stations and hose reels P Instrument tubing and fittings P Insulation P Insulation Jacketing P Level Glass P Main condenser Shell P Main condenser Tubes P Main condenser Tubesheet P Mixer A Muffler P Odorizer P Oil mist eliminator P Piping and fittings P Pressure building coils P Pressure vessel P Pump Casing P Restricting Orifice P Rotameter P Rupture Disk P Sample chamber P Screen P Sensor Element P/A (P for a pressure boundary, if_ applicable)

Sight Glass P Soot blower UP I

.Exelon Corporation PP-8 Rev. 2 1 Sheet 14 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive_ S=Short-Lived Snubber A Mechanical Systems Components Sparger (Y-Quencher)

P Spray Nozzle P Sprinkler Head P Steam Trap P Strainer P Strainer Body P Tanks P Tank heater P Temperature control manifold P Thermowell P Turbine Casing P Vacuum Breaker P Vacuum Pump Casing P Valve Body P Valve Operator A Ventilation Damper housing P Demister P Ductwork P P Fan Housing Filter Housing P Flexible Connection P HVAC plenum P Louver P Water motor alarm P Seals & Gaskets P/S Short-lived if replaced based on a qualified life or specified time period.a a a Access Hatch Covers UP Exelon Corporation PP-8 Rev. 2 Sheet 15 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived Class MC Pressure Retaining Boltino P Downcomers P Drywell head flange P Drywell head P Drywell head gasket S Drywell Penetration Bellows P Drywell Penetration sleeves P Drywell shell P Drywell support skirt P Electrical penetrations P Locks, hinges, and closure P mechanisms Personnel Airlock/Equipment P Hatch Penetration closure plate and P caps Seals, Gaskets, and O-rings P See note 1.Suppression Chamber P Penetrations Suppression Chamber ring P girders Suppression Chamber shell P Thermowell P Vent header deflector P Vent Jet Deflectors P Vent line bellows P Vent line, and vent header P P Anchorage Concrete Elements Biological shield wall P Structural Components and Commodities Building concrete at locations of expansion and grouted anchors; grouted pads for support base plates P Exelon Corporation PP-8 Rev. 2 Sheet 16 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments I P=Passive S=Short-Lived Curb P Structural Components and Commodities Drywell shield wall P Equipment and Component P Foundations

_Exhaust stack P Hatch plug P Masonry block wall P Reactor pedestal P Reinforced concrete P foundation Reinforced concrete Slab P Reinforced concrete trench P Reinforced concrete Wall P Reinforced Concrete Column P Removable block P Tank Foundations P Trench, manhole, ductbank P Tunnels P Unreinforced concrete P Doors Door P Door gasket P Steel Elements Access hatch P Beam Seat P Biological Shield Wall -P Concrete l Biological shield wall -lateral P support Biological shield wall P structural steel Biological Shield wall liner P plate Bird Screen P Blowout panel P There are no blowout panels at OC. Siding is credited for blowout panel function Cable Tray P 1-

.Exelon Corporation PP-8 Rev. 2 Sheet 17 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive_ S=Short-Lived Concrete embedment P Conduit P Curb P Door P Emergency Diesel Generator P Enclosure Hatch cover P Instrument Rack P Liner (Sump) P Lubrite Plate P Metal Deck P Metal Siding P Miscellaneous steel P (catwalks, handrails, ladders, manhole cover, platforms, grating, and associated supports)Missile Barrier P Panels and enclosures P Penetration sleeve, cap P plates, capped auxiliary boiler exhaust pipe Pipe whip restraints P Plate P Refueling bellows P Removable panel P Scuppers P Shielding block and plates P Spray Shield PD Srcua BlsP Structural Bolts IP Exelon Corporation PP-8 Rev. 2 I Sheet 18 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive_S=Short-Lived Structural steel: Beams, Columns, Girders, Radial beams, posts, bracing, plate, connections, etc..)P Trash racks P Tube Tray P Component Supports Supports for ASME XI Class 1 P Piping and Components (support members, welds, bolted connections, support anchorage to building structure)

Supports for ASME Class 1 P piping and components (constant and variable load spring hangers, guides, stops, sliding surfaces, design clearances)

Supports for ASME XI Class 2 P and 3 Piping and Components (support members, welds, bolted connections, support anchorage to building structure)

Supports for ASME Class 2 and P 3 Piping and Components (constant and variable load spring hangers, guides, stops, sliding surfaces, design clearances)

Supports for ASME Class MC P Components (support members, welds, bolted connections, support anchorage to building structure)

I Supports for ASME XI Class MC Components (guides, stops, sliding surfaces, design clearances)

P Exelon Corporation PP-8 Rev. 2 I Sheet 19 of 24 I g Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive_ S=Short-Lived Supports for Cable Trays (support members, welds, bolted connections, support anchorage to building structure)

P Structures and Component Supports Supports for conduits (support P members, welds, bolted connections, support anchorage to building structure)

Supports for instrument lines P Supports for Non-ASME Xl P Piping and Components (support members, welds, bolted connections, support anchorage to building structure)

Supports for HVAC ducts P (support members, welds, bolted connections, support anchorage to building structure)

Supports for HVAC P components and other miscellaneous mechanical equipment Supports for HVAC P Components (vibration isolation elements)Supports for platforms, pipe P whip restraints, jet impingement, and spray shields and other miscellaneous structures (support members, welds, bolted connections, support anchorage to building structure)

Supports for panels and enclosures, racks (support members, welds, bolted P connections, support anchorage to building structure)

_Supports for masonry walls (support members, welds, bolted connections, support anchorage to buildina structure)

P Exelon Corporation PP-8 Rev. 2 1 Sheet 20 of 24 I I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived Supports for tube track, and instrument tubing (support members, welds, bolted connections, support anchorage to building structure)

P Penetration Seal P Sealants Silicone foam P Caulk P Seal (Gap) P Roofing P Water control Embankment P Earthen water control P structures Fire Pond Dam P Canals P Transmission towers P Alarm Unit A Analyzers A Annunciator A Batteries A Cables P Cable Connections (metallic P parts)Chargers A Circuit Breakers A Connectors P Controller Indicator A Converters A Electric heaters P/A (P for a pressure boundary, if.___ .__ applicable)

Electrical Bus duct P A Exelon Corporation PP-8 Rev. 2 Sheet 21 of 24 I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive_ S=Short-Lived r-JUcAncal anU I&C Components Electrical and I&C Components l l s I 8 rs ..ffi rs lElectrical buses V-Electrical penetrations P Flow elements P/A P for a pressure boundary, if applicable Fuse A Fuse Holders P Generators A Heat Tracing A High Voltage Insulators P Indicators A Inverters A Insulated cables and P connections Insulated cables and P connections in instrumentation circuits Insulated inaccessible medium- P voltage cables Isolators A Lighting A Load Centers A Loop Controllers A Meters A Motor Control Centers A Motors A Power Supplies A Radiation Monitors A Recorders A Regulators (e.g., voltage reg.) A Relays A RTDs P/A P for a pressure boundary, if applicable Signal Conditioners A Solenoid Operators A Solid State Device A Starters A Surge Arresters A Switches A Switchgear A

Exelon Corporation PP-8 Rev. 2 Sheet 22 of 24 I I Exhibit A -Structure, Component or Commodity Type with Active, Passive, Short-Lived Determination Category Component Type A=Active Comments P=Passive S=Short-Lived Terminal Blocks P Thermocouples P/A P for a pressure boundary, if applicable Transducers P/A P for a pressure boundary, if applicable Transformers A Transmission conductors and P connections Transmitters A Turbine Controls A Wooden Utility Poles P Notes: 1. Seals and gaskets for primary containment hatches and airlocks are considered part of the primary containment pressure boundary.

The components are included in scope of ASME Section XI, Subsection IWE examinations and are not typically replaced based on a qualified life or specified time period.

Exelon Corporation PP-8 Rev. 2 Sheet 23 of 24 I 3 Exhibit B -Component Intended Functions Passive Intended Definition Function Absorb Neutrons Provide neutron absorption in spent fuel pool to prevent criticality Containment, Holdup Provide post accident containment, plateout of iodine and hold-and Plateout up (for radioactive decay) of iodine and non-condensable gases and Plteoutbefore release.Direct Flow Provide spray shield or curbs for directing flow Electrical Continuity Provide electrical connections to specified sections of an electrical circuit to deliver voltage, current, or signals Enclosure Protection Provide enclosure, shelter, or protection for in-scope equipment____ ____ ___ ____ ___ (including shielding)

Filter Provide filtration Fire BarrierProvide rated fire barrier to confine or retard fire from spreading Fre rerto or from adjacent areas of the plant Flood Barrier Provide flood protection barrier (internal and external flood event)Gaseous Release Path Provide path for release of filtered and unfiltered gaseous Gaseos ReeasePathdischarge Heat Transfer Provide heat transfer HELB Shielding Provide HELB shielding Insulation

-Electrical Insulate and support an electric conductor Insulation Jacket Prevent moisture absorption and provide physical support of Integrity thermal insulation Mechanical Closure Mechanical closure (e.g., bolting)Missile Barrier Provide missile barrier (internal or external missiles)Non-safety related component that maintains mechanical and Leakage Boundary structural integrity to prevent spatial interactions that could cause failure of safety related SSCs. This function includes the required structural support when the non-safety related leakage boundary piping is also attached to safety related piping.Pipe Whip Restraint Provide pipe whip restraint

--3 Exelon Corporation

[PI-8 Rev. 2 Sheet 24 of 24-I Exhibit B -Component Intended Functions Passive Intended Definition Function Provide pressure-retaining boundary so that sufficient flow at adequate pressure is delivered, or provide fission product barrier Pressure Boundary for containment pressure boundary, or provide containment isolation for fission product retention, or provide the containment, holdup and plateout function (for Main Steam system)Pressure Relief Provide a vent path for HELB pressure Shielding Provide shielding against radiation Spray Convert fluid into spray Provide structural support for structures and components within the scope for 54.4(a)(1), 54.4(a)(2), or 54.4(a)(3), or provide Structural Support structural integrity to preclude non-safety related component interactions that could prevent satisfactory accomplishment of a safety related function.Thermal Insulation Control of heat loss to preclude overheating of nearby safety related SSCs, 1 0 CFR 54.4 (a)(2)Throttle Provide flow restriction Vibration Isolation Provide flexible support for HVAC fan units.Water retaining Provide an essentially water leak tight boundary.b o u n d a ry _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Exelon Corporation PP-13 Rev. 2 1Sheet 1 of 101.I Position Paper 13 Abnormal Operational Transients Oyster Creek Nuclear Generating Station License Renewal Exelon Corporation PP-13 Rev. 2 1Sheet 2 of 101 I Approval Page Prepared by: Date: S. C. Getz 08/11/2005 Checked by: Date: M. J. May 08/11/2005 Approved by: Date: A. A. Fulvio 08/16/2005 PP-13 Rev. 2 Sheet 3 of 101 REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)1 Added section 4.0.9 Toxic Gas Protection; Toxic Gas Protection for control room HVAC to Table 1 systems 823, 826; combined MHC Front Standard system 314 with Main Turbine and Auxiliary System 301 in Table 2; clarified remarks in Table 1 system 424 and Table 2 system 155; deleted duplicate reference 2 Updated revision dates for NEI 95-10 (to Rev. 5 from Rev. 4) and NUREG -1800 (Rev. 1 Draft January 2005)3 4 5 PP-13 Rev. 2 Sheet 4 of 101 TABLE OF CONTENTS Page Approval Page ....................

2 Revision Summary ....................

3 Table of Contents ...................

4 1.0 Purpose ........................

5 2.0 Scope ........................

5 3.0 AOT Requirements

........................

6 4.0 Methodology

........................

7 5.0 References

........................

10 6.0 Attachments (Table 1, Table 2) ........................

10

[PP-13 Rev. 2 Sheet 5 of 101 1.0 Purpose License Renewal Rule 10 CFR Part 54.4(a)(1) requires that safety-related plant systems, structures, and components relied upon to remain functional during and following design-basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1), § 50.67(b)(2), or § 100.11, as applicable, be included in the scope of license renewal. (10CFR54.4(a)(1))

The purpose of this position paper is: (1) To confirm that design basis internal and external events including abnormal operational transients (AOT's), anticipated operational occurrences, and natural phenomena as described in the current licensing basis (CLB) are to be considered when conducting scoping for license renewal; and (2) To identify the Oyster Creek Nuclear Generating Station systems and structures relied upon to remain functional to ensure § 54.4(a)(1) functions during and following such events. Design basis accident events (DBAs) are not included in this review as systems and structures credited with mitigating their effects are considered to be safety related and are already included in license renewal scope. The identified systems and structures are listed in Table 1. Items in Table 1 may be safety-related or nonsafety-related.

Table 2 includes nonsafety-related systems and structures that, while not credited with performing a § 54.4(a)(1) function, are credited with operating during and following the event, and is included to provide information for use during system and structure scoping. Systems and structures not credited with mitigating effects of the subject events are not included in these tables. This position paper will be used in conjunction with Project Level Instruction PLI-2, "Scoping of Systems and Structures." This position paper is for the use of personnel engaged in the preparation, review, or approval of scopirfg evaluations in support of license renewal activities for Oyster Creek. This paper documents the technical basis for the license renewal scoping conclusions, along with the methodology and CLB source documents used. The resulting Table 1 identifies which of the systems and structures identified in Oyster Creek Engineering Standard ES-017 are credited with ensuring § 54.4(a)(1) functions during design basis events (those that are not considered design basis accidents) as described in the CLB, e.g., abnormal operational transients, anticipated operational occurrences, external events, and natural phenomena.

The results will be used to populate the corresponding license renewal database field. Systems and structures listed in Table 1 will result in a "Yes" answer to scoping criteria 54.4(a)(1).

Table 2 results will not result in a "Yes" to scoping criteria 54.4(a)(1) but will provide information on system functions, including possible system supporting functions, for use during the scoping process.2.0 Scope The scope of this document is those systems and structures that are required for the Oyster Creek Nuclear Generating Station to comply with the requirements of 10 CFR54.4 for non-design basis accident (non-DBA) design basis events, e.g., abnormal operational transients, anticipated operational occurrences, external events, and natural phenomena as described in the CLB.Components at Oyster Creek Nuclear Generating Station can be associated with a system or structure through design drawings or the Component Record List (Ref. 2). License renewal scoping is performed at the system and structure level. The scope of this review is therefore limited to the PP-13 Rev. 2 Sheet 6 of 101 identification of systems and structures.

The identification of individual components is not within the scope of this position paper.3.0 AOT Requirements Regulatory requirements for inclusion in scope of plant systems, structures, and components for license renewal are stated in 1 OCFR54.4 as follows: Part 54 Reference (a) Plant systems, structures, and components within the scope of this part are --(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined as in 10 CFR 50.49 (b)(1)) to ensure the following functions

--(i) The integrity of the reactor coolant pressure boundary;(ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1), §50.67(b)(2), or § 100.11 of this chapter, as applicable.

(2) All nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii)of this section.(3) All systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).10 CFR 50.49 (b)(1) defines design-basis events (DBEs) in (ii) below: Part 50 Reference§50.49 Environmental qualification of electric equipment important to safety for nuclear power plants.(a) Each holder of or an applicant for a license for a nuclear power plant, other than a nuclear power plant for which the certifications required under §50.82(a)(1) have been submitted, shall establish a program for qualifying the electric equipment defined in paragraph (b) of this section.(b) Electric equipment important to safety covered by this section is: (1) Safety-related electric equipment. (continued)

PP-13 Rev. 2 Sheet 7 of 1 01 Part 50 Reference (continued)(i) This equipment is that relied upon to remain functional during and following design basis events to ensure --(A) The integrity of the reactor coolant pressure boundary;(B) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (C) The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines in §50.34(a)(1), §50.67(b)(2), or§100. 11 of this chapter, as applicable.(ii) Design basis events are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure functions (b)(1)(i) (A) through (C) of this section.The conclusion is that Abnormal Operational Transients and other design-basis events as defined in 10 CFR 50.49(b)(1) are specifically required to be considered in conducting scoping for license renewal.4.0 Methodology Systems, structures, and components relied on to mitigate the consequences of design basis accidents are clearly within the scope of license renewal and are addressed by inclusion of safety-related systems, structures, and components per 10 CFR 54.4(a)(1) along with those non safety-related support systems specifically required to demonstrate compliance with the applicable NRC regulation per 10 CFR 54.4(a)(2).

