Text

Rev. 1 to Reconciliation of Program & Line Item Differences Between January 2005 Draft NUREG-1801 & September 2005 Revision 1 of NUREG-1801.
	ML060870132
Person / Time
Site:	Oyster Creek
Issue date:	03/24/2006
From:	Getz S; Exelon Corp
To:	; Office of Nuclear Reactor Regulation
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ML060870123	List: ML060870126; ML060870132; ML060870147;
References
	%dam200606, NUREG-1801, TAC MC7624
	Download: ML060870132 (118)
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Exelon Corporation Rev. 1 Sheet 1 of 12 Reconciliation of Program and Line Item Differences Between January 2005 Draft NUREG-1801 and September 2005 Revision I NUREG-1801 Revision 1 Oyster Creek Generating Station License Renewal

Exelon Corporation Rev. 1 Sheet 2 of 12 Approval Page I Prepared by: (Original signed by:) Date: 3/24/2006 S.C. Getz Checked by: (Original signed by:) Date: 3/24/2006 M. A. Miller Approved by: (Original signed by:) Date: 3/24/2006 D. B. Warfel

Rev. 1 Sheet 3 of 12 REVISION

SUMMARY

Rev Required Changes to Achieve Revision 0 N/A (Initial Issue) 1 Added Attachment 7, Evaluation of New Line Items; Revised Sections 1.0, 2.0, 3.0, 4.0, and 6.0 to address evaluation of new line items from September 2005 Revision 1 of NUREG-1 801; Corrected typo in NUREG number in Section 4.0, Program B.1.22; Corrected NPS size wording in Section 4.0, Program B.1.24; Attachment 2.1; Revised Attachment 3 to add detail to the AP-62 discussion 2

3 4

5

Rev. 1 Sheet 4 of 12 TABLE OF CONTENTS Page Approval Page 2.......

Revision Summary .............. 3 Table of Contents 4 1.0 Purpose .......... .5 2.0 Scope ........... 5 3.0 Methodology ........... 6 4.0 Conclusion .......... 8 5.0 References .......... 11 6.0 Attachments .......... 12

Rev. 1 Sheet 5 of 12 1.0 Purpose The Oyster Creek Generating Station License Renewal Application (LRA) was submitted to the NRC on July 22, 2005. The Aging Management Programs and activities contained in the LRA were structured to address the guidance provided in the Draft NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", January 2005. Draft NUREG-18100 references Draft NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report", January 20015.

Subsequently, NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" was published in September 2005, referencing NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report", published September 2005.

The purpose of this document is to identify and reconcile differences between the January 2005 Draft GALL Aging Management Programs and Aging Management Review (AMR) line items used in the Oyster Creek LRA, with those in the September 2005 Revision 1 GALL. Differences that result in required changes to the LRA will be incorporated in updates to the application, in accordance with the requirements of 10 CFR 54.

The Oyster Creek License Renewal Team reviewed the changes to NUREG-1800 and NUREG-1801, utilizing information provided by the NRC in NUREG-1832 and NUREG-1833. The Team first evaluated these changes to determine their applicability to the Oyster Creek LRA, and then evaluated the applicable changes to determine their impact on the Oyster Creek LRA. This review included identification and evaluation of:

Changes and additions to NUREG-1 801 Aging Management Programs Changes to NUREG-1801 Aging Management Review line Items used in the Oyster Creek LRA Deletions of Aging Management Review line items from the Revision 1 NUREG-1801 that had been used in the Oyster Creek LRA Additions of Aging Management Review line items to the Revision I NUREG-1 801 that were not in the January 2005 Draft document and had not been used in the Oyster Creek LRA The specifics of this review and evaluation are presented in Section 2.0, Scope, below. changes determined to be administrative in nature were deemed to not materially affect the contents of the LRA, and were not included in the scope of this document.

2.0 Scope The scope of this document is as follows:

Summarize in tabular form changes or additions to the Aging Management Programs (AMPs) from the September 2005 Revision 1 GALL, with technical assessments of the differences and impact on the Oyster Creek LRA, if any.

a Review new September 2005 Revision 1 GALL AMPs potentially applicable to the Oyster Creek LRA, and evaluate the ability of the AMPs used in the Oyster Creek LRA to satisfy the specifications of the new Revision 1 GALL AMPs.

Evaluate changes to GALL AMR line items found in the September 2005 Revision 1 GALL from those in the January 2005 Draft GALL, and determine whether those changes affect

Rev. 1 Sheet 6 of 12 the Oyster Creek LRA's use of the GALL AMR line items. This activity contains three categories:

1. AMR line items used in the Oyster Creek LRA that require further evaluation in the September 2005 Revision 1 GALL, but did not require further evaluation in the January 2005 Draft GALL

2. AMR line items that were contained in the January 2005 Draft GALL and were used in the Oyster Creek LRA, but have since been deleted from the September 2005 Revision 1 GALL

3. Other AMR line items from the January 2005 Draft GALL used in the Oyster Creek LRA that contain non-administrative differences in the September 2005 Revision 1 GALL

For line items used in the Oyster Creek LRA that invoked plant specific programs which require further evaluation in both the January 2005 Draft GALL and the September 2005 Revision 1 GALL, review the applicable referenced sections in both corresponding versions of NUREG-1800 (SRP) for changes, and determine any impact on the OC LRA.

Review new GALL AMR line items added to the September 2005 Revision 1 GAL.L that were not included in the January 2005 Draft GALL document and consequently were not included in the Oyster Creek LRA, and evaluate for applicability to Oyster Creek.

For line items used in the Oyster Creek LRA that invoked GALL programs (non-plant specific) which required further evaluation in both the January 2005 Draft SRP and September 2005 Revision 1 SRFP, the applicable referenced sections of the SRP were spot-checked for changes to ascertain whether new or revised further evaluations of GALL program results were specified. No changes to the SRP further evaluation sections that required change to Oyster Creek GALL-based aging management programs were noted in the spot-check. It was concluded that changes associated with the .SRP sections concerning further evaluation of GALL programs would be evident during the evaluation of changes to the GALL programs, and any effect on the OC LRA would be identified as part of that review. Consequently, comprehensive review of the SRP sections for further evaluation of CALL programs was not included in the scope of this evaluation.

3.0 Methodology The September 2005 Revision 1 GALL AMPs applicable to the Oyster Creek LRA were reviewed and compared with the January 2005 Draft GALL version. Applicable differences potentially significant to the OC LRA (i.e., did not consist solely of administrative changes) were identified and summarized in the table, along with a technical assessment of the significance of the change, and whether the OC LRA was affected by the change. Reference Attachment 1.

September 2005 Revision 1 GALL included six (6) new AMPs that were not contained in the January 2005 Draft GALL. Two of these new programs, XI.M1 1A, "Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors," and XI.137, "Flux Thimble Tube Inspection," are applicable only to pressurized water reactors and therefore not applicable to Oyster Creek. The remaining four programs, XI.M35, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping," XI.M36, "External Surfaces Monitoring,"

XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Componenis," and XI.lMvI39, "Lubricating Oil Analysis," were evaluated and compared with the corresponding AMPs used in the Oyster Creek LRA. The comparison was made on an element-by-element basis, with resulting conclusions as to the equivalency of the AMP used by the Oyster Creek LRA. These evaluations are found in Attachment 2.