However, there exists a wider range of design basis events that are not considered to be design basis accidents

-these events are defined in Chapter 15 of the Oyster Creek UFSAR as Abnormal Operational Transients, but also may be found in other sections of the UFSAR as well as other CLB documents.

In regard to identification of these design basis events, Section 2.1.3, "Review Procedures," of NUREG-1 800 states: NUREG 1800 Reference The set of design basis events as defined in the rule is not limited to Chapter 15 (or equivalent) of the UFSAR. Examples of design basis events that may not be described in this chapter include external events, such as floods, storms, earthquakes, tornadoes, or hurricanes, and internal events, such as a high-energy-line break. Information regarding design basis events as defined in 10CFR50.49(b)(1) may be found in any chapter of the facility UFSAR, the Commission's regulations, NRC orders, exemptions, or license conditions within the CLB.These sources should also be reviewed to identify systems, structures, and components that are relied on to remain functional during and following design basis events (as defined in 10 CFR 50.49(b)(1))

to ensure the functions described in 10 CFR 54.4(a)(1).

To ensure the intent of 10 CFR 54.4(a)(1) was met, a review for systems and structures credited during non-DBA design basis events as described in NUREG-1 800 was performed, using CLB documentation sources including the Oyster Creek UFSAR and Facility Description and Safety PP-13 Rev. 2 Sheet 8 of 101 Analysis Report (FDSAR), the Oyster Creek IPE Submittal Report in response to Generic Letter 88-20, "Individual Plant Examinations for Severe Accident Vulnerabilities

-1 OCFR50.54(f)," the Oyster Creek Individual Plant Examination for External Events ("IPEEE" document in response to Generic Letter 88-20 Supplement 4), and Oyster Creek station procedures.

Table 1 is a list of those systems and structures that are relied upon to remain functional during and following non-DBA design basis events to ensure a § 54.4(a)(1) function.

Table 2 lists nonsafety-related systems and structures that, while not credited with performing a § 54.4(a)(1) function, are credited with operating during and following the event, and are included to provide information for use during system and structure scoping. The systems in Table 2 may provide a supporting function under 1 OCFR54.4(a)(2).

System and structure identification in these tables is based on the names in Oyster Creek Engineering Standard ES-017 (reference 3).The transients specifically identified in Chapter 15 of the OC UFSAR (Reference

1) were reviewed to identify systems and structures credited for mitigation of the effects of those events. Searches in the UFSAR in entirety and other electronically stored CLB documents were also conducted using the other various internal and external event names, e.g., "flood", "tornado", "missiles", etc. to identify systems and structures whose function is credited for their mitigation.

Manual searches of non-electronic documents were also made to identify systems and structures credited with functioning to mitigate effects of design basis events. DBAs were not considered as these events are mitigated by safety related systems (and non-SR support systems) that are already included in license renewal scope. Events described by 1 OCFR54.4(a)(3) were not considered as these event categories are considered individually for license renewal. Beyond-design basis severe accidents were not considered as these events are not in-scope for license renewal. The systems and structures that were identified to operate to ensure a § 54.4(a)(1) function are recorded in Table 1 with the name of the design basis event for which their function is credited, the document where the reference is located, and their safety classification per PP-02. Nonsafety-related systems and structures that are not credited with performing a § 54.4(a)(1) function, yet are credited with operating during and following the event, are included in Table 2. Systems and structures referenced in the source documents as relied upon to remain functional for a design basis event are included in these tables -during scoping of the individual systems, the evaluator may determine whether the system provides a required function per the license renewal definition.

This document (PP-1 3) may be revised to reflect the results of those scoping determinations.

The categories of non-design basis accident DBEs and the method by which systems and structures credited for their mitigation were identified for inclusion in Table 1 and Table 2 are listed below: 4.0.1 Abnormal Operational Transients Abnormal operational transients (AOTs) are defined in the OC UFSAR as the result of various system malfunctions or operator errors that can be reasonably expected during plant operations.

These defined AOTs are specifically listed in Chapter 15 of the UFSAR, which was reviewed to determine the AOT categories and identify which systems were credited for mitigating the consequences of those transients.

lPP-13 Rev. 2lSheet 9 of 101 4.0.2 High Winds/Tornado High wind and tornado conditions including tornado-generated missiles are postulated external events which have been analyzed in various documents.

OC procedure ABN-31, "High Winds" (Reference

9) lists systems, including various tanks, which may be used to prepare for mitigating the effects of forecast high wind or tornado events. The IPEEE report (Reference

4) Section 5.1 and OC UFSAR sections 3.3 and 3.8.4 also list systems and structures required for response to high wind or tornado events.4.0.3 Missiles Section 3.5 of the OC UFSAR identifies the sources and types of postulated missiles internal and external to the plant, including those internally generated (both inside and outside the drywell), turbine-sourced low- and high-trajectory missiles, and externally generated missiles.

Systems and structures reviewed for missile interaction are included in UFSAR Section 3.5 and the IPEEE report (Reference

4) Section 5.1.4.0.4 Flooding Flood design considerations including those externally-sourced from intense precipitation, stream and river swelling, hurricanes, storm tides, etc., and internally sourced from piping or tank failure, etc. are discussed in OC UFSAR sections 2.4, 3.8, and 9.3, the IPEEE report (Reference

4) section 5.2, and Technical Data Report (TDR) 779 (Reference 6).4.0.5 Abnormal Intake Level Abnormally high or low intake levels and the systems credited for mitigating actions are discussed in Oyster Creek station procedure ABN-32 (Reference 7).4.0.6 High Energy Line Break (HELB)The effects of HELBs and those systems relied on to mitigate their effects are discussed in OC UFSAR section 3.6 and in the OC FDSAR (Reference

13) Amendment 75a.4.0.7 Station Seismic Events Systems and structures designed to withstand a postulated station seismic event, as well as systems procedurally required for post-seismic function, are listed in OC UFSAR sections 3.2 and 3.7, and Oyster Creek station Procedure ABN-38 (Reference 8).4.0.8 Reactor Building Crane In response to NUREG 0612 and NRC Bulletin 96-02, Oyster Creek committed to upgrade the reactor building crane to single-failure proof status. While not specifically a transient, the commitment to upgrade the crane, failure of which could prevent the satisfactory accomplishment of a safety-related function, is considered in the scope of license renewal. Reference NEI 95-10 (Reference

10) Appendix F section 3.2, and OC TDR 3002 (Reference 5).

4.0.9 Toxic Gas Protection The Control Room HVAC System has been designed to maintain a suitable environment for equipment and personnel during normal and emergency plant conditions.

The OC UFSAR section 6.4 describes the control room habitability envelope and performance requirements.

5.0 References

1. Oyster Creek Nuclear Generating Station, Updated Final Safety Analysis Report, Revision 13 2. Oyster Creek Component Record List (CRL)3. Engineering Standard ES-017, "Identification of Oyster Creek Plant Systems", Revision 22 4. GPU Nuclear Corporation response to Generic Letter 88-20 Supplement 4 "Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities 10 CFR 50.54(f)" 5. Technical Data Report TDR 3002, Single Failure Proof Crane Upgrade 6. Technical Data Report TDR 779, Evaluation of Possible Internal Flooding of OC Nuclear Generating Station Power Plant Bldgs.7. Oyster Creek Generating Station Procedure ABN-32 Rev. 0, Abnormal Intake Level 8. Oyster Creek Generating Station Procedure ABN-38 Rev. 0, Station Seismic Event 9. Oyster Creek Generating Station Procedure ABN-31 Rev. 0, High Winds 10. Nuclear Energy Institute (NEI), NEI 95-10, Industry Guideline on Implementing the Requirements of 10 CFR Part 54, Revision 5 11. 10 CFR Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants 12. NUREG-1 800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 1 Draft dated January 2005 13. Oyster Creek Facility Description and Safety Analysis Report (FDSAR)6.0 Attachments Table 1 -- "Systems and Structures Relied Upon to Function to Ensure Section 54.4(a)(1)

Functions During and Following Non-DBA DBEs" Table 2 -"Systems and Structures Credited with Operating (Not for Performance of Section 54.4(a)(1)

Function)

During and Following Non-DBA DBEs" Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 1 of 37 Standard Materials, Environments, and Aging Effects Oyster Creek License Renewal Project Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 2 of 37 APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 A. M. Ouaou A. A. Fulvio Date 01 A. M. Ouaou K. P. Muggleston D. B. Warfel Date .02 Ahmed M. Ouaou M. A. Miller D. B. Warfel Date 03 A. M. Ouaou K. P. Muggleston D. B. Warfel Date Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 3 of 37 REVISION

SUMMARY

Rev. Required Changes to Achieve Revision No.0 Initial Issue 1 Revised to add ground water, fresh water, and salt water chemistry test results.Added certain environments, and aging effects for NUREG-1 801 consistency.

Added reference to NEI 95-10 Rev. 5, and NUREG-1 801 draft rev. 1 January 2005 2 Incorporate LRCR #7, #41, #68, #89, #116, #136 3 Incorporate LRCR #148, #150, changed LRCR #136 in Rev. 2 to #137 Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects 1.0 Purpose PP-15 Rev. 3 Sheet 4 of 37 2.0 S 10 CFR 54.21 (a)(3) requires a demonstration that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the current licensing basis throughout the period of extended operation.

Aging effects are a function of a material and its normal operating environment.

This position paper provides a list of standard materials, environments, and potential aging effects from which Oyster Creek Nuclear Generating Station (OCNGS) plant specific materials, environments, and the applicable aging effect (s) can be selected.

The equivalent NUREG-1 801 (Ref. 6) materials and environments are listed in the tables to establish a correlation between OCNGS and NUREG-1801 materials and environments.

This position paper is for the use of personnel engaged in systems, structures and commodities screening process defined in PLI-3 (Ref. 1)Scope The scope of this position paper is to identify standard materials, environments, and aging effects applicable or potentially applicable to OCNGS structures, components, and commodities.

Environments that have been determined applicable to OCNGS are described in Section 4.2.This position paper does not describe specific methods or instructions for identifying plant specific materials and aging effects. The user is required to review plant documents to establish material of construction for structures, components, and commodities subject to aging management review. Similarly, the user is required to identify aging effects applicable to OCNGS material-environment combination using previous Exelon aging management reports (Ref. 20), Industry reports (Ref. 13,14), NUREG-1801 (Ref. 6), and plant specific operating experience.

For additional details, refer to PLI-3 (Ref. 1)If a material, environment, or aging effect identified during the screening or aging management review processes is not included in Tables 1-6, the project Technical Lead shall be notified.

This position paper will then be revised to include the newly identified material, environment, or aging effect.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects 3.0 10CFR Part 54 Requirements.

§54.21 Contents of application

-technical information Each application must contain the following information: (a) An integrated plant assessment (IPA). The IPA must --PP-15 Rev. 3 Sheet 5 of 37 (1) For those systems, structures, and components within the scope of this part, as delineated in§54.4, identify and list those structures and components subject to an aging management review. Structures and components subject to an aging management review shall encompass those structures and components

--(i) That perform an intended function, as described in §54.4, without moving parts or without a change in configuration or properties.

These structures and components include, but are not limited to, the reactor vessel, the reactor coolant system pressure b (ii) oundary, steam generators, the pressurizer, piping, pump casings, valve bodies, the core shroud, component supports, pressure retaining boundaries, heat exchangers, ventilation ducts, the containment, the containment liner, electrical and mechanical penetrations, equipment hatches, seismic Category I structures, electrical cables and connections, cable trays, and electrical cabinets, excluding, but not limited to, pumps (except casing), valves (except body), motors, diesel generators, air compressors, snubbers, the control rod drive, ventilation dampers, pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans, transistors, batteries, breakers, relays, switches, power inverters, circuit boards, battery chargers, and power supplies; and (ii) That is not subject to replacement based on a qualified life or specified time period.(2) Describe andjustify the methods used in paragraph (a)(1) of this section.(3) For each structure and component identified in paragraph (a)(1) of this section, demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects 4.0 Methodology PP-15 Rev. 3 Sheet 6 of 37 4.1 Materials Standard materials listed in Table-1 were extracted from OCNGS material specifications, Line List Specification (Ref. 9), design and vendor drawings, UFSAR (Ref. 8), and previous license renewal applications (Ref. 21-26). The equivalent NUREG-1 801 (Ref. 6) materials are listed in the table to establish a correlation between OCNGS materials used in the application and NUREG-1 801 materials.

4.2 Environments The environments are based on the review of OCNGS UFSAR (Ref. 8), chemistry control procedures (Ref. 17-19), and previous Exelon and other license renewal applications (Ref.21-26). Grouping of the environments considers proposed industry changes to NUREG-1801 (Ref. 7). Tables 1 and 2 provide a summary of the environments described below and their equivalent NUREG-1 801 environment.

4.2.1 Internal Environments 4.2.1.1 Auxiliary Steam Steam produced in oil fired auxiliary boilers from Boiler Treated Water. Auxiliary steam is used for space heating and for operating a radwaste concentrator for the evaporative processing of liquid radioactive waste (Ref. 8 Section 10.4.8).4.1.2.2 Boiler Treated Water Demineralized water subject to chemistry controls specified in the plant Auxiliary Boiler Chemistry procedure.

4.2.1.3 Closed Cooling Water The chemical makeup of the closed cooling water is maintained in accordance with EPRI TR-1 07396 "Closed Cooling Water Chemistry Guidelines".

Purity and chemical content is maintained by periodic sampling and batch chemical addition in accordance with Exelon procedure (Ref. 19). Reactor Building Closed Cooling Water (RBCCW), Turbine Building Closed Cooling Water (TBCCW), Emergency Diesel Generator (EDGCCW), NRW Closed Cooling Water, and AOG Closed Cooling Water chemistry controls are included in this procedure.

4.2.1.4 Closed Cooling Water < 140 0 F Closed Cooling Water at an operating temperature that is below the threshold limit for Stress corrosion Cracking (SCC) in austenitic stainless steel components.

4.2.1.5 Condensation Air and moisture on internal surfaces of design features, such as drain traps, provided to collect potential moisture in gas or air systems.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 7 of 37 4.2.1.6 Containment Atmosphere The drywell is made inert with nitrogen to render the primary containment atmosphere non-flammable by maintaining the oxygen content below 4% by volume during normal operation.

The normal operating temperature within the drywell varies with elevation.

Elevations up to elev. 55' are subject an average bulk temperature of 139 0 F or less.Above this elevation, the temperature varies from 168 0 F, just above elev. 55', to 256 0 F above elev. 95'. Humidity within the drywell varies from 20-40% (Ref. 12).4.2.1.7 Diesel Engine Exhaust This environment applies to components exposed to hot diesel engine exhaust gases, which contain moisture, particulates, and potentially sulfur residues.

The presence of particulates can led to loss of material due to erosion; while sulfur residue in presence of moisture may let to sulfuric acid formation in the exhaust system.4.2.1.8 Dry Gas The dry gas environment is industrial gas containing little or no moisture such as nitrogen, carbon dioxide, hydrogen, oxygen, helium, and halon. These gases and dried air are considered inert with respect to corrosion potential because they have no significant moisture content (Ref. 20)4.1.2.9 Fuel Oil Fuel oil is used as a fuel in internal combustion diesel engines and auxiliary heating boiler. Fuel oil does not cause or promote aging of the internal and external surfaces of the materials.

However, water and other contaminants may become entrained in the fuel oil and cause or promote components aging (Ref. 20).4.1.2.10 Indoor Air Indoor environment consists of indoor ambient conditions where components are protected from outdoor moisture.

Conditions outside the drywell consist of normal room air temperatures ranging from 65 0 F -140OF and the relative humidity is 100% maximum.The warmest room outside the drywell is the Trunion room, with an average temperature of 140OF (Ref. 12)4.1.2.11 Lubricating Oil Lubricating oil is an organic fluid used to reduce friction between moving parts. This environment is applicable to rotating equipment, such as pumps, compressors, or the diesel engines. Lubricating oil does no cause or promote aging of the internal surfaces of the materials.

However, moisture and other contaminants may become entrained in the oil and cause or promote component aging (Ref. 20).4.1.2.12 Outdoor Air Outdoor environmental conditions consist of air temperatures typically ranging from 23.7 0 F -84 0 F and an average annual precipitation of approximately 42 inches (Ref. 8, Section 2.3)

Oyster Creek License Renewal Project PP-15 Rev. 3 Standard Materials, Environments, and Aging Effects Sheet 8 of 37 4.1.2.13 Raw Water -Raw water consists of fresh water or salt water.4.1.2.13.1 Fresh Water Fresh raw water is drawn from either a deep well or from a pond formed by a small dam on the Oyster Creek, known as the Fire Pond Dam.Water taken from the deep well is processed in the pretreatment facility.

After treatment, part of the water goes to the domestic water system and the rest is further treated in the Makeup Demineralized Water System to be used as demineralized water and for makeup to the Condensate Storage and Transfer System. Typical deep well water chemistry parameters identified during original construction, including pH (6.35), Chlorides (19 ppm), sulfates (7.5 ppm), are given in UFSAR (Ref. 8, Table 2.4-3).Recent testing of groundwater taken from 2 wells show a pH range of (5.6 -6.4), chloride range of (3-138 ppm), and a sulfate range of (7 -73 ppm).Fresh water drawn from the Fire Pond Dam is untreated and is used for fire suppression and to the circulating water, service water pumps, and dilution pump oil coolers. Recent chemistry results show that (pH = 4.8, chlorides

= 12 ppm, sulfates = 6 ppm).4.1.2.13.2 Salt water Raw salt water is drawn from Barnegat Bay, which receives salt water from the Atlantic Ocean and fresh water runoff from streams, which border it on the western shore, including Oyster Creek and Forked River. Salinity of the water varies from 12 parts per thousand (ppt) in the upper reaches to 32 ppt at Barnegat inlet and lower sections of the Bay. Recent tests of salt water at the intake structure showed that (pH = 7.9, Chlorides= 14659, Sulfates = 1419). The average monthly water temperatures range from 37 OF in winter to 80 0 F in summer. The salt water is conveyed through the intake canal into the intake structure and subsequently used as a source of water for Service Water System, Emergency Service Water System, and Circulating Water System. Sodium hypochlorite is injected at various points in the systems to eliminate or reduce Biofouling.(Ref. 8, Sections 2.4,10.4)4.1.2.14 Refrigerant Refrigerants constitute a large family of fluorinated hydrocarbon compounds that exhibit similar chemical properties and a wide range of physical characteristics.

Their inert character and the range of their vapor pressures, boiling points and other physical properties make them suited for use in refrigeration and air conditioning systems.Fluorocarbons show no appreciable decomposition at temperatures up to 400 OF, and oxidize only with extreme difficulty at very high temperatures.

Fluorocarbons are non-corrosive to all common metals except at very high temperatures.

Unless the system experiences contamination with moisture and/or sulfur, the conditions necessary for internal corrosion do not exist.4.1.2.15 Sodium Pentaborate The sodium pentaborate solution of the Standby Liquid Control (SBLC) system, also known as Liquid Poison system, provides a relatively mild environment (demineralized Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-1 5 Rev. 3 Sheet 9 of 37 water and pH slightly basic). However the solution can potentially induce corrosion if permissible conductivity and pH limits are exceeded.

The normal makeup water used for mixing the SBLC borated water solution is demineralized water that is maintained within chemistry guidelines.

Borated water chemistry is controlled in accordance with OCNGS Technical Specifications.

4.1.2.16 Steam Steam produced in the reactor vessel from reactor grade water and has extremely low levels of impurities.

The systems that are pertinent to this evaluation are the reactor pressure vessel and internals, isolation condenser, and main steam. The steam exists as a two-phase vapor, ranging from high quality steam in the main steam system to a low quality steam in the Isolation Condenser system. The Isolation Condenser lines normally see little or no steam flow because these systems operate infrequently.

4.1.2.17 Treated Water Demineralized water consists of pretreated fresh well water that is further purified in a mobile demineralized unit and transferred to the demineralized water storage tank (DWST) where it is stored until it is needed (Ref. 8, Section 9.2.3). The water is not treated with corrosion inhibitors and is not chemically treated to remove oxygen.Demineralized water chemistry is maintained in accordance with Exelon procedures (Ref. 19)Fuel pool water is demineralized water that is further recirculated through filters, demineralizers, and heat exchangers to achieve desired water quality and clarity. Fuel pool water is in conformance with chemistry parameters specified in EPRI TR-103515 (Ref. 16).Torus water is demineralized water. Water quality is maintained in accordance with Exelon procedures that include recommendations from EPRI TR-103515 (Ref. 16).Reactor grade water is water that has been demineralized, contains no added corrosion inhibitors, and low conductivity and impurities.

The various reactor grade waters have slightly different chemistry requirements.

Reactor grade water is maintained in accordance with more stringent chemistry parameters than other systems since this water is used for reactor coolant. Chemistry activities provide for monitoring and controlling of water chemistry that is based on EPRI TR-1 03515 (Ref. 16).Treated water is divided into three categories for the purpose of identifying applicable aging effects, Treated water, Treated water > 482 0 F, and Treated water < 140 0 F.Treated Water is used for systems that operate at any temperature and could contain austenitic stainless steel components, but no CASS at temperature

>482 0 F. In this environment, austenitic stainless steel components are conservatively assumed to be subject to SCC in addition to the other applicable aging mechanisms, regardless of actual operating temperature. (For additional details see Ref. 7 & Ref. 13). Treated water > 482 0 F, and Treated water < 140 0 F are discussed below.4.1.2.18 Treated Water < 140 0 F Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 10 of 37 Treated water < 140 0 F environment is used for systems that could contain austenitic stainless steel components.

In this environment, thermal aging embrittlement and SCC are not applicable aging mechanisms.

4.1.2.19 Treated Water > 482 0 F Treated water > 482 0 F environment is specified only for cast austenitic stainless steel (CASS) components that normally operate at a temperature greater than 482 0 F. In this environment, CASS components are susceptible to thermal aging embrittlement, which could lead to loss of fracture toughness aging effect in addition to other applicable aging effects.4.2.2 External Environments 4.2.2.1 Adverse Localized Environment Adverse localized environment is an environment that could exist in limited plant areas caused by heat, radiation, moisture, or voltage. This environment is applicable to electrical cables only.4.2.2.2 Aggressive Environment Ground water and raw water environments are considered aggressive if pH < 5.5, or chlorides

> 500 ppm, or sulfates > 1500 ppm.4.2.2.3 Boiler Treated Water Refer to section 4.1.2.2 4.2.2.4 Closed Cooling Water Refer to section 4.2.1.3 4.2.2.5 Closed Cooling Water < 140 0 F Refer to section 4.2.1.4 4.2.2.6 Concrete Concrete environment refers to components and commodities embedded or encased in concrete.

The high alkalinity of concrete (pH >12.5) provides an environment that protects embedded steel from corrosion.

4.2.2.7 Containment Atmosphere Refer to section 4.2.1.6 4.2.2.8 Dry Gas Refer to section 4.2.1.8 4.2.2.9 Encased Applies to components encapsulated in steel, or aluminum.

Encased components are inaccessible, and are not exposed to air, water, or other environments.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects 4.2.2.10 Fuel Oil Refer to section 4.1.2.9 4.2.2.11 Indoor Air Refer to section 4.1.2.10 4.2.2.12 Lubricating Oil Refer to section 4.1.2.11 4.2.2.13 Outdoor Air Refer to section 4.1.2.12 4.2.2.14 Raw Water -Fresh Water Refer to 4.1.2.13.1 4.2.2.15 Raw Water -Salt Water Refer to 4.1.2.13.2 PP-15 Rev. 3 Sheet II of 37 4.2.2.16 Soil External environment for structures and components that are in contact with soil.Structures and components in contact with soil may be exposed to groundwater if they are located below the local ground water elevation.

Site groundwater has been tested and determined non-aggressive to concrete.

The soil environment is also used for concrete components that may not be in contact with soil to account for potential cracking due to settlement since OCNGS structures are supported on soil.4.2.2.17 Steam Refer to section 4.1.2.16 4.2.2.18 Treated Water Refer to section 4.1.2.17 4.2.2.19 Treated Water < 140 Refer to section 4.1.2.18 4.2.2.20 Treated Water > 482 Refer to section 4.1.2.19 4.2.2.21 Water- Flowing Water that is refreshed, thus having a larger impact on leaching of calcium hydroxide from concrete structure 4.2.2.22 Water -Standing Water that is stagnant and unrefreshed, thus possibly resulting in increased ionic strength of solution up to saturation Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-1 5 Rev. 3 Sheet 12 of 37 4.2.2.23 Adverse Localized Environment Adverse localized environment is an environment that could exist in limited plant areas caused by heat, radiation, or moisture in the presence of oxygen. This environment is applicable to electrical cables only.4.3 Aging Effects The standard aging effects and the corresponding age-related degradation mechanisms listed in Table 4 were extracted from NUREG-1801 (Ref. 6), Industry documents (Ref. 13, 14), and previous license renewal applications (Ref. 21-26). The list should be used when determining aging effects and aging mechanisms applicable to OCNGS structures, components, or commodities as described in PLI-3 (Ref. 1).5.0 Attachments:

Table 1 -Oyster Creek Materials and Equivalent NUREG-1801 Materials Table 2 -Oyster Creek Internal Service Environments and Equivalent NUREG-1 801 Environments Table 3 -Oyster Creek External Environments and Equivalent NUREG-1 801 Environments.

Table 4 -Standard Mechanical Aging Effects Table 5 -Standard Structural Aging Effects (Excluding Concrete)Table 6 -Standard Structural Aging Effects (Concrete)

Table 7 -Electrical Aging Effects and Mechanisms Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1 801 Aging Effects Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects 6.0 References PP-15 Rev. 3 Sheet 13 of 37 1. PLI-3, "Screening of Systems, Structures and Commodities" 2. 1 OCFR54.4 Requirements for Renewal of Operating Licenses for Nuclear Power Plants 3. NEI 95-10, "Industry Guideline for Implementing The Requirements of 10 CFR Part 54 -The License Renewal Rule," Revision 5 4. Oyster Creek Component Record List (CRL)5. NUREG-1 800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", Draft Rev. 1, January 2005.6. NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report," Draft Rev. 1, January 2005.7. NEI Letter to Dr. P.T. Kuo, Proposed method for updating the GALL report, NUREG-1 801, dated May 11,2004.8. Oyster Creek Nuclear Generating Station Updated Final Safety Analysis Report, Rev. 13 9. SYS-LL-OC-1, "Line List & Specification" 10. BR 2001 Sheet 1, Revision 20, Mechanical Symbols 11. SDBD-OC-243 (MPR), Design Basis Document for Containment System Oyster Creek Nuclear Generating Station 12. ES-027, Environmental Parameters

-Oyster Creek NGS, Rev. 4 13. EPRI TR-1003056, "Non-Class I Mechanical Implementation Guideline and Mechanical Tools, Revision 3" 14. EPRI TR-1 002950, "Structural Tools, Revision 1" 15. EPRI TR-1 07396, "Closed Cooling Water Chemistry Guidelines" 16. EPRI TR-1 03515, "BWR Water Chemistry Guidelines" 17. Exelon Procedure CY-AB-1 20-100, "Reactor Water Chemistry" 18. Exelon Procedure CY-AB-1 20-320, "Control Rod Drive Water Chemistry" 19. Exelon Procedure CY-AA-120-400, "Closed Cooling Water Chemistry" 20. Aging Effects Topical Report, Dresden Nuclear Power Station Units 2 &3, Quad Cities Nuclear Power Station 1 &2.21. Dresden and Quad Cities License Renewal Application, including RAI 3.0-1 22. Peach Bottom License Renewal Application

23. R.E. Ginna Nuclear Power Plant, Application for Renewed Operating License 24. BFN Units 1, 2, and 3 License Renewal Application

25. Donald C. Cook Nuclear Plant License Renewal Application

26. Joseph M. Farley Nuclear Plant Units 1 and 2, Application for License Renewal 27. EPRI 1003057, "License Renewal Electrical Handbook" Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 14 of 37 Table I -Oyster Creek Materials and Equivalent NUREG-1 801 Materials Oyster Creek Equivalent NUREG- Comments Material 1801 Material Alloy steel Steel Alloy steel closure bolting with yield strength < 150 ksi; except for bolting in the Control Rod Drive system where it is considered high-strength (yield > 150 ksi)Aluminum Aluminum Alumina Silica Material not in NUREG- Alumina silica consists of high 1801 temperature ceramic fibers and inorganic binders. The material is used in fire rated barriers.Asbestos Material not in NUREG- Fibrous material used for thermal (Thermal Insulation) 1801 insulation of piping and components.

Aluminum bronze Copper alloy Boraflex Boraflex Boral Boral Brass Copper alloy Bronze Copper alloy Calcium Silicate Material not in NUREG- Thermal insulation material (Thermal Insulation) 1801 manufactured from mineral fiber and molded or shaped to easily fit around piping and components.

CASS Cast austenitic stainless steel (CASS)Carbon and low alloy Steel steel Cast Iron Steel For Oyster Creek, cast iron is treated Gray cast iron as gray cast iron and subject to loss of material due to selective leaching.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 15 of 37 Table 1 -Oyster Creek Materials and Equivalent NUREG-1801 Materials Oyster Creek Equivalent NUREG- Comments Material 1801 Material Chrome Moly Steel Chrome Moly is not specifically identified in NUREG-1801.

The material provides high resistance to loss of material due to flow-accelerated corrosion (FAC).However it is conservatively treated as carbon steel.Concrete Concrete Copper Copper alloy <15% Zn Copper Alloy Copper alloy > 15% Zn Elastomer Elastomer Butyl, Rubber, Neoprene, silicones Epoxy Potting Material not in NUREG- Epoxy resin material used as a 1801 sealant around cables for containment electrical penetrations.

Fiberglass Material not in NUREG- Semi-rigid fibrous glass quilted (Thermal Insulation) 1801 between two layers of scrim and encapsulated in fiberglass cloth jackets, forming a composite blanket;or pre-molded fiberglass modules and panels encased in fiberglass jackets.Galvanized steel Galvanized Steel Glass Glass Gravel, Sand Material not in NUREG- Crushed stone and sand used for 1801 tank foundations.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 16 of 37 Table 1 -Oyster Creek Materials and Equivalent NUREG-1801 Materials Oyster Creek Equivalent NUREG- Comments Material 1801 Material Grout Grout Gypsum board Material not in NUREG- Wallboard used in fire barriers.1801 Insulation material -Insulation materials bakelite, phenolic (e.g. bakelite, phenolic melamine or ceramic, melamine or ceramic, molded polycarbonate molded polycarbonate)

High strength alloy Low-alloy steel, yield Closure bolting for the reactor vessel steel strength >150 ksi and CRD system.Lubrite Lubrite Masonry Concrete block Mecatiss Material Not NUREG- Mecatiss is a trade name for fire 1801 barrier material.

It consists of layers of mineral wool covered internally and externally by fiberglass cloth, which is saturated with a patented silicon sealer. Each layer of wool and cloth is also coated with patented mastic glue, which forms heat and moisture barriers.Nickel alloy Nickel alloys NUKON Material not in NUREG- NUKON insulation system consists of (Thermal Insulation) 1801 fiberglass blankets, modules, or panels used for thermal insulation inside the primary containment drywell.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 17 of 37 Table 1 -Oyster Creek Materials and Equivalent NUREG-1 801 Materials Oyster Creek Equivalent NUREG- Comments Material 1801 Material Permali Material Not NUREG- Trade name for a composite material 1801 used for shielding purposes in the primary containment biological shield wall penetrations.