Rev. 1 Sheet 7 of 12 Note: Portions of the Oyster Creek Generating Station License Renewal Application not submitted with the original application on July 22, 2005 (i.e., those concerning the Meteorological Tower and the Forked River Combustion Turbines) were developed using the applicable September 2005 Revision 1 GALL AMPs. Except for Structures Monitoring, the AMPs used for these portions of the LRA do not require reconciliation between the versions in the January 2005 Draft GALL and September 2005 Revision 1 GALL. The Oyster Creek B.1.31 XI.S6 Structures Monitoring Program is used (in lieu of the Revision 1 GALL program External Surfaces Monitoring) for all portions of the Oyster Creek LRA. See Attachment 2.2.

The AMRs defined in Volume 2 of GALL present acceptable methods of managing aging effects.

Each AMR line item from the GALL report identifies the component, material, environment, and aging effect, along with the corresponding aging management program. A unique AMR line item may be used multiple times. The September 2005 Revision 1 GALL incorporated changes to some of the AMR line items. NUREG-1832, "Analysis of Public Comments on the Revised License Renewal Guidance Documents", September 2005, Appendix E, "Aging Management Review Line-Item Comparison" provides a "before and after" presentation of the AMR line items for evaluation.

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

1. AMR line items used in the Oyster Creek LRA that require further evaluation in the September 2005 Revision 1 GALL, but did not require further evaluation in the January 2005 Draft GALL.

Nineteen (19) line items used in the Oyster Creek LRA which did not require further evaluation in the January 2005 Draft GALL, now list a "Yes" in the further evaluation column in the tables found in Volume 2 of the September 2005 Revision 1 GALL. These changes were evaluated for their effect on the OC LRA, if any. The results are included in Attachment 3.

2. AMR line items that were contained in the January 2005 Draft GALL and were used in the Oyster Creek LRA, but have since been deleted from the September 2005 Revision 1 GALL.

Twenty (20) line items used in the Oyster Creek LRA that were included in the January 2005 Draft GALL have been deleted from Volume 2 of the September 2005 Revision 1 GALL. For fifteen (15) of these line items, the GALL Master List addresses the reasoning behind the deletion and lists an equivalent or replacement line item. The twenty line item deletions were evaluated for their effect on the OC LRA, if any. The results are included in Attachment 4.

3. Other AMR line items from the January 2005 Draft GALL used in the Oyster Creek LRA that contain non-administrative differences in the September 2005 Revision I GALL.

Forty-One (41) line items from the January 2005 Draft GALL that were used in the Oyster Creek LRA were identified to have had non-administrative changes made to them in the Seplember 2005 Revision 1 GALL. These line items were not captured in the first category above (i.e.,

"further evaluation" did not change). These changes typically contain a technical difference, e.g.,

address an additional aging effect or invoke a new or different program. These changes were evaluated for their effect on the OC LRA, if any. The results are included in Attachment 5.

Eighteen (18) line items used in the Oyster Creek LRA invoked plant specific programs which require further evaluation in both the January 2005 Draft NUREG-1800 (SRP) and the September 2005 Revision 1 SRP. The applicable referenced sections in both versions of the SRP were reviewed for changes that may have necessitated new evaluations of a plant specific aging

Rev. l Sheet 8 of 12 management program to ensure that aging effects are adequately managed. This review concluded that there were no significant changes to the SRP sections, and that new evaluations were not required. The results are included in Attachment 6.

Eighty-eight (88) line items were added to the September 2005 Revision 1 NUREG-180', that were not included in the January 2005 Draft NUREG-1801. Consequently, these items were not addressed in the Oyster Creek LRA submitted in July 2005. These added AMR line items were reviewed and evaluated for applicability to Oyster Creek. The results are included in Attachment 7.

4.0 Conclusion The following changes to the Oyster Creek LRA aging management programs were required due to reconciliation between the January 2005 draft GALL and the approved September 2005 Revision 1 GALL:

Program B.1.7 (XI.M7) BWR Stress Corrosion Cracking:

The September 2005 Revision 1 GALL program deletes the specific reference to BWRVIP-29 for reactor coolant water chemistry. An exception was taken in the Oyster Creek LRA to BW/RVIP-29 for this program; due to the GALL change, this exception no longer applies.

Program B.1.16 (XI.M23) Inspection of Overhead Heavy Load and Light Load (Relaled to Refueling) Handling Systems:

The September 2005 Revision 1 GALL program deletes specifications for aging management of active components. An exception was taken in the Oyster Creek LRA to tracking the number and magnitude of lifts by the crane. Due to the GALL change, this exception no longer applies.

Program B.1.22 (XI.M30) Fuel Oil Chemistry:

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

The January 2005 Draft did not invoke the Standard Technical Specifications. Oyster Creek has not adopted the Standard Technical Specifications as described in NUREG-1430 through NUREG-143:3; however, the Oyster Creek fuel oil specifications and procedures invoke similar requirements for fiel oil purity and fuel oil testing as described by the Standard Technical Specifications. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

Program B.1.24 (XI.M32) One-Time Inspection:

The September 2005 Revision 1 GALL program states that one-time inspection of Class 1 piping less than or equal to NPS 4 is addressed in Chapter XI.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping. NUREG-1801 aging management program XI.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping will not be used at Oyster Creek. The new Oyster Creek One-Time Inspection aging management program will include the one-time inspection of Class 1 piping less than NPS 4. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

Rev. 1 Sheet 9 of 12 The September 2005 Revision I GALL program specifies the 2001 ASME Section Xl B8PV Code, including the 2002 and 2003 Addenda for Subsections IWB, IWC, and IWD. The current: Oyster Creek ISI Program Plan for the fourth ten-year inspection interval effective from October 15, 2002 through October 14, 2012, approved per 10CFR50.55a, is based on the 1995 ASME Section Xl B&PV Code, including 1996 addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval. While this exception has already been taken in the Oyster Creek LRA for the B.1.1 (Xl.Ml) ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD program, this is a new exception for Oyster Creek program B.1.24 based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

The September 2005 Revision 1 GALL program states that the guidelines of EPRI Repolt 1000701, "Interim Thermal Fatigue Management Guideline (MRP-24)," January 2001 should be used for identifying piping susceptible to potential effects of thermal fatigue. EPRI Report 1000701 recommends specific locations for assessment and/or inspection where cracking and leakage has been identified in nominally stagnant non-isolable piping attached to reactor coolant systems in domestic and similar foreign PWRs. As Oyster Creek is a BWR, these inspection guidelines are not applicable. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

Program B.1.31 (XI.S6) Structures Monitoring Program:

There are no changes for structures; however, Oyster Creek credits the Structures Monitoring Program for managing the aging effects of external surfaces of mechanical components, which are covered by new GALL program XI.M36, External Surfaces:

The September 2005 Revision 1 GALL program XI.M36 states that monitoring of external surfaces of mechanical components is performed every refueling cycle.. Oyster Creek performs this monitoring every 4 years. Technical basis for this exception is provided in Attachment 2.2. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

The September 2005 Revision 1 GALL program specifies monitoring for leakage. The Oyster Creek program will be enhanced to require visual inspection of external surfaces of mechanical steel components that are not covered by other programs for leakage from or onto external surfaces, worn, flaking, or oxide-coated surfaces, corrosion stains on thermal insulation, and protective coating degradation (cracking and flaking). This is a new enhancement based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

Program B.1.36 (XI.E3) Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements:

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

Program B.2.2 (plant-specific) Lubricating Oil Monitoring Activities:

Re\v. I Sheet 10 of 12 The September 2005 Revision 1 GALL added new aging management program XI.M39, Lubricating Oil Analysis, which will not be used at Oyster Creek. The Oyster Creek aging management program B.2.2, Lubricating Oil Monitoring Activities will incorporate the specifications of GALL program XI.M39 with the following exception and enhancement:

The new program in September 2005 GALL specifies that flash point be measured for all lubricating oils. Oyster creek will sample and measure flash point for lubricating oil for diesel engines only.