Plexiglass Material Not in Plexiglass is clear plastic material NUREG-1801 (Lucite) used in the Standby Gas Treatment ductwork Polyethylene Material Not in NUREG-1801 Polymers Polymer (e.g., rubber) Polymers in the Oyster Creek LRA are plastic materials.

Rubbers are_ addressed as elastomers.

Polypropylene Material Not in Polypropylene is a thermoplastic NUREG-1801 material with good resistance to strong acids, weak to strong alkalis, and most organic solvents.

The material is used for chlorination system piping Polyvinyl chloride Material Not in PVC and CPVC piping and fitting NUREG-1801 and conduits.(PVC, CPVC)Porcelain, malleable Porcelain, malleable Used for High Voltage insulators iron, aluminum, iron, aluminum, galvanized steel, galvanized steel, cement cement Pyrocrete Material not in Used as a Fire Barrier NUREG-1 801 Roofing Material Material Not in Built-up roofing materials NUREG-1 801 (waterproofing membrane, felt, tar, flashing, etc.) for structures, Stainless steel Stainless steel Tar Material Not in Bituminous materials used for NUREG-1 801 sealing concrete joints, and intake canal slope protection.

Thermo-Lag Material not in Used as a Fire Barrier NUREG-1 801 Titanium Material Not in Heat exchanger titanium tubes.NUREG-1801 Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 18 of 37 Table 1 -Oyster Creek Materials and Equivalent NUREG-1801 Materials Oyster Creek Equivalent NUREG- Comments Material 1801 Material Treated wood Material Not in Pressure treated utility poles, wood NUREG-1801 piles and wood sheeting used in water control structures.

Various (Gravel, Tar, Various Material that make dams, canals, Soil, wood, galvanized and other earthen water control steel) structures Various metals used Various metals used for for electrical electrical contacts connections Various organic Various organic Polymers used in electrical polymers (e.g. EPR, polymers (e.g. EPR, applications XLPE, PVC, ETFE) SR, EPDM, XLPE)Zinc Material not in NUREG-1801 I Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev.oa -3DeletelSheet 19 of 37 Table 2 -Oyster Creek Internal Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Auxiliary Steam' Heating and process steam produced from Steam heating boiler using Boiler Treated Water.Boiler Treated Water ' Demineralized water subject to chemistry Treated Water controls specified in the plant Auxiliary Boiler Chemistry procedure.

Closed Cooling Water Treated water subject to water chemistry Closed cycle cooling controls recommended in EPRI TR-107396, water"Closed Cooling Water Chemistry Guidelines." Closed Cooling Water includes Reactor Building Closed Cooling Water (RBCCW), and Turbine Building Closed Cooling Water (TBCCW).Closed Cooling Water Closed cooling water below the temperature Closed cycle cooling< 140 0 F 2 threshold for SCC in austenitic stainless steel water components.

Condensation Condensation environment applies to internal Condensation surfaces of design features, such as drain (Internal/External) traps, provided to collect potential moisture in gas or air systems.' This environment is not an exact match of the environment defined in NUREG-1 801 because water chemistry is controlled to different guidelines.

However for aging management review considerations it is considered equivalent.

2 This environment is not an exact match of environments defined in NUREG-1 801; however it is bounded by the listed equivalent NUREG-1 801 environment Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 20 of 37 Table 2 -Oyster Creek Internal Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Containment This environment is inert with nitrogen to Air -Indoor Atmosphere render the atmosphere non-flammable by Uncontrolled maintaining the oxygen content below 4% by volume. The average normal temperature inside the drywell is 139 0 F, with a humidity range of 20-40%. The upper elevations (above elev. 95') of the drywell could be exposed to higher temperatures, up to 256 0 F.Diesel Engine Exhaust Gas present in diesel engine exhaust Diesel Exhaust gases Dry Gas Carbon dioxide, halon, helium, dried air, Gas hydrogen, oxygen, nitrogen Air, Dry Fuel Oil Diesel oil used for the combustion engines Fuel Oil and heating boilers.Indoor Air Air in a sheltered environment, other than Air -Indoor containment atmosphere.

Air temperature Uncontrolled range is 65 0 F -1 40 0 F and the humidity Is 100% maximum.Lubricating Oil Low to medium viscosity hydrocarbons used Lubricating Oil for lubrication of rotating equipment.

Outdoor Air Outdoor air environment is subject to local Air -Outdoor weather conditions.

The mean temperature range is 23.7 0 F -84 0 F and the average annual precipitation is approximately 42 inches.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 21 of 37 Table 2 -Oyster Creek Internal Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Raw Water -Fresh Fresh raw water is drawn from either a deep Raw Water Water well or from the Fire Pond Dam. Water taken from the deep wells is processed in the pretreatment facility and used for domestic water or treated further and used as Demineralized water and for make up to the condensate storage and transfer system.Fresh water drawn from the Fire Pond Dam is untreated and is used for fire suppression and to the circulating water and service water pumps seals, and dilution pump oil coolers.Recent chemistry results show that the pH =4.8, chlorides

= 12 ppm, and sulfates = 6 ppm.Raw Water -Salt Raw salt water is drawn from Barnegat Bay, Water which receives salt water from the Atlantic Ocean and fresh water runoff from streams, which border it on the western shore, including Oyster Creek and Forked River.Recent tests of water samples taken at the Intake Structure and Canal showed that the pH = 7.9, Chlorides

=14659 ppm, and Sulfates 1419 ppm. The average monthly water temperature range is 37 0 F in the winter and 80 0 F in summer Refrigerant Inert gases such as Freon commonly used in Gas refrigeration and air conditioning systems.Sodium Pentaborate This environment consists of treated water Sodium pentaborate containing sodium pentaborate solution.

The solution environment is found only in Standby Liquid Control System (Liquid Poison System)Steam Steam that is subject to BWR water chemistry Steam controls Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 22 of 37 Table 2 -Oyster Creek Internal Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Treated Water Treated water is demineralized water and is Treated water the base water for all clean systems.Depending on the system, this demineralized Reactor Coolant water may require additional processing.

Treated water can be deaerated, include corrosion inhibitors, biocides, or some combination of these treatments.

Treated water is subject to BWR water chemistry controls.

Treated water includes reactor grade water, spent fuel pool water, torus water, and demineralized water.Treated Water < Treated Water below the temperature Treated water 1 40 0 F' threshold for SCC in austenitic stainless steel components.

Treated Water > 482 0 F Treated water above thermal embrittlement Treated water >threshold for CASS components.

482 0 F X This environment is not an exact match of environments defined in NUREG-1801; however it is bounded by the listed equivalent NUREG-1801 environment I Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. ;, I (Delete Sheet 23 of 37 Table 3 -Oyster Creek External Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Adverse localized Environment, which could exist in limited plant Adverse Localized Environment areas caused by heat, radiation, or moisture Environment in the presence of oxygen.Aggressive Ground water and raw water environments Aggressive Environment 1 are considered aggressive if pH < 5.5, or Environment chlorides

> 500 ppm, or sulfates > 1500 ppm.Boiler Treated Water' Demineralized water subject to chemistry Treated Water controls specified in the plant Auxiliary Boiler Chemistry procedure Closed Cooling Water Treated water subject to water chemistry Closed cycle cooling controls recommended in EPRI TR-1 07396, water"Closed Cooling Water Chemistry Guidelines." Closed Cooling Water includes Reactor Building Closed Cooling Water (RBCCW), and Turbine Building Closed Cooling Water (TBCCW).Closed Cooling Water Closed cooling water below the temperature Closed cycle cooling<1 40 0 F 3 threshold for SCC in austenitic stainless steel water components.

Concrete Embedded or Encased in concrete Concrete Containment This environment is inert with nitrogen to Air -Indoor Atmosphere render the atmosphere non-flammable by Uncontrolled maintaining the oxygen content below 4% by volume. The average normal temperature Air with Reactor inside the drywell is 139 0 F, with a humidity Coolant Leakage range of 20-40%. The upper elevations (above elev. 95') of the drywell could be Air with Steam or exposed to higher temperatures, up to 256 0 F. Water Leakage For bolting this environment includes potential leakage of treated water, steam, or raw water 1 This environment is not an exact match of aggressive environments defined in NUREG-1801, Table IX.D.However it is an exact match of the aggressive environment used in NUREG-1801 AMR tables, for example line Item III.A34 (T-05).2 This environment is not an exact match of the environment defined in NUREG-1801 because water chemistry is controlled to different guidelines.

However for aging management review considerations it is considered equivalent.

3 This environment is not an exact match of environments defined in NUREG-1801; however it is bounded by the listed equivalent NUREG-1 801 environment Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 24 of 37 Table 3 -Oyster Creek External Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Dry Gas Nitrogen Gas Air, Dry Encased Applies to components encapsulated in steel, Environment not in or aluminum.

Encased components are NUREG-1801 inaccessible, and not exposed to air, water, or other environments.

Fuel Oil Diesel oil used for the combustion engines Fuel Oil and heating boilers.Indoor Air Air in a sheltered environment, other than Air -indoor containment atmosphere.

Air temperature Uncontrolled range is 65 0 F -1 40'F and the humidity is 100% maximum. For bolting this environment Air with Reactor includes potential leakage of treated water, Coolant Leakage steam, sodium pentaborate, or raw water Air with Steam or Water Leakage Lubricating Oil Low to medium viscosity hydrocarbons used Lubricating Oil for lubrication of rotating equipment.

Outdoor Air Outdoor air environment is subject to local Air -Outdoor weather conditions.

The mean temperature range is 23.7 0 F -84 0 F and the average annual precipitation is approximately 42 inches.Raw Water -Fresh Fresh water drawn from the Fire Pond Dam is Raw Water Water untreated and is used for fire suppression and to the circulating water and service water pumps seals, and dilution pump oil coolers.Recent chemistry results show that the pH =4.8, chlorides

= 12 ppm, and sulfates = 6 ppm.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 25 of 37 Table 3 -Oyster Creek External Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Raw Water -Salt Raw salt water is drawn from Barnegat Bay, Raw Water Water which receives salt water from the Atlantic Ocean and fresh water runoff from streams, which border it on the western shore, including Oyster Creek and Forked River.Recent tests of water samples taken at the Intake Structure and Canal showed that the pH = 7.9, Chlorides

=14659 ppm, and Sulfates 1419 ppm. The average monthly water temperature range is 37 0 F in the winter and 80 0 F in summer.Soil External environment for structures and Soil components buried in soil. Buried structures and components mayl be exposed to groundwater if they are located below the local ground water elevation.

Site groundwater has been tested and determined non-aggressive to concrete.Steam Steam that is subject to BWR water chemistry Steam controls Treated Water Treated water is demineralized water and is Treated water the base water for all clean systems.Depending on the system, this demineralized water may require additional processing.

Treated water can be deaerated, include corrosion inhibitors, biocides, or some combination of these treatments.

Treated water is subject to BWR water chemistry controls.

Treated water includes reactor grade water, spent fuel pool water, torus water, and demineralized water.Treated Water Treated Water below the temperature Treated water< 140 0 F' threshold for SCC in austenitic stainless steel components.

Treated Water > 482 0 F Treated water above thermal embrittlement Treated water threshold for CASS components.

> 482 0 F' This environment is not an exact match of environments defined in NUREG-1801; however it is bounded by the listed equivalent NUREG-1801 environment Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 26 of 37 Table 3 -Oyster Creek External Service Environments and Equivalent NUREG-1801 Environments Oyster Creek Description Equivalent NUREG-Environment 1801 Environment Water -flowing Water that is refreshed, thus having larger Water -flowing impact on leaching of calcium hydroxide from concrete structures.

Water -standing Water that is stagnant and un-refreshed, thus Water -standing possibly resulting in increased ionic strength of solution up to saturation Table 4 -Standard Mechanical Aging Effects Aging Effect Applicable Aging Mechanism Buildup of Deposits Due to:* Biofouling

• Fouling Loss of Material Due to:* General Corrosion* Crevice Corrosion* Pitting Corrosion* Galvanic Corrosion* Microbiologically Influenced Corrosion (MIC)* Flow Accelerated Corrosion (FAC).Erosion* Selective Leaching* Wear Crack Initiation and Growth Due to:* Hydrogen Damage* Stress Corrosion Cracking (SCC)* Intergranular Stress Corrosion Cracking (IGSCC)* Irradiation Assisted Stress Corrosion Cracking (IASCC)* Cyclic Loading* Fatigue Loss of Fracture Toughness Due to:* Neutron Irradiation Embrittlement Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 27 of 37 Table 4 -Standard Mechanical Aging Effects Aging Effect Applicable Aging Mechanism* Thermal Aging Embrittlement Loss of Fracture Toughness (TLAA) Due to:* Neutron Irradiation Embrittlement

• Thermal Aging Embrittlement Loss of Preload Due to:* Stress relaxation Cumulative Fatigue Damage (TLAA) a Fatigue Change in Material Properties Due to:* Irradiation

• Thermal Exposure* Ultraviolet Radiation

& Ozone Reduction of Heat Transfer Due to:* Fouling caused by the buildup (from whatever source) on the heat transfer surface Reduction of Neutron-Absorbing Due to: Capacity

• Irradiation

• Loss of the Boraflex Matrix Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 28 of 37 Table 5 -Standard Structural Aging Effects (Excluding Concrete)Aging Effect Applicable Aging Mechanism Change in Material Properties Due to:* Irradiation

• Thermal Exposure* Ultraviolet Radiation

& Ozone Crack Initiation and Growth Due to:* Stress Corrosion Cracking (SCC)* Intergranular Stress Corrosion Cracking (IGSCC)* Cyclic Loading_ Fatigue Cumulative Fatigue Damage

• Fatigue Cumulative Fatigue Damage (TLAA)

• Fatigue Fretting or Lockup Due to:* Mechanical wear Loss of Preload Due to:* Stress relaxation Loss of Material Due to:* General Corrosion* Crevice Corrosion Ad Pitting Corrosion* Galvanic Corrosion* Microbiologically Influenced Corrosion (MIC)e Erosion* Selective Leaching* Wear Loss of Material, Loss of Form Due to: (Applies to earthen structures)

• Erosion* Settlement

• Sedimentation

• Sink holes Loss of Mechanical Function Due to:* Corrosion* Distortion

• Dirt* Overload* Fatigue due to vibratory and cyclic thermal loads* Elastomer hardening Loss of Sealing Due to:* Deterioration of seals, gaskets, and moisture Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 29 of 37 Table 5 -Standard Structural Aging Effects (Excluding Concrete)Aging Effect Applicable Aging Mechanism barriers (caulking, and other sealants)Reduction or Loss of Isolation Due to: Function

• Radiation hardening* Temperature

• Humidity* Sustained vibratory loading Reduction in Anchor Capacity Due to Due to: Local Concrete Degradation

• Cracking* Loss of material Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 30 of 37 Table 6 -Standard Structural Aging Effects (Concrete)

Aging Effect Applicable Aging Mechanism Loss of Material Due to:* Freeze -Thaw* Abrasion and Cavitation

• Elevated Temperature

• Aggressive Chemical Attack* Corrosion of Embedded Steel* Corrosion of Reinforcing Steel Cracking Due to:* Freeze-Thaw

• Reaction with Aggregates

• Shrinkage* Settlement

• Elevated Temperature

• Irradiation

• Fatigue* Restraint (applicable to masonry block walls)Change in Material Properties Due to:* Leaching of Calcium Hydroxide* Aggressive Chemical Attack* Elevated Temperature

• Irradiation

• Irradiation of Reinforcing Steel* Creep* Cathodic Protection Effect on Bond Strength Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 31 of 37 Table 7 -Electrical Aging Effects and Mechanisms Aging Effect Applicable Aging Mechanism Degradation due to various aging mechanisms Applies to components subject to (TLAA) 1 OCFR50.49, Environmental Qualification requirements Embrittlement, cracking, melting, discoloration, swelling, or loss of dielectric strength leading to reduced insulation resistance (IR); electrical failure caused by thermal/thermoxidative degradation of organics; radiolysis and photolysis (ultraviolet

[UV] sensitive materials only) of organics; radiation-induced oxidation; moisture intrusion Embrittlement, cracking, melting, discoloration Due to:* Heat* Ultraviolet Increased Resistance Due to:* Ohmic heating* Thermal cycling* Electrical transients Localized damage and breakdown of insulation Due to: leading to electrical failure

• Moisture intrusion* Water trees Loss of Material Due to:* Ant damage* Insect damage* Moisture damage Change in Material Properties Due to:* Moisture damage Various degradations Due to:* Various mechanisms Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 32 of 37 Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1801 Aging Effects Oyster Creek Aging Description or Explanation Equivalent NUREG-1801 Aging Effects Effects Change in Material Change in material properties is used to Loss of Bond/ Corrosion of Rebar Properties designate loss of bond, increase in porosity and permeability, and loss of Increase in Porosity and Concrete strength listed in NUREG-1801.