Justification for this is provided in Attachment 2.4. This is a new exception based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

The Oyster Creek program will be enhanced to include sampling and measurement of flash point of diesel engine lubricating oil to detect contamination of lubricating oil by fuel oil. This is a new enhancement based on the reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

Program B.2.4 (plant-specific) Periodic Inspection of Ventilation Systems:

The September 2005 Revision 1 GALL added new aging management program XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, which will not be used at the Oyster Creek station, but is used for the Forked River Combustion Turbine site. The Oyster Creek aging management program B.2.4, Periodic Inspection of Ventilation Systems incorporates the specifications of GALL program XI.M38, with the exception of inspection of coatings. The Oyster Creek B.2.4 program does not take credit for coatings of internal surfaces, but directly inspects for loss of material. The Oyster Creek program is enhanced to provide specific guidance to inspect for Loss of Material by inspecting for corrosion, rust, pitting or wear, and for Change in Material Properties by inspecting for cracking, perforations, or other damage. These enhancements were part of the Oyster Creek LRA submitted in July 2005, and are not due to reconciliation of this aging management program from the January 2005 draft GALL to the approved September 2005 Revision 1 GALL.

The following change to the Oyster Creek LRA aging management review was required due to reconciliation of changes to line items that did not require further evaluation in the January 2005 draft GALL, but do require further evaluation in the approved September 2005 Revision 1 GALL:

EP-:34 (V.D2-10, 3.2.1) -This line item for stainless steel heat exchanger tubes in treated water, addressing reduction of heat transfer due to fouling, invoked the Water Chemistry program with "No" further evaluation required in the January 2005 draft GALL and has been changed in the September 2005 Revision 1 GALL to Water Chemistry and One-Time Inspection, with "Yes" for evaluation of aging effects. There are 2 instances of this line item being used in the Oyster Creek License Renewal Application, both in the Isolation Condenser system, for heat exchanger tubes, internal and external. The Oyster Creek LRA will add two line items for one-time inspection of the internal and external surfaces of the isolation condenser tube for reduction of heat transfer due to fouling. These are new additions based on the reconciliation of the Oyster Creek LRA between the January 2005 draft GALL and the approved September 2005 Revision 1 GALL.

The following change to the Oyster Creek LRA aging management review was required cue to reconciliation of changes to line items that were not administrative changes:

T-14 (III.A5-13) - Oyster creek will commit to perform monitoring of any leakage from the spent fuel pool liner via the pool leak chase piping.

Rev. 1 Sheet 11 of 12 The following changes to the Oyster Creek LRA aging management review were required due to reconciliation of new line items added to the September 2005 Revision 1 NUREG 1801 document that: were not included in the January 2005 Draft NUREG-1801, and consequently were not addressed in the Oyster Creek LRA submittal:

AP-80 (Revision 1 SRP Item No. 3.3.1-52) - This material and environment combination of copper alloy heat exchanger tubes in closed cooling water with the aging effect and mechanism of red iction of heat transfer due to fouling is addressed in the Oyster Creek LRA submittal with the Closed-Cycle Cooling Water System program (B.1.14) for the shutdown cooling pump seal coolers.

This was invoked by a non-GALL line item, as this aging effect was not in the January 2005 Draft GALL for this component, material, and environment combination. This is in accordance with the requirements of September 2005 Revision 1 GALL for new line item AP-80. In the Oyster Creek LRA submittal, the Emergency Diesel Generator and Auxiliary System brass lube oil cooler and radiator tubes exposed to a closed cooling water environment do not include the Reduction of Heat Transfer aging effect in the Oyster Creek LRA submittal, based on EPRI Mechanical Tools Appendix G. In EPRI Mechanical Tools Appendix G, fouling is not identified as a significant aging effect for copper alloy heat exchangers in a closed cooling water environment. In order for this component to be in accordance with this new GALL line item, its addition to the Emergency Diesel Generator and Auxiliary System AMR is required.

RP-25 (Revision 1 SRP Item No. 3.1.1-14) - The specifications of new line item RP-25 Will be addressed as follows: The aging effect of loss of material due to pitting and crevice corrosion in reactor vessel flanges, nozzles, penetrations, safe ends, vessel shell, heads and welds will be managed though the use of the Water Chemistry and One-Time Inspection programs. The selection of susceptible locations for one-time inspection will be based on severity of conditions, time of service, and lowest design margin.

RP-26 (Revision 1 SRP Item No. 3.1.147) - The specifications of new line item RP-26 will be addressed as follows: The BWR Vessel Internals program (B.1.9) is used in the Oyster Creek LRA for aging management of the reactor vessel internals components. The Oyster Creek LRA credits this program for managing cracking initiation and growth in reactor internal components.

5.0 References

1. Draft NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", January 2005

2. NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants", September 2005

3. Draft NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report", January 2005

4. NUREG-1 801, Revision 1, "Generic Aging Lessons Learned (GALL) Report", September 2005

5. NUREG-1832, "Analysis of Public Comments on the Revised License Renewal Guidance Documents", September 2005

6. NUREG-1833, "Technical Bases for Revision to the License Renewal Guidance DocLments",

October 2005

7. Oyster Creek Generating Station License Renewal Application, July 2005

Rev. 1 Sheet 12 of 12 6.0 Attachments Attachment 1: Table 1 - Oyster Creek License Renewal GALL Program Comparison - January 2005 Draft tc September 2005 Revision 1 Attachment 2: New Aging Management Programs in September 2005 Revision 1 GALL vs.

Corresponding Programs Used in the Oyster Creek LRA Attachment 3: AMR Line Items used in the Oyster Creek LRA for which "Further Evaluation" changed from "No" to "Yes" in the September 2005 Revision 1 GALL Attachment 4: AMR Line Items used in the Oyster Creek LRA which were Deleted from the September 2005 Revision 1 GALL Attachment 5: AMR Line Items used in the Oyster Creek LRA for which Changes in the September 2005 Revision 1 GALL were not solely Administrative Attachment 6: AMR Line Items used in the Oyster Creek LRA which invoke Plant-Specific Programs Requiring Further Evaluation in both the January 2005 Draft and September 2005 Revision I SRP Attachment 7: Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL)

Attachment 1 Table 1 Oyster Creek License Renewal GALL Program Comparison

,January 2005 Draft GALL to September 2005 Revision 1 GALL

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 Comparison of the January Draft and September Revision 1 of NUREG-1801 revealed both editorial and technical revisions, and that 6 new programs were added.

OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

B.1.1 XI.M1 ASME Section 1. Editorial changes. 1. Editorial changes do not affect the No Xi Inservice 2. Clarification of the GALL position on technical assessment performed for Inspection, acceptable date of ASME Code used, Oyster Creek for this program.

Subsections relative to 10CFR50.55a has been 2. Although NUREG-1 801 specifies the 2001 IWB, IWC, provided. edition including the 2002 and 2003 and IWD Addenda of the ASME Section Xi Code, Subsections IWB, [WC, and IWD for inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified. Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

B.1.2 XLI.M2 Water 1. Editorial changes. 1. Editorial changes do not affect the No Chemistry 2. Clarifications have been provided on technical assessment performed for industry document revisions. Oyster Creek for this program.

2. Clarifications provided on industry document revisions do not affect BWRs and, therefore, have no effect on the technical assessment performed for Oyster Creek for this program.

B.1.3 XL.M3 Reactor Head 1. Editorial changes. 1. Editorial changes do not affect the No Closure Studs 2. Clarification of the GALL position on technical assessment performed for acceptable date of ASME Code used, Oyster Creek for this program.

relative to 10CFR50.55a has been 2. Although NUREG-1801 specifies the 2001 provided. edition including the 2002 and 2003 Addenda of the ASME Section Xl Code, Subsections IWB, IWC, and IWD for inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it Is justified. Oyster Creek's current ISI

__ program plan for the fourth ten-year Page 1 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. I OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

inspection interval anproved per 10 CFR 50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

B.1.4 XI.M4 BWR Vessel 1. Editorial changes. 1. Editorial changes do not affect the No IDAttachment 2. Clarification of the GALL position on technical assessment performed for Welds acceptable date of ASME Code used, Oyster Creek for this program.

relative to 10CFR50.55a has been 2. Although NUREG-1801 specifies the 2001 provided. edition including the 2002 and 2003

3. Added the specification that relief Addenda of the ASME Section Xi Code, requests must be submitted and Subsections IWB, IWC, and IWD for approved. inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified. Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

3. No inspection relief has been requested by Oyster Creek.

B.1.5 XI.M5 BWR 1. Editorial changes. 1. Editorial changes do not affect the No Feedwater 2. Clarification of the GALL position on technical assessment performed for Nozzle acceptable date of ASME Code used, Oyster Creek for this program.

relative to 10CFR50.55a has been 2. Although NUREG-1 801 specifies the 2001 provided. edition including the 2002 and 2003 Addenda of the ASME Section Xi Code, Subsections IWB, IWC, and IWD for inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified. Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR IO S1a,is based o'he *,0 1SSi- 6e -utu l_ including 1996 Addenda. The next_120-Page 2 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

month inspection interval for Ovster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

B.1.6 XL.M6 BWR Control 1. Editorial changes. 1. Editorial changes do not affect the No Rod Drive 2. Clarification of the GALL position on technical assessment performed for Return Line acceptable date of ASME Code used, Oyster Creek for this program.

Nozzle relative to 10CFR50.55a has been 2. Although NUREG-1801 specifies the 2001 provided. edition including the 2002 and 2003 Addenda of the ASME Section Xl Code, Subsections IWB, IWC, and IWD for inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified. Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

B.1.7 XL.M7 BWR Stress 1. Editorial changes. 1. Editorial changes do not affect the Yes. An Corrosion 2. The program description and scope of technical assessment performed for exception was Cracking the program was revised to include Oyster Creek for this program. taken in the LRA nickel based alloy components. 2. Nickel based alloy structures and/or to BWRVIP-29

3. The specific reference to BWRVIP-29 for components have been identified in the for program reactor coolant water chemistry control Oyster Creek LRA for the Reactor B.1.7. This was deleted. Pressure Vessel (RP-03, R-04, R-64, R- exception no 68, R-69), Reactor Internals (R-53, R-96), longer applies to and Emergency Service Water System B.1.7.

(AP-16, AP-53) license renewal systems.

The addition of nickel based alloy components to the scope of the BWR Stress Corrosion Cracking program does not affect the programs selected for these components as identified in the Oyster Creek LRA. The only GALL item referenced above invoking the BWR

____ ___ ____ ____ ____ __l_ _S _ I2epte September 2g05 verionf ber2 eptem ber_ 05 of svrsio GALL is3aR6ha of ALLLsLRi8. _ ____ ____ ___

Page 3 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 Oc GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.I GALL item R-68 included the reference to the BWR Stress Corrosion Cracking program in the Draft January 2005 version of GALL. Therefore, this change to XL.M7 has no effect on the Oyster Creek LRA.

3. The specific reference to BWRVIP-29 was deleted from Xl.M7 but the reference to Water Chemistry program XI.M2, which specifies BWRVIP-29, remained.

B.1.8 Xl.M8 BWR 1. Editorial changes. 1. Editorial changes do not affect the No Penetrations 2. Clarification of the GALL position on technical assessment performed for acceptable date of ASME Code used, Oyster Creek for this program.

relative to 10CFR50.55a has been 2. Although NUREG-1801 specifies the 2001 provided. edition including the 2002 and 2003 Addenda of the ASME Section Xl Code, Subsections IWB, IWC, and IWD for inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified. Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

B.1.9 Xl.M9 BWR Vessel 1. Added the specification that for plants 1. No new specifications. OC has already No Internals that have not yet reached a fluence of reached the threshold and has committed 5E+20 threshold for IASCC prior to to these inspection requirements in the POE, that the 5% & 10% inspection LRA.

requirement is to begin once threshold is 2. Although NUREG-1801 specifies the 2001 reached. Additionally, clarification edition including the 2002 and 2003 added that the extent of the examination Addenda of the ASME Section Xl Code, and its frequency would be based on a Subsections IWB, IWC, and IWD for ten percent sample of the total inspection, repair, and replacement, it population, which includes all grid beam allows an applicant to rely on a different and beam-to-beam crevice slots. version of the ASME Code providing it is

2. Clarification of the GALL position on justified. Oyster Creek's current ISI acceptable date of ASME Code used, program plan for the fourth ten-year relative to 10CFR50.55a has been inspection interval, approved per 10 CFR prcided. 50.5, is bascd on tha 199S edtian

. l[__ including 1996 Addenda. The next 120- l Page 4 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. I OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

N/A XI.M10 Boric Acid Program not used at Oyster Creek. N/A No Corrosion N/A XI.M1 1 Nickel-Alloy Program not used at Oyster Creek. N/A No Nozzles and Penetrations N/A Xl.M1 1A Nickel-Alloy Program not used at Oyster Creek. N/A No Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors N/A XI.M12 Thermal Aging Program not used at Oyster Creek. N/A No Embrittlement of Cast Austenitic Stainless Steel (CASS)

B.1.10 XI.M13 Thermal Aging Editorial changes. Editorial changes do not affect the technical No and Neutron assessment performed for Oyster Creek for this Irradiation program.

Embrittlement of Cast Austenitic Stainless Steel (CASS)

N/A - XI.M14 Loose Part Program not used at Oyster Creek. N/A No Monitoring N/A XI.M15 Neutron Noise Program not used at Oyster Creek. N/A No Monitoring N/A XI.M16 PWR Vessel Program not used at Oyster Creek. N/A No Intemals B.1.11 XI.M17 Flow- Editorial Changes. Editorial changes do not affect the technical No Accelerated assessment performed for Oyster Creek for this Corrosion program.