Change Permeability/Aggressive in material properties is evidenced in Chemical Attack concrete structures and structural members as increased permeability, Increase in Porosity and increased porosity, reduction in pH, permeability, Loss of Strength/reduction in tensile strength, reduction in Leaching Hydroxide compressive strength, reduction in Increase in Porosity, modulus of elasticity, and reduction in Permeability!

Leaching of bond strength.

Calcium Hydroxide Reduction of Strength and Modulus/ Elevated Temperature

(>1 50' F general; >2000 F local)Change in Material Change in material properties is used to Increased Hardness, Shrinkage Properties designate increased hardness, shrinkage and loss of strength/Weathering and loss of strength due to weathering l Elastomer and hardening and loss of strength due to Hardening and Loss of Strength/elastomer degradation.

Elastomer Degradation Cracking Cracking in concrete may be due to Expansion and Cracking/reaction with aggregate, corrosion of Reaction with Aggregate* Concrete embedded steel, freeze-thaw, aggressive chemical attack, elevated temperature, Loss of Material (Spalling, shrinkage, and settlement.

Aging Scaling) and Cracking!

Freeze-mechanisms are not specifically listed in Thaw the AMR tables. However, the applicable mechanisms are addressed as indicated by NUREG-1801 Vol. 2 Item line number. Cracking, Loss of Bond d Loss of Material (Spalling, Scaling)/

Corrosion of embedded Steel Increase in Porosity and Permeability, Cracking, Loss of Material (Spalling, Scalling)/

Aggressive Chemical Attack Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 33 of 37 Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1801 Aging Effects Oyster Creek Aging Description or Explanation Equivalent NUREG-1801 Aging Effects Effects Cracks and distortion due to increased stress levels from settlement Cracking Cracking of masonry walls is due to Cracking due to Restraint restraint against expansion and shrinkage, Creep, and* Masonry contraction, shrinkage, and creep. The Aggressive Environment walls are not exposed to aggressive environment.

This term is synonymous to the "cracking" Cracking/

Cyclic Loading standardized expression in NUREG-Cracking Initiation and 1801. The Oyster Creek AMR tables Cracking/

Stress Corrosion Growth present aging at the aging effect level and Cracking do not specifically list the associated l aging mechanisms.

However aging Cracking / Stress Corrosion management reviews consider the Cracking and Intergranular applicable aging mechanisms and the Stress Corrosion Cracking credited aging management programs Cracking .Stress Corrosion are reviewed to ensure that the applicable Cracking, /ntergranular Stress aging mechanisms are adequately Corrosion Cracking, and Cyclic managed. Loading Cracking/

Stress Corrosionr lCracking, Intergranular Stress Corrosion Cracking, Irradiation-assisted Stress Corrosion Cracking Cracking/

Flow-Induced vibration Cracking/

Thermal and Mechanical Loading Cumulative Fatigue Cumulative fatigue damage is due to Cumulative Fatigue Damage Damage (TLAA) fatigue as defined by ANSI B31.1, ASME III, and ASME VIII.Embrittlement, Cracking, Embrittlement, Cracking, Melting, Melting, Discoloration, Discoloration, Swelling, or Loss Swelling, or Loss of Same as NUREG-1 801 Table IX.E of Dielectric Strength Leading to Dielectric Strength Reduced Insulation Resistance Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 34 of 37 Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1801 Aging Effects Oyster Creek Aging Description or Explanation Equivalent NUREG-1801 Aging Effects Effects j Leading to Reduced (IR); Electric Failure/ Degradation Insulation Resistance of Organics (IR); Electric Failure/ (Thermal/Thermoxidative), Degradation of Organics Radioalysis and Photolysis (UV (Thermal/Thermoxidativ Sensitive Materials only) of e), Radioalysis and Organics; Radiation-induced Photolysis (UV Sensitive Oxidation, and Moisture Intrusion Materials only) of Organics; Radiation-induced Oxidation, and Moisture Intrusion Fretting or Lockup Same as NUREG-1 801 Table IX.E Fretting or Lockup Localized Damage and Same as NUREG-1 801 Table IX.E Localized Damage and Breakdown of Insulation Breakdown of Insulation Leading Leading to Electrical to Electrical Failure/Moisture Failure/ Moisture Intrusion, Water Trees Intrusion, Water Trees Loss of Form In earthen water-control structures, loss Loss of Form of form can result from erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, and seepage.Loss of Fracture Loss of Fracture Toughness/

Toughness Thermal Aging Embrittlement l Same as NUREG-1 801 Table IX.El Loss of Fracture Toughness/

Neutron Irradiation Embrittlement Loss of Fracture Toughness/

Thermal Aging and Neutron Irradiation Embrittlement Loss of Leak Tightness The primary containment Loss of Leak Tightness personnel/equipment airlock can experience loss of leak tightness in closed position resulting from mechanical wear of locks, hinges, and closure mechanisms Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 35 of 37 Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1801 Aging Effects Oyster Creek Aging Description or Explanation l Equivalent NUREG-1801 Aging Effects j Effects Loso:aeil eeaPtig Loss of Material* Metallic materials Loss of material for metallic materials can be the result of one or more aging mechanism including general corrosion, pitting, crevice corrosion, microbiologically influenced corrosion, fouling, flow-accelerated corrosion, galvanic corrosion, selective leaching, and wear. The Oyster Creek AMR tables present aging at the aging effect level and do not specifically list the applicable aging mechanisms.

However the Oyster Creek aging management reviews consider the applicable aging mechanisms and the credited aging management programs are reviewed to ensure that the applicable aging mechanisms are adequately managed. For example loss of material due galvanic corrosion is managed by programs that manage loss of material due to general corrosion, such as water chemistry programs and one-time inspection or by periodic inspections.

The NRC staff has found that these activities are adequate to manage loss of material due to galvanic corrosion (D!QC SER NUREG-1796, Section 3.3.2.5).Selective leaching and flow-accelerated corrosion mechanisms are also not specifically listed in the Oyster Creek AMR tables. However loss of material due to selective leaching is evaluated as indicated by the use of the Selective Leaching of Materials program. Loss of material or 'Wall Thinning" due to flow-accelerated corrosion is evaluated as indicated by identification of the applicable NUREG-1801 Vol. 2 line number and by the use of Flow-Accelerated Corrosion program.Loss of Material/

General, Pitting, and Crevice Corrosion Loss of Material/

Corrosion Loss of Material/

General Corrosion Loss of Material/

General (Steel Only), Pitting and Crevice Corrosion Loss of Material/

Pitting, Crevice, and Microbiologically influenced Corrosion, and Fouling Loss of Material/

General, Pitting, Crevice, and Microbiologically Influenced Corrosion Loss of Material/

General and Pitting Corrosion Loss of Material/Microbiologically Influenced Corrosion Loss of Material/

Pitting and Crevice Corrosion Loss of Material/

Pitting and Crevice Corrosion, and Fouling Loss of Material/

Pitting, Crevice, and Galvanic Corrosion Loss of Material/

Selective Leaching Loss of Material/

Selective Leaching and General Corrosion Loss of Material/

Wear Wall Thinning/

Flow-Accelerated Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 36 of 37 Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1801 Aging Effects Oyster Creek Aging Description or Explanation l Equivalent NUREG-1801 Aging Effects j Effects Corrosion Loss of Material Loss of material in concrete may be due Cracking, Loss of Bond, and to corrosion of embedded steel, freeze- Loss of Material (Spalling,* Concrete thaw, aggressive chemical attack, and Scaling)/

Corrosion of Embedded abrasion or cavitation.

Aging Steel mechanisms are not specifically listed in the Oyster Creek AMR tables. However, Loss of Material (Spalling, the applicable mechanisms are Scaling) and Cracking/

Freeze-addressed as indicated by NUREG-1 801 Thaw Vol. 2 Item line number.Increase in Porosity and Permeability, Cracking, Loss of Material (Spalling, Scalling)!

Aggressive Chemical Attack Loss of Material/

Abrasion;Cavitation Loss of Material/

Corrosion of Embedded Steel Loss of Material, Loss of Same as NUREG-1801 Table IX.E Loss of Material, Loss of Form Form Loss of Mechanical Same as NUREG-1 801 Table IX.E Loss of Mechanical Function Function Loss of Preload Same as NUREG-1 801 Table IX.E Loss of Preload Loss of Sealing Same as NUREG-1 801 Table IX.E Loss of Sealing; Leakage Through Containment Not Applicable The aging effect in NUREG-1 801 is determined not applicable to Oyster Creek material and environment combination.

A basis for this determination is provided in a plant specific note.

Oyster Creek License Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 37 of 37 Table 8 -Oyster Creek Aging Effects and Equivalent NUREG-1801 Aging Effects Oyster Creek Aging l Description or Explanation 1 Equivalent NUREG-1801 Aging Effects J Effects None The material in the specified environment None does not result in an aging effect requiring management.

Reduction in Anchor Same as NUREG-1801 Table IX.E Reduction in Anchor Capacity Capacity Due to Local Due to Local Concrete Concrete Degradation Degradation Reduction of Heat Same as NUREG-1 801 Table IX.E Reduction of Heat Transfer Transfer Reduction of Neutron- Same as NUREG-1 801 Table IX.E Reduction of Neutron-Absorbing Absorbing Capacity Capacity Reduction or Loss of Same as NUREG-1 801 Table IX.E Reduction or Loss of Isolation Isolation Function Function Various degradations

/ Same as NUREG-1801 Various degradations

/ various various mechanisms mechanisms PP-01 ATTACHMENT 1 -LR System/Structure Names LR System Names: 1. "C" Battery Room Heating & Ventilation

2. 120/208 Volt Non-Essential Distribution System 3. 120VAC Vital Power System 4. 125V Station DC System 5. 24/48V Instrument Power DC System 6. 4160V AC System 7. 4160V Switchgear Room Ventilation

8. 480/208/120V Utility (JCP&L) Non-Vital Power 9. 480V AC System 10. 480V Switchgear Room Ventilation

11. Alternate Rod Injection System (ARI)12. Augmented Off-Gas Closed Cooling Water System 13. Augmented Off-Gas System 14. Automatic Depressurization System 15. Battery and MG Set Room Ventilation

16. Breathing Air System 17. Canal Water Temperature Monitoring System 18. Cathodic Protection System 19. Chemical Laboratory Auxiliary Gases 20. Chlorination System 21. Circulating Water System 22. Condensate System 23. Condensate Transfer System 24. Containment Inerting System 25. Containment Spray System 26. Containment Vacuum Breakers 27. Control Rod Drive System 28. Control Rods 29. Control Room HVAC 30. Core Spray System 31. Cranes and Hoists 32. Dilution System 33. Drywell Cooling System 34. Drywell Floor and Equipment Drains 35. Electrical Commodity Groups 36. Electrical Heat Trace System 37. Elevators and Manlifts 38. Emergency Diesel Generator and Auxiliary System 39. Emergency Service Water System 40. Feedwater System 41. Fire Protection System 42. Fuel Assemblies

43. Fuel Storage and Handling Equipment 44. Grounding and Lightning Protection System 1 PP-01 ATTACHMENT 1 -LR System/Structure Names 45. Hardened Vent System 46. Heating & Process Steam System 47. Hydrogen & Oxygen Monitoring System 48. Hydrogen Water Chemistry System 49. Instrument (Control)

Air System 50. Intermediate Range Monitoring System 51. Isolation Condenser System 52. Lighting System 53. Local Power Range Monitoring System/Average Power Range Monitoring System 54. Main Condenser 55. Main Condenser Air Extraction System 56. Main Fuel Oil Storage & Transfer System 57. Main Generator and Auxiliary System 58. Main Office Building HVAC 59. Main Steam System 60. Main Turbine and Auxiliary System 61. Meteorological Monitoring System 62. Miscellaneous Floor and Equipment Drain System 63. Miscellaneous HVAC System 64. New Radwaste Closed Cooling Water System 65. New Radwaste Service Water System 66. Nitrogen Supply System 67. Noble Metals Monitoring System 68. Nuclear Boiler Instrumentation

69. Offsite Power System 70. Penetration Pressurization System 71. Plant Annunciator System 72. Plant Communications System 73. Plant Computer System 74. Post-Accident Monitoring System 75. Post-Accident Sampling System 76. Process Sampling System 77. Radiation Monitoring System 78. Radio Communications System 79. Radwaste Area Heating and Ventilation System 80. Radwaste System 81. Reactor Building Closed Cooling Water System 82. Reactor Building Floor and Equipment Drains 83. Reactor Building Ventilation System 84. Reactor Head Cooling System 85. Reactor Internals 86. Reactor Manual Control System 87. Reactor Overfill Protection System (ROPS)88. Reactor Pressure Vessel 89. Reactor Protection System 2 PP-o1 ATTACHMENT 1 -LR System/Structure Names 90. Reactor Recirculation System 91. Reactor Water Cleanup System 92. Remote Shutdown System 93. Rod Worth Minimizer 94. Roof Drains and Overboard Discharge 95. Sanitary Waste System 96. Screen Wash System 97. Service Air System 98. Service Water System 99. Shutdown Cooling System 100. Source Range Monitoring System 101. Spent Fuel Pool Cooling System 102. Standby Gas Treatment System (SGTS)103. Standby Liquid Control System (Liquid Poison System)104. Station Blackout System 105. Torus Water Storage and Transfer System 106. Traveling In-Core Probe System 107. Turbine Building Closed Cooling Water System 108. Turbine Building Ventilation System 109. Water Treatment

& Distr. System Notes: 1. Review system table to determine makeup of system 2. Numbering does not correspond to license renewal system number LR Structure Names: 1. Ambulance Building 2. Breathing Air Compressor Building 3. Chlorination Facility 4. Component Supports Commodity Group 5. Condensate Transfer Building 6. Dilution Structure 7. Discharge Structure and Canal 8. Domestic Water Facility 9. Emergency Diesel Generator Building 10. Exhaust Tunnel 11. Fire Pond Dam 12. Fire Pumphouses

13. Fish Sample Pool 14. Heat Exchanger Building 15. Heating Boiler House 16. Independent Spent Fuel Storage Installation

17. Intake Structure and Canal (Ultimate Heat Sink)18. Low Level Radwaste Facility 3 PP-01 ATTACHMENT 1 -LR System/Structure Names 19. Maintenance Buildings 20. Material Storage Buildings 21. Miscellaneous Yard Structures

22. Monitoring and Change Facility 23. New Radwaste Building 24. New Sample Pumphouse 25. Off Gas Building 26. Office Building 27. Old Radwaste Building 28. Other Office Buildings 29. Oyster Creek Substation

30. Pipe Tunnel 31. Piping and Component Insulation Commodity Group 32. Pretreatment Facility 33. Primary Containment

34. RAGEMS Buildings 35. Reactor Building 36. Respirator Facility 37. Security Structures

38. Site Emergency Building 39. Turbine Building 40. Ventilation Stack Notes: 1. Review structures table to determine makeup of structures

2. Numbering does not correspond to license renewal structure number 4 ATTACHMENT 4 -LR Systems/Structures by Category Reactor Vessel, Internals, and Reactor Coolant System 1. Control Rods 2. Fuel Assemblies

3. Isolation Condenser System 4. Nuclear Boiler Instrumentation

5. Reactor Head Cooling System 6. Reactor Internals 7. Reactor Pressure Vessel 8. Reactor Recirculation System Engineered Safety Features 1. Automatic Depressurization System 2. Containment Spray System 3. Core Spray System 4. Standby Gas Treatment System (SGTS)Auxiliary Systems 1. "C" Battery Room Heating & Ventilation