B.i.i Xi.Ms18 Boiting 1. tltornal Changes. 1. Editorial changes do not affect the No Integrity 2. Element 1 - added 'non-safety-related technical assessment performed for Page 5 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No. _ X bolting." Oyster Creek for this Droaram.

a. Added descriptor to 2. No impact.

structural bolting 3. No impact.

b. Added pointer to Xi.M3 for 4. Already included - No Impact.

reactor head closure bolts. 5. Already included - No Impact.

c. Added reference to 1995 6. Already included - No Impact.

edition of ASME Code 7. No impact.

Section Xi.

3. Element 2 - deleted reference to 'Hot Torquing'. Added reference to EPRI documents for maintenance practices

4. Element 3 - Added additional monitoring for safety related pressure retaining components such as leakage and loss of prestress

a. Added loss of material and cracking to high strength bolts.

5. Element 4 - Removed reference to Section Xl 1995 edition through 1996 addenda and added 'endorsed in 10CFR50.55a(b)(2).

a. Added reference to Category

'D-B" and 'Class 3".

b. For high strength structural bolting added reference to stress corrosion cracking (SCC).

6. Element 7 - Dropped reference to Repair.

a. For NSSS component support bolting added replacement IAW EPRI NP-5769

7. Element 10 -Added statement about downcomer tee-quencher bolting and reactor building closed cooling system bolting leakage.

N/A XI.M19 Steam Program not used at Oyster Creek. N/A No Generator Tube Integrity B.1.13 XLI.M20 Open-Cycle Added elastomers to the list of items The elastomers identified in the ESW and SW No Cooling Water periodically inspected, monitored, or tested. systems that are exposed to Raw Water-Salt System Water are periodically inspected as part of the Pet^d!c !nSpect!Lc Pr--a~ to 2.S'.

B.1.14 I XI.M21 CClosed-Cycle I 1. Editorial changes. 1. Editorial changes do not affect the_l _No_ l Page 6 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

Cooling Water 2. Added SCC as an aging mechanism to technical assessment performed for System be managed by the Program. Oyster Creek for this program.

3. In 'Monitoring and Trending' added 2. Oyster Creek chemistry control and heat

'Tests to evaluate heat removal exchanger design precludes cracking.

capability of the system and degradation 3. The CCCW program performs internal of system components may also be inspections and other tests to evaluate used' AND 'internal inspections' to heat removal capability.

demonstrate system operability and 4. No technical impact as a result of the confirm the effectiveness of the removal of the reference. The exception program. taken in the LRA still applies to the

4. Deleted the specification to comply program.

specifically with TR-1 07306.

B.1.15 XL.M22 Boraflex Editorial changes. Editorial changes do not affect the technical No Monitoring assessment performed for Oyster Creek for this program.

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

Description:

'These cranes comply with long-lived criterion for components and number and Load (Related the Maintenance Rule requirements commodities within the scope of this program. magnitude of lifts to Refueling) provided in 10 CFR 50.65. The Nuclear An exception had been taken to Item 2. in the by the crane is Handling Regulatory Commission Regulatory OC LRA; the number and magnitude of lifts by no longer Systems Guide (RG) 1.160 provides guidance for the crane are not tracked. Due to the GALL applicable.

monitoring the effectiveness of change, this exception is no longer required.

maintenance at nuclear power plants."

2. Deleted from Parameters Monitored/Inspected: 'The number and magnitude of lifts made by the crane are also reviewed."

3. Deleted from Detection of Aging Effect:

'Functional tests are also performed to assure their integrity."

4. Deleted from Acceptance Criteria: "EOCI Specification #61 (or later revisions),"

5. Deleted from Operating Experience:

'Because of the requirements for monitoring the effectiveness of maintenance at nuclear power plants provided in 10 CFR 50.65" B.1.17 XI.M24 Compressed Added an emphasis on stainless steel The Oyster Creek program precludes aging No Air Monitoring components. effects on all component materials.

B.1.18 XL.M25 BWR Reactor 1. Editorial changes. 1. Editorial changes do not affect the No Water 2. Clarification of the GALL position on technical assessment performed for Cleanup acceptable date of ASME Code used, Oyster Creek for this program.

System relative to 10CFR50.55a has been 2. Although NUREG-1801 specifies the 2001 prvl eUd.LI i-iiAudiy iitis 2002 arnd 2003 Addenda of the ASME Section Xl Code. I _I Page 7 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

Subsections IWB. IWC. and IWD for inspection, repair, and replacement, it allows an applicant to rely on a different version of the ASME Code providing it is justified. Oyster Creek's current ISI program plan for the fourth ten-year inspection interval, approved per 10 CFR 50.55a, is based on the 1995 edition including 1996 Addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

B.1.19 XI.M26 Fire Protection 1. Editorial changes 1. Editorial changes do not affect the No

2. Added specification that visual technical assessment performed for inspections be performed by "fire Oyster Creek for this program.

protection qualified inspectors' 2. No significant effect - OC uses qualified

3. Deleted specifications for VT-iNT-3 or personnel for these inspections equivalent inspections 3. No significant effect.

4. Deleted GALL industry OE discussion 4. No effect on LRA.

that said no corrosion-related problems have been reported for the fuel supply line, pump casing of diesel fire pump, or halon C02 systems, and no aging-related problems found with fire protection systems, emergency breathing and auxiliary equipment, and communication equipment.

B.1.20 XLI.M27 Fire Water 1. Added specific reference to the edition 1. Change is not technically significant. No System of NFPA 25 used, as well as the specific 2. Change is not technically significant.

sections. 3. Change is not technically significant.

2. Flow testing specifications are less prescriptive.

3. Monitoring and trending is now 'as specified by the associated plant commitments pertaining to NFPA codes and standards".

N/A XI.M28 Buried Piping Program not used at Oyster Creek. N/A No and Tanks Surveillance B.1.21 XI.M29 Aboveground Editorial changes. Editorial changes do not affect the technical No Steel Tanks assessment performed for Oyster Creek for this B.1.22 l XI.M30 Fuel Oil l 1. NUREG-1 801 states in XI.M30 that the 1. Oyster Creek has not adopted the Yes. This is a Page 8 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. I OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No. l Chemistry fuel oil aging management program is in Standard Technical Specifications as new exception part based on the fuel oil purity and described in these NUREG's, however, (item 1).

testing requirements of the plant's the Oyster Creek fuel oil specifications Technical Specifications that are based and procedures invoke similar on the Standard Technical requirements for fuel oil purity and fuel oil Specifications of NUREG-1430 through testing as described by the Standard NUREG-1433. The January 2005 Draft Technical Specifications. These include did not invoke the Standard Technical testing requirements for new fuel oil (API Specifications. gravity, kinematic viscosity, water and

2. A new standard is invoked for fuel oil, sediment) prior to adding the new fuel to ASTM D6217, as an acceptable the storage tank to ensure that the oil has alternative to ASTM D2276 for not been contaminated with substances particulate. that would have an immediate detrimental impact on diesel engine combustion, and, testing of new fuel after adding it to the storage tank to confirm that the remaining fuel oil properties are within specification requirements. Oyster Creek fuel oil activities also provide for the trending of particulate contamination in new and stored fuel oil. Water and Sediment is drained periodically (quarterly) from the Emergency Diesel Generator Fuel Storage Tank. This periodicity exceeds the Standard Technical Specifications requirements of "once every [31] days",

however, it is aligned with the requirements of Regulatory Guide 1.137 which states that a quarterly basis is sufficient unless accumulated condensation is suspected (in which case a monthly basis is appropriate).