2. 4160V Switchgear Room Ventilation

3. 480V Switchgear Room Ventilation

4. Augmented Off-Gas Closed Cooling Water System 5. Augmented Off-Gas System 6. Battery and MG Set Room Ventilation

7. Breathing Air System 8. Chemical Laboratory Auxiliary Gases 9. Chlorination System 10. Circulating Water System 11. Containment Inerting System 12. Containment Vacuum Breakers 13. Control Rod Drive System 14. Control Room HVAC 15. Cranes and Hoists 16. Dilution System 17. Drywell Cooling System 18. Drywell Floor and Equipment Drains 19. Elevators

& Manlifts 20. Emergency Diesel Generator and Auxiliary System 21. Emergency Service Water System 22. Fire Protection System 23. Fuel Storage and Handling Equipment 1 ATTACHMENT 4 -LR Systems/Structures by Category 24. Hardened Vent System 25. Heating & Process Steam System 26. Hydrogen & Oxygen Monitoring System 27. Hydrogen Water Chemistry System 28. Instrument (Control)

Air System 29. Main Fuel Oil Storage & Transfer System 30. Main Office Building HVAC 31. Meteorological Monitoring System 32. Miscellaneous Floor and Equipment Drain System 33. Miscellaneous HVAC System 34. New Radwaste Closed Cooling Water System 35. New Radwaste Service Water System 36. Nitrogen Supply System 37. Noble Metals Monitoring System 38. Penetration Pressurization System 39. Plant Communications System 40. Post-Accident Sampling System 41. Process Sampling System 42. Radiation Monitoring System 43. Radwaste Area Heating and Ventilation System 44. Radwaste System 45. Reactor Building Closed Cooling Water System 46. Reactor Building Floor and Equipment Drains 47. Reactor Building Ventilation System 48. Reactor Water Cleanup System 49. Roof Drains and Overboard Discharge 50. Sanitary Waste System 51. Screen Wash System 52. Service Air System 53. Service Water System 54. Shutdown Cooling System 55. Spent Fuel Pool Cooling System 56. Standby Liquid Control System (Liquid Poison System)57. Torus Water Storage and Transfer System 58. Traveling In-Core Probe System 59. Turbine Building Closed Cooling Water System 60. Turbine Building Ventilation System 61. Water Treatment

& Distr. System Steam and Power Conversion Systems 1. Condensate System 2. Condensate Transfer System 3. Feedwater System 4. Main Condenser 5. Main Condenser Air Extraction System 2 ATTACHMENT 4 -LR Systems/Structures by Category 6. Main Generator and Auxiliary System 7. Main Steam System 8. Main Turbine and Auxiliary System Electrical Components

1. 120/208 Volt Non-Essential Distribution System 2. 120VAC Vital Power System 3. 125V Station DC System 4. 24/48V Instrument Power DC System 5. 4160V AC System 6. 480/208/120V Utility (JCP&L) Non-Vital Power 7. 480V AC System 8. Alternate Rod Injection System (ARI)9. Canal Water Temperature Monitoring System 10. Cathodic Protection System 11. Electrical Commodity Groups 12. Electrical Heat Trace System 13. Grounding and Lightning Protection System 14. Intermediate Range Monitoring System 15. Lighting System 16. Local Power Range Monitoring System/Average Power Range Monitoring System 17. Offsite Power System 18. Plant Annunciator System 19. Plant Computer System 20. Post-Accident Monitoring System 21. Radio Communications System 22. Reactor Manual Control System 23. Reactor Overfill Protection System (ROPS)24. Reactor Protection System 25. Remote Shutdown System 26. Rod Worth Minimizer 27. Source Range Monitoring System 28. Station Blackout System Structures and Component Supports 1. Ambulance Building 2. Breathing Air Compressor Building 3. Chlorination Facility 4. Component Supports Commodity Group 5. Condensate Transfer Building 6. Dilution Structure 7. Discharge Structure and Canal 8. Domestic Water Facility 3 ATTACHMENT 4 -LR Systems/Structures by Category 9. Emergency Diesel Generator Building 10. Exhaust Tunnel 11. Fire Pond Dam 12. Fire Pumphouses

13. Fish Sample Pool 14. Heat Exchanger Building 15. Heating Boiler House 16. Independent Spent Fuel Storage Installation

17. Intake Structure and Canal (Ultimate Heat Sink)18. Low Level Radwaste Facility 19. Maintenance Buildings 20. Material Storage Buildings 21. Miscellaneous Yard Structures

22. Monitoring and Change Facility 23. New Radwaste Building 24. New Sample Pumphouse 25. Off Gas Building 26. Office Building 27. Old Radwaste Building 28. Other Office Buildings 29. Oyster Creek Substation

30. Pipe Tunnel 31. Piping and Component Insulation Commodity Group 32. Pretreatment Facility 33. Primary Containment

34. RAGEMS Buildings 35. Reactor Building 36. Respirator Facility 37. Security Structures

38. Site Emergency Building 39. Turbine Building 40. Ventilation Stack 4 Position Paper 1, Rev 3 Sheet 1 of 7 License Renewal Systems and Structures Oyster Creek Generating Station Position Paper 1, Rev 3 Sheet 2 of 7 Prepared by: Date: Mark A. Miller Checked by: Date: Stu Getz Approved by: Date: Don B. Warfel Position Paper 1, Rev 3 Sheet 3 of 7 REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue)1 As-built to reflect scoping/screening/AMR completion 2 Revised LR Structures and incorporated administrative changes per 01#'s 1315 and 1440 3 Zinc Injection System was included in the Feedwater System per LRCR's 167 and 170.4 5 Position Paper 1, Rev 3 Sheet 4 of 7 TABLE OF CONTENTS Page Approval Page .................................................

2 Revision Summary ..................................................

3 Table Of Contents .................................................

4 Identification of Systems and Structures

................................................

5 1. Purpose .................................................

5 2. Scope........................................................................................................................5

3. Methodology

................................................

5 4. References

................................................

7 5. Attachments

.................................................

7 Attachment 1 -LR System/Structure Names (4 pgs)Attachment 2 -LR Name Sort of PP-1 Systems (49 pgs)Attachment 3 -OC LR Structures (4 pgs)Attachment 4 -LR Systems/Structures by Category (4 pgs)

Position Paper 1, Rev 3 Sheet 5 of 7 1. Purpose The license renewal scoping criterion under 10 CFR 54 requires the licensee to identify all systems or structures which fall within the scope of 1 OCFR54.4(a)(1), 1 OCFR54.4(a)(2), 1 OCFR54.4(a)(3).

Procedure ES-017 provides a comprehensive list of Oyster Creek systems and structures.

In addition to systems and structures, ES-017 also includes selected components and other special case groupings.

This position paper documents a review of the ES-01 7 list to identify the systems and structures appropriate for license renewal review. The list of systems and structures is verified by review against the Oyster Creek UFSAR. In some cases, system or structure descriptive titles are modified to reflect the UFSAR description terminology.

This position paper provides the correlation between the UFSAR and ES-017, and also provides a consolidated list of systems and structures appropriate for license renewal review.The purpose of this document is to identify a consolidated and verified list of systems and structures subject to 1 OCFR54.4 review.2. Scope This document applies to all systems and structures identified at Oyster Creek Generating Station.3. Methodology Engineering Standard ES-017, "Identification of Oyster Creek Plant Systems", has been established as the governing document for the assignment of identification numbers and names to Oyster Creek systems, structures, components, and special items. In some instances, Engineering Standard ES-01 7 also identifies a hierarchy within a system by identifying its related subsystems.

The use of ES-017 for these purposes is invoked in several key Oyster Creek documents and procedures:

• Oyster Creek UFSAR Section 17.2 states that operation and maintenance of the Oyster Creek Generating Station is conducted in accordance with the approved Quality Assurance Plan. Quality Assurance Topical Report (QATR) NO-AA-1 0, Appendix F, paragraph 2.2.1.1 identifies the PIMS Component Record List (CRL)as the database for the identification of the permanent plant structures, systems, and components within the scope of the QATR. The identification of systems, and their structure, within the CRL has been based on the systems, structures, components, and special items identified in ES-01 7.* Oyster Creek maintenance rule basis document TDR 1196, Rev. 01 Section II para. 2.2 identifies Engineering Standard ES-017 as the source document for the system number and name for Oyster Creek systems.

Position Paper 1, Rev 3 Sheet 6 of 7* Oyster Creek Procedure ES-012, "CRL Component ID, Data Format and Structure", Rev. 12 Sections 1.0, 4.9, 5.5 and Exhibit 1 identifies ES-017 as the source document for system identification.

• Oyster Creek Procedure EP-01 1, "Methodology for Assigning and Maintaining the Quality Classification of Components", Rev. 11 Exhibit 2D identifies ES-017 as the source document for system identification.

Based on this precedence, the initial license renewal systems list was developed from ES-017 systems and groupings.

This list was then benchmarked against the DRE/QC and PBAPS license renewal systems lists and further verified against other design basis documents for Oyster Creek (e.g., system DBD's, Maintenance Rule documentation, etc.). These reviews resulted in a validated initial license renewal systems list that could be reviewed against the Oyster Creek UFSAR.For every system, component, or special item identified, the applicable sections of the Oyster Creek UFSAR were reviewed to determine the relationship between ES-017 and UFSAR descriptions and functions.

Where appropriate, ES-017 systems have been combined or segregated to align with UFSAR system descriptions and functions as closely as possible.

The UFSAR was also reviewed to identify systems or functions not directly included in the ES-017 listing. UFSAR systems/functions not directly included in ES-01 7 were either logically grouped within an ES-01 7 system, or were identified as an individual License Renewal System. (e.g., The attached list of systems does not include a system referred to as primary containment isolation system or secondary containment isolation system. This is because Engineering Standard ES-01 7 does not include systems by these names. The primary containment and secondary containment isolation functions have been embedded within, and will be scoped with, the systems penetrating these structures.)

Plant structures were identified from the ES-017, UFSAR, plant design drawings, or PIMS. The license renewal name for each structure is based on whether the structure is specifically described in the UFSAR or not. Structures described in the UFSAR are given the UFSAR name as the license renewal name. For structures not described in the UFSAR, the license renewal name is the name used in ES-017 or design drawings.Trailers designated as structures in ES-017 or design drawings are not given a license renewal name. These are considered temporary enclosures and will not be included in the license renewal application.

The 390 ES-017 systems/structures/components/special items have been consolidated down to a total of 149 license renewal system/structure names. Each license renewal system may consist of only one ES-01 7 systems/structures/components/special item or may consist of multiple logically grouped systems/structures/components or special items. In a few instances, an ES-01 7 system was separated into multiple systems since the ES-017 system contained several distinctive functional groups that would be better scoped for license renewal individually.

An ES-017 system may also be identified as a"non-system" when the system number is used for higher-level system identification, or, when the system number is associated with a special item (such as a process).The 149 license renewal systems/structures were "binned" by discipline:

Structural, Mechanical, and Electrical/I&C.

Six (6) categories were then used to further group the license renewal systems and structures.

These categories include: Reactor Vessel, Position Paper 1, Rev 3 Sheet 7 of 7 Internals, and Reactor Coolant System; Engineered Safety Features; Auxiliary Systems;Steam and Power Conversion Systems; Electrical Components; and Structures and Component Supports.

To aid in the alignment of the Oyster Creek license renewal systems and structures into these categories, the guidance of NUREG-1 801 "Generic Aging Lessons Learned (GALL) Report" was utilized.The resulting list of all Oyster Creek license renewal systems and structures is provided in Attachment

1. Details of the systems review are provided in Attachment

2. Details of the structures review are provided in Attachment

3. Attachment 2 and 3 are to be used to determine system and subsystem groupings during the scoping process. Attachment 4 identifies the license renewal system/structures by category.4. References

1. 10 CFR Part 54 -Requirements for Renewal of Operating Licenses for Nuclear Power Plants.2. Nuclear Energy Institute (NEI), NEI 95-10, Industry Guideline on Implementing the Requirements of 10 CFR Part 54, Revision 5.3. NUREG-1 800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," January 2005 4. NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report," January 2005 5. TDR-1 196, "Oyster Creek Maintenance Rule Technical Basis Document", Revision 1.6. Engineering Standard ES-017, "Identification of Oyster Creek Plant Systems", Revision 22.7. Oyster Creek Generating Station Procedure ES-012, "CRL Component ID, Data Format and Structure", Revision 12.8. Oyster Creek Generating Station Procedure EP-01 1, "Methodology for Assigning and Maintaining the Quality Classification of Components", Revision 11.9. Oyster Creek Generating Station UFSAR, Revision 13, April 2003.10. Oyster Creek PIMS Component Records List (CRL)11. Exelon Quality Assurance Topical Report NO-AA-1 0, Revision 72 5. Attachments

1. LR System/Structure Names (4 pgs)2. LR Name Sort of PP-1 Systems (49 pgs)3. OC LR Structures (4 pgs)4. LR Systems/Structures by Category (4 pgs)

Oyster Creek License Renewal Project Project Level Instruction 1 Preparation of Project Level Instructions and Position Papers PLI-1 Rev. 3 Sheet 2 of 8 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio 5/28/04 Dave Honan Don Warfel 1 G. J. Beck Dave Honan Don Warfel 6/22/05 2 C.Micklo Dave Honan Don Warfel 8/24/05 3 S. B. Rafferty 6 _l John Hufnagel Dry; Don Warfel mff/@ /8/ass Revision Log Rev. Description of the Change 0 Initial Issue I Update references and exhibits 2 Addition of PLI-16 3 Updated for formatting reasons.

Oyster Creek License Renewal Project Project Level Instruction 2 Scoping of Systems & Structures PLI-02 Rev.4 Sheet 2 of 36 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 H. D. Honan K. P. Muggleston D. B. Warfel 1/16/04 1 K. P. Muggleston H. D. Honan D. B. Warfel 1/28/04 2 H. D. Honan K. P. Muggleston D. B. Warfel 4/21/05 3 H.D. Honan J. G. Hufnagel A.A. Fulvio 8/16/05 4 S. B. Raffert /J. G. HufnageJl D. B. Warfegy /0 9/9/O Oyster Creek License Renewal Project Project Level Instruction 3 Screening of Systems, Structures

& Commodities PLI-03 Rev.2 Page 2 of 22 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 K. P. Muggleston H. D. Honan D. B. Warfel 6/5/04 1 K. P. Muggleston C. Micklo D. B. Warfel 6/17/05 2 S. Rafferty L.J. Hufnagel SI4 D. B. Warfel Q J5 /_.:Y V Revision Log Rev. No. Description of the Change(s)0 Initial issue.1 Updated to correct references, minor editorial changes.2 Updated for formatting reasons.

Exelon Corporation PLI-04 Rev. 02 Sheet 2 of 11 APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Al Fulvio Don Warfel Date 1/13/04 1/13/04 1/13/04 01 Kevin Muggleston Stu Getz Al Fulvio Date 8/16/05 816/2005 8/16/05 02 non Daoffe ..John Hufnagel Warfel Date lb Oyster Creek License Renewal Project Project Level Instruction 5 Aging Management Reviews PLI-5 Rev. 2 Page 2 of 11 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Mark Miller Don Warfel 11-16-04 1 Kevin Muggleston Mark Miller Al Fulvio 8-17-05 2 T Shannon Rafferty0 John Hufnagel Don Warfel Revision Log Rev. Description of the Change 0 Initial Issue 1 Updated references, Database details and Table Description exhibit 2 Updated for formatting reasons.

Oyster Creek License Renewal Project Project Level Instruction 6.Evaluation of Time Limited Aging Analyses PLI-6 Rev2 Sheet 2 of 16 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 M. J. May A. A. Fulvio D. B. Warfel 1/24/05 1 M. J. May S. C. Getz A. A. Fulvio 8/16/05 2 S. Rafferty J. Hufnagel D.B. Warfel _______U,- _ ___-- -v -Revision Log Rev. Description of the Change o Initial Issue I Updated revision of NEI 95-10 and added NUREG-1800 to references.