2. Fuel oil will be routinely sampled and analyzed for particulate contamination in accordance with modified ASTM Standard D 2276-00, Method A. The alternative methods of ASTM D 6217 will not be used.

B.1.23 XL.M31 Reactor 1. Only untested capsules must be 1. Change is not technically significant. No Vessel - maintained for future use. 2. Change is not technically significant.

Surveillance 2. Deleted specification that changes to

_ storage requirements must be approved by the NRC.

B.1.24 XL.M32 One-Time 1. Excludes Class 1 piping less than or 1. (a) NUREG-1 801 states in XL.M32 that Yes. These are Inspection equal to NPS 4 in favor of new M35 one-time inspection of Class I piping less new exceptions Prgrrn. hnor~ *1 S..vffa' to NP4isadd e S s e e diie,. %

2.-

De lI

____ _______2. Deleted specification tthat iseto inspection be [ I-Chapter Chapter XI.M35, On

- , Time Inspt of One Time inspection of lo asod d

a dcument Page 9 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC [ GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No. . ._._______ ___ I.___._

_I____ _._.

in strict accordance with App B. instead ASME Code Class 1 Small Bore-Piping. Reconciliation of permitting 'qualified" personnel to follow NUREG-1801 aging management Program and

.procedures' consistent with it. program XL.M35, One Time Inspection of Line Item

3. Now permits 'equivalent' VT. ASME Code Class I Small Bore-Piping Differences inspections. will not be used at Oyster Creek. The new Between January

4. Added a clear specification that Oyster Creek One-Time Inspection aging 2005 Draft inspections occur no earlier than 10 management program will include the NUREG-1801 years before the PEO. one-time inspection of Class 1 piping less and September

5. Deleted provision for remote visual than or equal to NPS 4. 2005 NUREG-inspections. (b) NUREG-1 801 specifies (in Xl.M1, 1801 Revision V,

6. Included new guidelines for establishing XI.M32, and XI.M35) the 2001 ASME Attachment 2.

sample sizes, such as materials of Section Xl B&PV Code, including the fabrication, environment, plausible aging 2002 and 2003 Addenda for Subsections effects, and operating experience. IWB, IWC, and IWD. The current Oyster Creek ISI Program Plan for the fourth ten-year inspection interval effective from October 15, 2002 through October 14, 2012, approved per 10CFR50.55a, is based on the 1995 ASME Section Xl B&PV Code, including 1996 addenda.

The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

(c) NUREG-1801 states in XL.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping, that the guidelines of EPRI Report 1000701, Interim Thermal Fatigue Management Guideline (MRP-24),' January 2001 should be used for identifying piping susceptible to potential effects of thermal fatigue. EPRI Report 1000701 recommends specific locations for assessment and/or inspection where cracking and leakage has been identified in nominally stagnant non-isolable piping attached to reactor coolant systems in domestic and similar foreign PWRs. As Oyster Creek is a BWR, these inspection guidelines are not applicable.

(d) See also document'Reconciliation of Program and Line Item Differences Between January 2005 Draft NUREG-iRni qnel zPntrnmher gnn5 N1IJRFr-1Rni I I Revision 1", Attachment 2.

Page 10 of 17

Oyster Creek License Renewal Attachment I Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No. io

_revious

2. This is less restrictive than the specification for inspection quality.

3. One-Time inspections for Oyster Creek will consist of volumetric examinations.

4. Oyster Creek is already within 10 years of the PEO (2009).

5. Remote visual inspections are not planned for One-Time inspections.

6. The One-Time Inspection Sample Basis Document addresses the following:

(a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection locations in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of aging if age-related degradation is found that could jeopardize an intended function before the end of the period of extended operation.

B.1.25 XI.M33 Selective 1. Editorial changes. 1. Editorial changes do not affect the No Leaching of 2. Added visual inspections to discussion technical assessment performed for Materials of inspection techniques. Oyster Creek for this program.

2. No technical effect. Visual examinations were already included in other program elements.

B.1.26 XI.M34 Buried Piping 1. Added that gray cast iron should be (1-3) No technical effect. These differences No and Tanks managed under Chapter XI.M33, are already addressed in the LRA.

Inspection 'Selective Leaching of Materials.'

2. New specification that opportunistic inspections be performed in highly susceptible areas or those with a history of corrosion.

3. Verification will now be required that at least one focused or opportunistic inspection in historically or suspected to be susceptible areas was performed prior to the PEO but within the past 10 NIA XL.M35 One-time JNew Program, not applicable to OC. l See One-Time Inspection program B.1.24 Yes. See One- l Page 11 of 17

Oyster Creek License Renewal Attachment I Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA impacted Progra m No.I Inspection of [Specifications incorporated into One-Time (XI.M32). Time Ininprtion ASME Code Inspection.] program B.1.24 Class 1 Small (XI.M32).

Bore-Pipin q N/A XL.M36 Extemal New Program. Program not used at Oyster See Structures Monitoring Program B.1.31 Yes. See Surfaces Creek. [Specifications incorporated into (XI.S6). Structures Monitoring Structures Monitoring Program] Monitoring Program B.1.31 (XI.S6).

N/A XI.M37 Flux Thimble New Program. Program not used at Oyster N/A No Tube Creek.

Inspection N/A XL.M38 Inspection of New Program. Program not used at Oyster See Periodic Inspection of Ventilation Systems Yes. See Intemal Creek. [Specifications incorporated into B.2.4. Periodic Surfaces in Periodic Inspection of Ventilation Systems] Inspection of Miscellaneous Ventilation Piping and Systems B.2.4.

Ducting I_ Components N/A XI.M39 Lubricating Oil New Program. Program not used at Oyster See Lubricating Oil Monitoring Activities Yes. See Analysis Creek. [Specifications incorporated into program B.2.2. Lubricating Oil Lubricating Oil Monitoring Activities program.] Monitoring Activities

._ program B.2.2.

B.1.27 XI.S1 ASME Section No changes. N/A No XI, Subsection IWE N/A XI.S2 ASME Section Program not used at Oyster Creek. N/A No Xl, Subsection IWL B.1.28 XI.S3 ASME Section No changes. N/A No Xl, Subsection IWF .