2 Updated for formatting reasons.-t++++

Oyster Creek License Renewal Project Project Level Instruction 8 Aging Management Program Reviews PLI-8 Rev. 3 Sheet 2 of 8 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Mark Miller Don Warfel 8/19/04 1 Al Fulvio/Lou Corsi Mark Miller Don Warfel 4/20/05 2 Lou Corsi Mark Miller Don Warfel 6/22105 3 Shannon Rafferti John IHufnagel

(- Don Warfel ______/1 S .Revision Log Rev. Description of the Change 0 Initial Issue I Added Guidance contained in Exhibits 2 and 3 and approval process prior to Plant Health Committee 2 Added or updated references to NEI and NUREG 1800 and 1801 3 Updated for formatting reasons.I LI Oyster Creek License Renewal Project Project Level Instruction 11 License Renewal Document Control PLI- I1 Rev. 2 Sheet 2 of 5 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date o Al Fulvio Dave Honan Don Warfel 7/12/04 1 George Beck Dave Honan Don Warfel 6/22/05 2 Louis J. Corsi Stu Getz Don Warfel _911/05 Revision Log Rev. Description of the Change O Initial Issue 1 Add review and approval requirements for Position Papers and Project Level Instructions; update references 2 Revised para. 6.2.2 and 6.2.4 for clarity (.

Oyster Creek License Renewal Project Project Level Instruction 12 Training of License Renewal Project Team and Site Personnel PLI-12 Rev. 3 Page 2 of 6 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 Al Fulvio Tom Quintenz Don Warfel I George Beck Dave Honan Don Warfel 6/22/05 2 John Hufnagel Dave Honan Al Fulvio 8/18/05 3 Shannon Raffert John Hufnagel I\T\4 Don Warfel (7 Revision Log Rev. Description of the Change 0 Initial Issue 1 Update references 2 Clarified Applicability Section and Step 6.2 3 Formatting Changes Oyster Creek License Renewal Project Project Level Instruction 15 License Renewal Document Change Request Process PLI-15 Rev. 2 Sheet 2 of 8 Approvals Rev. No. Prepared by: Reviewed by: Approved by: Date 0 H. D. Honan Al Fulvio D. B. Warfel .5-28-04 1 L. J. Corsi Stuart Getz D. B. Warfel 9-1-05 2 S. B. Rafferty I / J. G. Hufnagel J614 D. B. Warfel e '.

Position Paper 1, Rev 3 Sheet 2 of 7 Prepared by: Checked by: Approved by: Mark A. Miller Stu Getz T Don B. Warfel U2 Date: I a/S Date: 2/o/z Date: _ _ _ _ _ _

PP-2, Rev 2 Sheet 2 of 26 I Approval Page Revislo Prepared by: Checked by: Approved by: n _00 ._Louis J. Corsi Mark Miller Don Warfel Date 1/0&'04 1/21/2004 1/21/2004 01 Louis J. Corsi Mark Miller Don Warfel Date 4/12/2005 4/2212005 4/22/2005 Louis J. Cors 02 7A) _ ___Date 6/21/2005

' _(pI -o/so/en i Criteria for Scoping Systems and Structures Relied upon to Demonstrate Compliance With 10 CER 54.4 (a)(2)PP-03 Rev. 3 Sheet 2 of 15 Approvals Revision Prepared by: Checked by Approved by: 00 ._A. M. Ouaou T. E. Quintenz Date 01 A. M. Ouaou K. Muggleston D. B Warfel Date _ _02 A. M. Ouaou K. P. Muggleston D. B. Warfel Date 03 Ouaou K. P. Mugglestor D. B. Warfel Date ________ / I /o

.I Position Paper 4, Rev 2 Sheet 2 of 19 I APPROVAL PAGE Prepared by: 0. MAr Date: G 11lGose04-Checked by: Date: V1 /Approved by:

-( -C17-21,W Date:¢I I I II Exelon Corporation I PP-5 Rev. 01 Sheet 2 of 10 (APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Mark Miller Don Warfel Date 1/20/04 1/20/04 1/20/04 01 Kevin Muggleston Mark Miller Don Warfel Date 4/26/2005 4/2612005 4126/2005 02 .Date I Exelon Corporation PP-6 Rev. 01 Sheet 2 of 12 APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Mark Miller Don Warfel Date 1/8104 1/&04 1/13104 01 Kevin Muggleston Mark Miller Don Warfel Date 6/21/04 6/21/04 02 _Date': (..

Exelon Corporation SPP-7 Rev. 03 Sheet 2 of 25 (APPROVAL PAGE Revision Prepared by: Checked by: Approved by: 00 Kevin Muggleston Stu Getz Don Warfel Date 1/13/04 1/13/04 1/15/04 01 Kevin Muggleston Stu Getz Don Warfel Date 7/1/04 7/1/04 7/1/04 02 Kevin Muggleston Stu Getz Don Warfel Date 41/25OS 41/25s0 4/25/OS 03 Kevin Muggleston Stu Get? Don WaIfel Date 523/05 LPIo I (I j I I

-Exelon Corporation PP-8 Rev. 2 Sheet 2 of 24 (APPROVAL PAGE ( -II Revision Prepared by: Checked by: Approved by: 00 A. M. Ouaou A. A. Fulvio D. B. Warfel Date 01 A. M. Ouaou S. B. Rafferty D. B. Warfel Date .02 Ouou K. P. Muggleston D. B. Warfel Date /3o6 _ _ _ _ _ _ _ _ _3X (.

Exelon Corporation PP-13 Rev. 2 Sheet 2 of 10 Approval Page Prepared by: Checked by: Approved by: 51 C GDate: S. C. Ge> 17 Date: A ADate: I) I&oo/?1 t 1/Z6*PI I"161et~k (

Oyster Creek Ucense Renewal Project Standard Materials, Environments, and Aging Effects PP-15 Rev. 3 Sheet 2 of 37 (APPROVAL PAGE!Revision Prepared by: Checked by: Approved by: 00_ _ A. M. Ouaou A. A. Fulvio Date _01 A. M. Ouaou K. P. Muggleston D. B. Warfel Date _02 Ahmed M. Ouaou M. A. Miller D. B. Warfel Date .03 A. M. Ouaou K. P. Muggleston D. B. Warfel Date 7j__6__ ___ 7/,- 6 5 ' 7 /6 (.

Oyster Creek Nuclear Generating Station System and Structure Scoping Form Service Water System Part of Auxiliary Systems System Grouping System Functions:

1. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The SWS ensures that the Spent Fuel Pool Cooling and Augmented Spent Fuel Pool Cooling heat exchangers maintain stored fuel within acceptable limits by providing cooling water to the RBCCW System heat exchangers.

The SWS contains non-safety related water filled lines throughout the Turbine Building which have spatial interactions (spray or leakage) with safety related SSCs.

Reference:

UFSAR Section 9.2.1.1 and 9.1.3.1 -1OCFR54.4(a)(2)

2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10CFR50.48).

The SWS is credited for supporting the Reactor Building Closed Cooling Water (RBCCW) System.

References:

FSSD Specification SP-1302-06-013 para.5.2.3.6.6

-1OCFR54.4(a)(3) w 'f--I/I; /;-'2'3. Maintains the Emergency Service Water (ESW) side of the Containment Spray heat exchangers full to ensure their readiness to perform their emergency function.

References:

UFSAR Section 9.2.1.1 4. Provide alternate, and/or supplementary seawater cooling to the tube side of the two Turbine Building Closed Cooling Water (TBCCW) heat exchangers.

References:

UFSAR Section 9.2.1.1 5. Supplies operating pressure for the Chlorination System Circulating

'Water and Service Water eductors.

References:

Flow Diagram.FP SE-5419 sht.. 1 6. Supplies operating pressure f6r'the Turbine Building Closed Cooling Water (TBCCW) heat exchangers water box vacuum priming eductors.

References:

, Flow Diagram BR 2005 sht.. 2 System Intended Functions:

1. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The SWS ensures that the Spent Fuel Pool Cooling and Augmented Spent Fuel Pool Cooling heat exchangers maintain stored fuel within acceptable limits by providing cooling water to the RBCCW System heat exchangers.

The SWS contains non-safety related water filled lines throughout the Turbine Building which have spatial interactions (spray or leakage) with safety related SSCs. -10 CFR 54.4(a)(2)

2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The SWS is credited for supporting the Reactor Building Closed Cooling Water (RBCCW) System. -10 CFR 54.4(a)(3)

Page 6 of 11 Revision No: 1 Page 6 of 11 Revision No: 1 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Roof Drains and Overboard Discharge Part of Auxiliary Systems System Grouping System Functions:

1. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The Roof Drains and Overboard Discharge System carries Emergency Service Water from the Containment Spray Heat Exchangers.

The Roof Drains and Overboard Discharge System carries Service Water from the Reactor Building Closed Cooling Water Heat Exchangers which are used to cool the Spent Fuel Pool Cooling and Augmented Spent Fuel Pool Cooling Heat Exchangers.

The Reactor Building, Turbine Building, and Office Building roof drain systems have potential spatial interaction (leakage/spray) with safety related equipment within these structures.

Reference:

UFSAR Section 9.3.3.2.9

-10CFR54.4(a)(2)

2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10CFR50.48).

The Roof Drains and Overboard Discharge System carries Service Water from the Reactor Building Closed Cooling Water Heat Exchangers which are used to cool the Shutdown Cooling System. The Roof Drains and Overboard Discharge System carries Fire Protection System deluge spray from the M' cellaneous Floor and Equipment Drain System.

Reference:

FSSD Specification SP-1302-06-013 par .2.3.6.6, FHAR D.1.1 and E.3.a, and UFSAR Section 9.3.3.2.9

-1 OCFR54.4(a)(3)

V 3. Receive non-radioactive discharges from building drainage systems and yard drains.

Reference:

UFSAR Section 9.3.3.2.9 and drawing BR 2192 System Intended Functions:

1. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The Roof Drains and Overboard Discharge System carries Emergency Service Water from the Containment Spray Heat Exchangers.

The Roof Drains and Overboard Discharge System carries Service Water from the Reactor Building Closed Cooling Water Heat Exchangers which are used to cool the Spent Fuel Pool Cooling and Augmented Spent Fuel Pool Cooling Heat Exchangers.

The Reactor Building, Turbine Building, and Office Building roof drain systems have potential spatial interaction (leakage/spray) with safety related equipment within these structures.

-10 CFR 54.4(a)(2)

2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The Roof Drains and Overboard Discharge System carries Service Water from the Reactor Building Closed Cooling Water Heat Exchangers which are used to cool the Shutdown Cooling System. The Roof Drains and Overboard Discharge System carries Fire Protection System deluge spray from the Miscellaneous Floor and Equipment Drain System. -10 CFR 54.4(a)(3)

Page 5 of 11 Revision No: 1 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Reactor Building Closed Cooling Water System Part of Auxiliary Systems System Grouping System Functions:

1. Provide primary containment boundary.

The RBCCW System includes Primary Containment isolation valves that close to prevent the release of radioactive contamination through system lines.

References:

UFSAR Section 7.3.1.1.1 and Table 6.2-12 -10CFR54.4(a)(1)

2. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The RBCCW System provides cooling to the Fuel Pool Cooling and Augmented Fuel Pool Cooling Heat Exchangers to ensure that stored fuel is maintained within acceptable temperature limits. The RBCCW System contains non-safety related water filled lines throughout the Primary Containment and the Reactor Building which have spatial interactions (spray or leakage) with safety related SSCs.

References:

UFSAR Section 9.2.2.2 and 9.1.3.1 -1OCFR54.4(a)(2)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (1 OCFR50.48).

The RBCCW System is credited for supporting the Shutdown Cooling System (SDC).

References:

FSSD SpecificatioP-1302-06-013 para. 5.2.3.4.3 and 5.2.3.6.5

-10CFR54.4(a)(3)

4. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Environmental Qualification (10CFR50.49).

The Primary Containment isolation valves within the RBCCW System are Environmentally Qualified.

References:

UFSAR Section 3.11 -1 OCFR54.4(a)(3)

5. Provide inhibited demineralized water to all of the system components at a specified temperature range.

References:

UFSAR Section 9.2.2.2 6. Act as a buffer between radioactively contaminated systems, which it cools, and the Service Water System, which is the heat sink for the RBCCW System.

References:

UFSAR Section 9.2.2.2 System Intended Functions:

1. Provide primary containment boundary.

The RBCCW System includes Primary Containment isolation valves that close to prevent the release of radioactive contamination through system lines. -10 CFR 54.4(a)(1)

2. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The RBCCW System provides cooling to the Fuel Pool Cooling and Augmented Fuel Pool Cooling Heat Exchangers to ensure that stored fuel is maintained within acceptable temperature limits. The RBCCW System contains non-safety related water filled lines throughout the Primary Containment and the Reactor Building which have spatial interactions (spray or leakage) with safety related SSCs. -10 CFR 54.4(a)(2)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The RBCCW System is credited for supporting the Shutdown Cooling System (SDC). -10 CFR 54.4(a)(3)

4. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Environmental Qualification (10 CFR 50.49). The Primary Containment isolation valves within the RBCCW System are Environmentally Qualified.

-10 CFR 54.4(a)(3)

Page B of 12 Revision No: 1 Page 6 of12 Revision No: I Oyster Creek Nuclear Generating Station System and Structure Scoping Form Nitrogen Supply System Part of Auxiliary Systems System Grouping System Functions:

1. Provide primary containment boundary.

The Nitrogen Supply System includes containment isolation devices that function to prevent the release of radioactive contamination through system lines.

References:

UFSAR Section 6.2.5 and Table 6.2-12 -1 OCFR54.4(a)(1)

2. Control combustible gas mixtures in the primary containment atmosphere.

The Nitrogen Supply System supports the Containment Inerting System in accomplishing the function of post LOCA combustible gas control of the primary containment atmosphere.

References:

UFSAR Sections 1.9.21, 3.1.37, 6.2.5, and NRPP6ER ,Related to Combustible Gas Control System dated 11/18/1992

-10CFR54.4(a)(1)

V 3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (1OCFR50.48).

The Nitrogen Supply System is credited with establishing the inert drywell environment in which a design basis fire cannot occur. The Nitrogen Supply System is not required to function during a fire or survive a fire. The Nitrogen Supply System suports the Containment Inerting System in accomplishing this function.

References:

FHAR, Document N -1746, Revision 12 -1OCFR54.4(a)(3)

4. Provide nitrogen gas to the feedwater heaters for layup.

References:

UFSAR 6.2.5,10.2, and 10.4 5. Provide nitrogen gas to the Traveling In-core Probe (TIP) System for TIP indexing mechanism purge.

References:

UFSAR 6.2.5 and 7.5 6. Provide nitrogen gas during normal power operation to the drywell nitrogen compressors for pneumatically operated drywell valves.

References:

UFSAR 6.2.5 and 9.3.1 7. Provide nitrogen gas to the Control Rod Drive System accumulator nitrogen charging system.

References:

UFSAR 6.2.5 and 4.6 8. Provide nitrogen gas to the Reactor Water Cleanup System recirculating pump surge tank.

References:

UFSAR 6.2.5 and 5.4.8 System Intended Functions:

1. Provide primary containment boundary.

The Nitrogen Supply System includes containment isolation devices that function to prevent the release of radioactive contamination through system lines. -10 CFR 54.4(a)(1)

2. Control combustible gas mixtures in the primary containment atmosphere.

The Nitrogen Supply System supports the Containment Inerting System in accomplishing the function of post LOCA combustible gas control of the primary containment atmosphere.

-10 CFR 54.4(a)(1)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The Nitrogen Supply System is credited with establishing the inert drywell environment in which a design basis fire cannot occur. The Nitrogen Supply System is not required to function during a fire or survive a fire. The Nitrogen Supply System supports the Containment Inerting System in accomplishing this function.

-10 CFR 54.4(a)(3)

Page 6 of 12 Revision No: 1 Page6 of 12 Revision No: 1 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Service Water System Part of Auxiliary Systems System Grouping System Functions:

1. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The SWS ensures that the Spent Fuel Pool Cooling and Augmented Spent Fuel Pool Cooling heat exchangers maintain stored fuel within acceptable limits by providing cooling water to the RBCCW System heat exchangers.