B.1.29 XI.S4 10 CFR 50 No changes. N/A No Part 50, Appendix J B.1.30 Xl.S5 Masonry Wall No changes. N/A No Program B.1.31 XI.S6 Structures There are no changes for structures. 1. Oyster Creek takes exception to the Yes Monitoring However, Oyster Creek credits the Structures frequency of every refueling cycle Program Monitoring Program for managing aging specified in Xl.M36. Technical basis for effects of external surfaces of mechanical the exception is, components, which are covered by new a) The frequency of 4 years specified for GALL Program Xl.M36, Extemal Surfaces. monitoring of exterior surfaces of

1. Monitoring of extemal surfaces of mechanical components is consistent with mecnanical components under the the frequency specified for exterior Oyster Creek Structures Monitoring j surfaces of supporting structures. The 4-Page 12 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC 1GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra .

m No. __ I _____ __

Program is every 4 years: whereas year frequency is consistent with indiistrv XI.M36 is every refueling cycle. guidelines and has proven effective in

2. XI.M36 also specifies monitoring for detecting loss of material due to corrosion, leakage and the Structures Monitoring and change in material properties of does not. structural elastomer on exterior surfaces of structures. Consequently this frequency will also be effective for detecting loss of material and change in material properties on exterior surfaces of mechanical components before an intended function is impacted.

b) Industry and plant-specific operating experience review has not identified any instances of significant loss of material or change in material properties of external surfaces of mechanical components subject to indoor air environment.

c) Mechanical components subject to outdoor air are constructed from stainless steel, aluminum, which are not susceptible to accelerated corrosion, or carbon steel components protected by protective coatings such as galvanizing, or painting.

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

d) Studies by EPRI (

Reference:

TR-103840, fig. 4.1-1) provides corrosion rate curve for carbon steels. This curve was constructed from 55 individual tests representing at least five different steels and six different test locations and environments. The curve shows 0.926 mils per year thickness loss during the first 1 1/2 years, decreasing to 0.21 mils per year after 15 1/2years. EPRI also conducted corrosion tests of ASTM A-36 structural steel at four nuclear plants located in Elma and Richland, Washington; and Midland, Michigan. The tests were conducted for up to 24 months.

EPs!ulsntude corsonated d is 0.o tcse results the corrosion rate is 0.5 mils Der Page 13 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. I OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

_ tear. If the corrosion rate is conservatively taken as 0.926 mils per year, then the loss of material projected for 4 years is less than 4 mils. This loss of material is insignificant and will not impact the intended function of mechanical components.

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

See also document Reconciliation of Program and Line Item Differences Between January 2005 Draft NUREG-1801 and September 2005 NUREG-1801 Revision 1', Attachment 2.

B.1.32 Xi.S7 RG 1.127, No changes. N/A No Inspection of Water-Control Structures Associated with Nuclear Power Plants B.1.33 XL.S8 Protective 1. Editorial changes. 1. Editorial changes do not affect the No Coating 2. Added 'or during the general visual technical assessment performed for Monitoring inspection' to element 4 to allow the Oyster Creek for this program.

and thorough inspections to be done during 2. Minor clarification. It really makes no Maintenance the general visual inspection as opposed difference whether the thorough Program to afterwards. inspections are done during the general

3. ASTM D 5163-05 has replaced GALL inspection or as a different activity after References to ASTM D 5163-96. the general inspections.

3. No impact since the Oyster Creek response to GL 98-04 is the program that is used to satisfy the requirement for 'an acceptable coatings maintenance aging management program (AMP) for license renewal' as identified in the 'Program Description" paragraph of NUREG-1801 Chapter Xl program XI.S8, Protective l l~UI lv4 e U IVIdCTI itIV 01 11I l lI.td l l

___________ rogrm. Te Oyster Creek commnitmens________

Page 14 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. I OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No.

from the GL 98-04 response do not include ASTM D 5163 so this change is not relevant.

B.1.34 XL.E1 Electrical Editorial changes. Editorial changes do not affect the technical No Cables and assessment performed for Oyster Creek for this Connections program.

not Subject to 10 CFR 50.49 Environmental Qualification Requirements B.1.35 XL.E2 Electrical Editorial changes. Editorial changes do not affect the technical No Cables and assessment performed for Oyster Creek for this Connections program.

not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentatio n Circuits B.1.36 XI.E3 Inaccessible 1. Editorial changes. , 1. Editorial changes do not affect the Yes Medium- 2. The previous versions of GALL did not technical assessment performed for Revision required Voltage define medium voltage. The September Oyster Creek for this program. to reflect the Cables not 2005 revision to GALL defines medium 2. OC is planning to include both 13.8 and inclusion of 34.5 Subject to 10 voltage as 2kV - 35kV. OC's LRA 34.5kV cables in its existing cable test kV cables.

CFR 50.49 submitted a B.1.36 program that program, that currently only includes 2.4 Environmental included 2.4 and 4.16kV cables. This and 4.16kV cables.

Qualification scope was expanded to include 13.8kV Requirements cables with the 10/12/05 RAI response for the Forked River Combustion Turbine.

N/A XI.E4 Metal Program not used at Oyster Creek. N/A No Enclosed Bus N/A Xi.E5 Fuse Holders Program not used at Oyster Creek. N/A No N/A XL.E6 Electrical Program not used at Oyster Creek. N/A No Cable Connections not Subject to 10 CFR 50.49 Environmental Qualification Requirements B.2.2 N/A Lubricating Oil Plant specific program that incorporates the See document 'Reconciliation of Program and Yes. See ili pe i'iuivi vurGALL puwyiau XiJ.39 Lie itemrDirferences Between January 2005 document l I l ciiis lLbiaigi~ayi.lDraft NUREG-1801 and September 005 - Reconciliation ofl Page 15 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra m No. _

NUREG-1801 Revision 1", Attachment 2. Program and Line Item Differences Between January 2005 Draft NUREG-1801 and September 2005 NUREG-1801 Revision 1",

Attachment 2.

B.2.4 N/A Periodic Plant specific program that incorporates the See document 'Reconciliation of Program and No. See Inspection of specifications of GALL program XI.M38 Line Item Differences Between January 2005 document Ventilation Inspection of Internal Surfaces in Draft NUREG-1801 and September 2005 'Reconciliation of Systems Miscellaneous Piping and Ducting NUREG-1801 Revision 1-, Attachment 2. Program and Components. Line Item Differences Between January 2005 Draft NUREG-1801 and September 2005 NUREG-1801 Revision 1",

Attachment 2.

B.3.1 X.M1 Metal Fatigue The specification that the minimum list of high The change allows the use of alternative No of Reactor fatigue usage locations include those locations in lieu of those specified in Coolant locations in NUREG/CR-6260 and any NUREG/CR-6260. To address the effects of Pressure additional critical components in the plant the coolant environment on component fatigue Boundary was revised. GALL now specifies high life at Oyster Creek, plant-specific calculations fatigue usage locations to include the have been performed for the locations locations identified in NUREG/CR-6260, as a identified in NUREG/CR-6260 for older-vintage minimum, or proposed alternatives based on GE BWR plants. The six locations are:

plant configuration. 1. Reactor Vessel (Lower Head to Shell Transition)

2. Feedwater Nozzle

3. Recirculation System (SDC Retum Line Tee), including the RPV recirculation inlet and outlet nozzles

4. Core Spray System (Nozzle and Safe End)

5. Isolation Condenser Retum to Shutdown Cooling

6. Limiting Feedwater Line Location These locations are the same as those identified in NUREG/CR-6260, except that the Isolation Condenser Return to Shutdown

__etu ! nt ot .e feed wate system, s eRO r lreturm"to't'he feedwater system, since Oyster II Page 16 of 17

Oyster Creek License Renewal Attachment 1 Rev. 1 GALL Program Comparison - January 2005 Draft to September 2005 Rev. 1 OC GALL AMP AMP Identification of Applicable Differences Technical Assessment of Significance LRA Impacted Progra mnNo.