The SWS contains non-safety related water filled lines throughout the Turbine Building which have spatial interactions (spray or leakage) with safety related SSCs.

Reference:

UFSAR Section 9.2.1.1 and 9.1.3.1 -10CFR54.4(a)(2)

2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10CFR50.48).

The SWS is credited for supporting the Reactor Building Closed Cooling Water (RBCCW) System.

References:

FSSD Specifiatton SP-1302-06-013 para.5.2.3.6.6

-1OCFR54.4(a)(3)

V 3. Maintains the Emergency Service Water (ESW) side of the Containment Spray heat exchangers full to ensure their readiness to perform their emergency function.

References:

UFSAR Section 9.2.1.1 4. Provide alternate, and/or supplementary seawater cooling to the tube side of the two Turbine Building Closed Cooling Water (TBCCW) heat exchangers.

References:

UFSAR Section 9.2.1.1 5. Supplies operating pressure for the Chlorination System Circulating

'Water and Service Water eductors.

References:

Flow Diagram FP SE-5419 sht.. 1 6. Supplies operating pressure for the Turbine Building Closed Cooling Water (TBCCW) heat exchangers water box vacuum priming eductors.

References:

Flow Diagram BR 2005 sht.. 2 System Intended Functions:

1. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

The SWS ensures that the Spent Fuel Pool Cooling and Augmented Spent Fuel Pool Cooling heat exchangers maintain stored fuel within acceptable limits by providing cooling water to the RBCCW System heat exchangers.

The SWS contains non-safety related water filled lines throughout the Turbine Building which have spatial interactions (spray or leakage) with safety related SSCs. -10 CFR 54.4(a)(2)

2. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The SWS is credited for supporting the Reactor Building Closed Cooling Water (RBCCW) System. -10 CFR 54.4(a)(3)

Page 6 of 11 Revision No: 1 Page 6 of II Revision No: 1 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Control Rod Drive System Part of Auxiliary Systems System Grouping System Functions:

1. Introduce negative reactivity to achieve or maintain subcritical reactor condition 10CFR54.4(a)(1) (UFSAR 4.6.2)2. Reactor Coolant Pressure Boundary 10CFR54.4(a)(1) (UFSAR 3.1.48)3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for Fire Protection (10CFR50.48) 10CFR54.4(a)(3) (UFSAR 3.1.15)4. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for Environmental Qualification (10CFR50.49) 10CFR54.4(a)(3) (UFSAR 3.11)5. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance wit the Commission's regulations for Station Black Out (1OCFR50.63) 10CFR54.4(a)(3) (UFSAR 6.3.1 &1 099)6. Provide cooling water flow to Control Rod Drive Mechanisms (UFSAR 3.9.4.1.2)

7. Provide makeup water to the RPV for other than regulated events (UFSAR 15.2.6)8. Provide high pressure, low flow water to the Reactor Head Cooling System (UFSAR 5.4.11)9. Discharge excess flow to the RPV (UFSAR 3.9.4.1.2)

10. Provide high pressure water to the CRDMs for reactivity management (UFSAR 3.9.4.1.2)

11. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

10CFR54.4(a)(2)

System Intended Functions:

1. Introduce negative reactivity to achieve or maintain subcritical reactor condition.

10 CFR 54.4(a)(1)

2. Provide reactor coolant pressure boundary.

10 CFR 54.4(a)(1)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). 10 CFR 54.4(a)(3)

4. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Environmental Qualification (10 CFR 50.49). 10 CFR 54.4(a)(3)

5. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Station Blackout.

(10 CFR 50.63). 10 CFR 54.4(a)(3)

6. Resist non-safety related SSC failure that could prevent satisfactory accomplishment of a safety related function.

10 CFR 54.4(a)(2)

Page 6 of 10 Revision No: 1 Page 6 of to Revision No: 1 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Containment Inerting System Part of Auxiliary Systems System Grouping System Functions:

1. Provide Primary Containment Boundary.

The CIS includes Primary Containment isolation valves that close to prevent the release of radioactive contamination through system lines.

References:

UFSAR Section 6.2.5 and Table 6.2-12 -10CFR54.4(a)(1)

2. Control combustible gas mixtures in the Primary Containment atmosphere.

The CIS is used for post accident combustible gas control of the containment atmosphere.

References:

UFSAR Sections 1.9.21, 3.1.37, and 6.2.5 -10CFR54.4(a)(1)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10CFR50.48).

The CIS is credited with establishing the inert drywell environment in which a design basis fire cannot occur. e 01s is not required to function during a fire or survive a fire.

References:

FHAR, Document No. 990-17>, Revision 12 -10CFR54.4(a)(3)

4. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Environmental Qualification (10CFR50.49).

The limit switches associated with the Primary Containment isolation valves within the CIS are Environmentally Qualified.

References:

UFSAR Section 3.11 -10CFR54.4(a)(3)

System Intended Functions:

1. Provide primary containment boundary.

The CIS includes Primary Containment isolation valves that close to prevent the release of radioactive contamination through system lines. 10 CFR 54.4(a)(1)

2. Control combustible gas mixtures in the primary containment atmosphere.

The CIS is used for post accident combustible gas control of the containment atmosphere.

10 CFR 54.4(a)(1)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The CIS is credited with establishing the inert drywell environment in which a design basis fire cannot occur. The CIS is not required to function during a fire or survive a fire. 10 CFR 54.4(a)(3)

4. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Environmental Qualification (10 CFR 50.49). The limit switches associated with the primary containment isolation valves within the CIS are Environmentally Qualified.

10 CFR 54.4(a)(3)

Page 6 of 1 1 Revision No: 0 Oyster Creek Nuclear Generating Station System and Structure Scoping Form Nitrogen Supply System Part of Auxiliary Systems System Grouping System Functions:

1. Provide primary containment bounda .The Nitrogen Supply System includes containment isolation devices that rrada contae e SAR etion 6.2.5 and Table 6.2-12 -1OCFR54.4(a)(1)

2. Control combustible gas mixtures in the primary containment atmosphere.

The Nitrogen Supply System \supports the Containment Inerting System in accomplishing the function of post LOCA combustible gas control of the primary containment atmosphere.

References:

UFSR-Sections 1.9.21, 3.1.37, 6.2.5, and NRC SER Related to Combustible Gas Control System dated 11/1 V 92 -10CFR54.4(a)(1) rj upon insafety analyse or plant ev uations go orm a fu tion that demonstrates compliance the comm~ti s re g or Firs Poection Cf50.4 ). l e Nili with establishing the inert drywell environment in which a design basis fire cannot occur. The Nitrogen Supply System is not required to function during a fire or survive a fire. The Nitrogen Supply System supports the Containment Inerting System in accomplishing this function.

References:

FHAR, Document No. 990-1746, Revision 12 -1 OCFR54.4(a)(3)

4. Provide nitrogen gas to the feedwater heaters for layup.

References:

UFSAR 6.2.5,10.2, and 10.4 5. Provide nitrogen gas to the Traveling In-core Probe (TIP) System for TIP indexing mechanism purge.

References:

UFSAR 6.2.5 and 7.5 6. Provide nitrogen gas during normal power operation to the drywell nitrogen compressors for pneumatically operated drywell valves.

References:

UFSAR 6.2.5 and 9.3.1 7. Provide nitrogen gas to the Control Rod Drive System accumulator nitrogen charging system.

References:

UFSAR 6.2.5 and 4.6 8. Provide nitrogen gas to the Reactor Water Cleanup System recirculating pump surge tank.

References:

UFSAR 6.2.5 and 5.4.8 System Intended Functions:

1. Provide primary containment boundary.

The Nitrogen Supply System includes containment isolation devices that function to prevent the release of radioactive contamination through system lines. -10 CFR 54.4(a)(1) 2.-Control combustible gas mixtures in the primary containment atmosphere.

The Nitrogen Supply System supports the Containment Inerting System in accomplishing the function of post LOCA combustible gas control of the primary containment atmosphere.

-10 CFR 54.4(a)(1)

3. Relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the commission's regulations for Fire Protection (10 CFR 50.48). The Nitrogen Supply System is credited with establishing the inert drywell environment in which a design basis fire cannot occur. The Nitrogen Supply System is not required to function during a fire or survive a fire. The Nitrogen Supply System supports the Containment Inerting System in accomplishing this function.

-10 CFR 54.4(a)(3)

Page 6 of 11 Revision No: 1 Attachment 3: OC LR Structures Plant Structure Name System CRL Class UFSAR Section UFSAR Name UFSAR Seismic License Renewal Structure Name Number Class containment-StrUctUre 6.2,1.2.2.2, Also Drywell, Vents, Table 3.2- Torus and Drywell and Torus 187 a 1,3.1.12 Penetrations Class I Primary Containment Containment penetrations 244 Q Class I Mechanical Q .Electrical 774 Q Drywell Personnel Airlock 245 Q Structural Steel 103 Reactor Pedestal Biological Shield Wall 1.2.2.2, 3.8.4.1, Table 3.2-1, Reactor Building 153 Q 3.1.12 Reactor Building Class I Reactor Building Spent Fuel Storage Pool 161 Q New Fuel Storage Vault 159 Structural Steel 103 Structural Walls 105 Ladders, handrail, etc.. 106 Control Rod Drive Rebuilding Facility 261 Emergency Generator Emergency Diesel Generator Building 157 Q 1.2.2.2, 3.8.4 Building Class I Emergency Diesel Generator Building Turbine Building 151 1.2.2.2,3.8.4 Turbine Building Class II Turbine Building Turbine Generator Pedestal 152 Control Room(and supporting part of Control Room 191 a 3.1.15 Turbine Building Class I Cable Spreading Room 192 Q l New Cable Spreading Rm & Bridge Encl 193 Q l Switchgear Room 4160V 195 Q ]Battery Room C 197 Q Clean Instrument Shop 173 _1 Attachment 3: OC LR Structures Contaminated Instrument Shop 182 Count Room and TLD Facilities 283 New Radwaste Buildings 155 1.2.2.2, 3.8.4 New Radwaste Building Class 11 New Radwaste Building Old Radwaste Building or Radioactvie Waste Old Radwaste Building 154 1.2.2.2, 3.8.4 Building (original)

Class II Old Radwaste Building Building Foundation 102 _Augmented Off-Gas Building 175 1.2.2.2 Off Gas Building Ventilation Stack 164 Q 1.2.2.2, 3.8.4 Ventilation Stack Class I Ventilation Stack Chlorination Facility Chlorination Facility Intake and Discharge Intake Structure and Canal (Ultimate Intake Structure 168 0 1.2.2.2 Structure Class II Heat Sink)Intake Canal 168 Q 1.2.2.2 Canals 127 ..Component Supports Component Supports Commodity Grou Equipment Supports 101 Piping & Pipe Supports 104 Cable Trays and Supports 772 Q ._ .lConduits and Supports 771 Q HVAC Duct Supports Tube Track & Supports Intake and Discharge Discharge Structure

& Canal 180 1.2.2.2 Structure Class II Discharge Structure and Canal Canals 127 Fire Protection Water Supply Pond 9.5.1.2.3 Fire Pond Dam Fire Pump House 176 9.5.1.2.3 Fire pumphouse Fire Pumphouses 2

Attachment 3: OC LR Structures Fresh water pump house Redundant Fire Prot. Pump house*1 1-Office Building 156 1.2.2.2, 3.8.4 Office Building Class II Office Building Switchgear Room 480V 194 Q Battery Room A&B 196 Q Health Physics & Change Facilities 281 Building Foundation 102 Auxiliary Office Building 160 Other Office Buildings New Office Building 189 Site Administration Building (Rad Pro Building) 165 .Contractor Building Drywell Support Center l Outage Command Center Condensate Transfer Building 171 Condensate Transfer building Chlorination Facility 169 3.8.4 Chlorination Building Class II Heating Boiler Houses 158 3.8.4 Heating Boiler House Class II Heating Boiler House Boiler House .-Heating Boiler House Site Emergency Building 184 3.8.4 Site Emergency Bldg Class II Site Emergency Building Maintenance Buildings Maintenance Building 162 Maintenance Building Eating and Meeting Building 172 Old Machine Shop 180 Material Storage Buildings Machine Shop and Materials Warehouse 163 3.8.4 Storage Building Class II Material Storage Buildings Storage building 166 Level D Storage Area .No Name 3 Attachment 3: OC LR Structures Dilution Structure 170 Dilution Structure Fish Sample Pool Building 183 Fish Sample Pool New Sample Building 185 New Sample Pumphouse Security Structures Security Structures Security Building 178 Personnel Processing Center North Guard House 179 Ballistic Resistant Enclosure (BRE)Guard Sheds Substation 177 ___ Oyster Creek Substation Waste Storage Facility 181 .Low Level Radwaste Facility Expanded Safety System Facility (ESSF) 186 N/A Miscellaneous Yard Yard Areas 3.8.4 Equipment Class II Miscellaneous Yard Structures Storm Sewers & yard drainage 121 Roads and Parking Lois 123 Landscaping 122 Fencing 124 Railroad (spurs only) 125 Site Preparation 110 Utility Trench Transformer foundations

__X _Transmission Towers l H2 Bottle Racks .Tank Foundations Torus Tank Fire Water Storage Tank l Condensate Storage Tank Demineralized Water Storage Tank Fuel Oil Tank Drywell Surge Tank l Turbine Building Dirty Oil Tank 4 Attachment 3: OC LR Structures Underground 126 Duct Banks 773 Manholes Trailers Toilet Instrumentation

& Calibration Trailers Pretreatment/Demin.

Trailers _Package Treatment Plant Outage Command Center _Drywell support Center Respirator Facility 284 Respirator Facility Ambulance Building _ Ambulance Building Monitoring and Change Facility Monitoring and Change Facility RAGEMS Building RAGEMS Building Class II RAGEMS Buildings Heat Exchanger Building Heat Exchanger Buildir Class II Heat Exchanger Building Pretreatment Building 167 3.8.4 Pretreatment Building Class II Pretreatment Facility Exhaust Tunnel ________ _ Ventilation Tunnel Class 11 Exhaust Tunnel_ ___Pipe Tunnel Pipe Tunnel -C s 11_ Pipe Tunnel ___Breathing Air Compressor Bldg 174 __ .________Breathing Air Compressor Building Independent Spent Fuel Storage Independent Spent Fuel Storage Installation 915 A Installation Main Control Panels 611 Q Relay Panels & Cabinets 618 a Q Local Control/Instrument Rack 614 .Remote shutdown and local shutdown panels 615 Q Radwaste Control Room Panels 612 AOG Off-Gas Control Room Panels 613 .Protective Coating 910 A ____--__Fire barriers, Dikes, and Penetrations 814 A 5 Attachment 3: OC LR Structures Building Foundation 102 Structural Steel 103 Structural walls 105 l Ladders, Handrails, stairs, & Miscellaneous 106 Forked River Structures N/A Various 131-148, 188 Microwave Building 159 l Combustion Turbine Building Insulation Piping and Component Insulation Comr Domestic Water Facility Domestic Water Facility 6 Attachment 3: OC LR Structures GALL Group Comments IIB.1 IIB.4 IIIA.2 .IIIA.3 IIIA.3 7 Attachment 3: OC LR Structures

++IIIA.3+/-1-N/A+N/A*1-IIIA.9 1-*1-III A.3+IIIA.6 N/A++III.B+/-+/-+/--4-N/A--I-+IIIA.6+III.A3 8 Attachment 3: OC LR Structures I III.A3 III.A3 N/A III.A3 Contains SR MCC 1A24 and 1B24 N/A N/A N/A Machine Shop N/A 9 Attachment 3: OC LR Structures I N/A N/A N/A N/A N/A N/A Low Level Radwaste Facility N/A Does not exist N/A 10 Attachment 3: OC LR Structures N/A N/A N/A N/A III A3 N/A N/A N/A Structure and anchorage onily ,.Structure and anchorage onlly Structure and anchorage onlly..Structure and anchorage onily+/-I Not a system VIL.G 11 Attachment 3: OC LR Structures Included with buildings Included with buildings or commodies Included with buildings Included with buildings The structures are outside the protected area and are not considered plant structures nodity Group 12