Creek does not have a RCIC system. The resultant fatigue usage factors from these environmental fatigue analyzes are less than acceptance limits for the period of extended operation; therefore, it was not necessary to analyze additional locations in the RCPB.

N/A X.S1 Concrete Program not used at Oyster Creek. N/A No Containment Tendon Prestress B.3.2 X.E1 Environmental No changes. N/A No Qualification (EQ) of Electrical Components Page 17 of 17

Attachment 2 New Aging Management Programs in September 2005 Revision 1 GALL Vs.

Corresponding Programs Used in the Oyster Creek LRA .1 OC LRA Use of B.1.24 XI.M32 One-Time Inspection program vs. XL.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping program .2 OC LRA Use of B.1.31 XI.S6 Structures Monitoring Program vs. XL.M36 External Surfaces Monitoring program .3 OC LRA Use of B.2.04 Periodic Inspection of Ventilation Systems program vs. XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program .4 OC LRA Use of B.2.2 Lubricating Oil Monitoring Activities program vs. XI.M39 Lubricating Oil Analysis program

Rev.1 Attachment 2.1 OC LRA Use of B.1.24 XI.M32 ONE-TIME INSPECTION Program vs. XI.M35 ONE-TIME INSPECTION OF ASME CODE CLASS 1 SMALL-BORE PIPING PROGRAM Program

Description:

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

Summary of Exceptions to NUREG-1801:

The Oyster Creek One-Time Inspection aging management program B.1.24 will include the one-time inspection of Class 1 piping less than NPS 4.

NUREG-1801 references in XI.M35 the 2001 ASME Section Xl B&PV Code, including the 2002 and 2003 Addenda for Subsections IWB, IWC, and IWD. The current Oyster Creek ISI Program Plan for the fourth ten-year inspection interval effective from October 15, 2002 through October 14, 2012, approved per 1OC:FR50.55a, is based on the 1995 ASME Section Xl B&PV Code, including 1996 addenda. The next 120-month inspection interval for Oyster Creek will incorporate the requirements specified in the version of the ASME Code incorporated into 10 CFR 50.55a twelve months before the start of the inspection interval.

NUREG-1801 states in XI.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping, that the guidelines of EPRI Report 1000701, "Interim Thermal Fatigue Management Guideline (MRP-24)," January 2001 should be used for identifying piping susceptible to potential effects of thermal fatigue. EPRI Report 1000701 recommends specific locations for assessment and/or inspection where cracking and leakage has been identified in nominally stagnant non-isolable piping attached to reactor coolant systems in domestic and similar foreign PWRs.

As Oyster Creek is a BWR, these inspection guidelines are not applicable.

1. Scope of Program:

The Oyster Creek One-Time Inspection aging management program will confirm that cracking initiation and growth due to stress corrosion cracking (SCC),

intergranular stress corrosion cracking (IGSCC), or thermal and mechanical loading is not occurring in Class 1 piping less than four-inch NPS, and includes measures to verify that unacceptable degradation is not occurring, thereby validating the effectiveness of existing aging management programs or confirming that there is no need to manage aging-related degradation for the period of extended operation.

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Rev. 1 l Attachment 2.1 Systems in the scope of the One-Time Inspection program for ASME Code Class 1 Small-Bore Piping Include:

Class 1 Piping Less

Control Rod Drive Crack Initiation than 4 inch in diameter System and Growth NPS

Core Spray System

Feedwater System

Isolation Condenser System

Main Steam System

Nuclear Boiler Instrumentation

Post-Accident Sampling System

Reactor Head Cooling System

Reactor Recirculation System

Reactor Water Cleanup System

Shutdown Cooling System

Standby Liquid Control System (Liquid Poison System)

Result: This element of the Oyster Creek XL.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping, with the exceptions identified above.

2. Preventive Actions:

The Oyster Creek One-Time Inspection aging management program is an inspection program to provide assurance that aging that has not yet manifested itself is not occurring, or that the evidence of aging shows that the aging is so insignificant that an aging management program is not warranted for Class 1 piping less than NPS 4.

Result: This element of the Oyster Creek XL.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XL.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping, with the exceptions identified above.

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Rev. I Attachment 2.1

3. Parameters Monitored/Inspected:

To confirm crack initiation and growth is not occurring in Class 1 piping with a diameter less than NPS 4, the One-Time Inspection program will utilize volumetric examination to inspect areas susceptible to stress corrosion cracking, intergranular stress corrosion cracking, or thermal and mechanical loading.

Result: This element of the Oyster Creek XI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping, with the exceptions identified above.

4. Detection of Aging Effects:

To confirm crack initiation and growth is not occurring in Class 1 piping with a diameter less than NPS 4, the One-Time Inspection program will inspect areas susceptible to stress corrosion cracking, intergranular stress corrosion cracking, or thermal and mechanical loading.

Result: This element of the Oyster CreekXI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping, with the exceptions identified above.

5. Monitoring and Trending:

The One-Time Inspection aging managemnent program provides for the evaluation of the need for follow-up examinations and increased inspection sample size to monitor the progression of aging if age-related degradation is found that could jeopardize an intended function before the end of the period of extended operation. The determination of the sample size of ASME Code Class 1 small-bore piping will be based on susceptibility, inspectability, dose considerations, and operating experience. Should aging effects be detected, the corrective action program triggers actions to characterize the nature and extent of the aging effect and determines what subsequent monitoring is needed to ensure intended functions are maintained during the period of extended operation.

Result: This element of the Oyster Creek XL.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping, with the exceptions identified above.

6. Acceptance Criteria:

For Class 1 piping, the Oyster Creek program directs evaluation of examination results in accordance with the 1995 ASME Section Xl Code, 1996 addenda.

Examination results are evaluated in accordance with IWB-3131 by comparing the results with the acceptance standards of IWB-3400. Additional examinations are performed in accordance with IWB-2430.

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Rev. 1 Attachment 2.1 Result: This element of the Oyster Creek XL.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping, with the exceptions identified above.

7. Corrective Actions:

Evaluations will be performed for inspection results that do not satisfy established criteria and a Issue Report (IR) will be initiated to document the concern in accordance with the Oyster Creek 10 CFR Part 50, Appendix B corrective action program. The 10 CFR Part 50, Appendix B corrective action program ensures that the conditions adverse to quality are promptly corrected. If the deficiency is assessed to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude repetition.

Result: This element of the Oyster Creek XL.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XL.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping.

8. Confirmation Process:

See Item 7 above.

Result: This element of the Oyster Creek XL.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class I Small-Bore Piping.

9. Administrative Controls:

See item 7 above.

Result: This element of the Oyster Creek XI.M32 One-Time Inspection aging managementprogram is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping.

10. Operating Experience:

For objective evidence of the effectiveness of the ASME Section Xl program (e.g., scope of the inspections and inspection techniques), see Program Basis Document PBD-AMP-B.1.01, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD."

Result.: This element of the Oyster CreekXI.M32 One-Time Inspection aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping.

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Rev. 1 Attachment 2.2 OC LRA Use of B.1.31 XI.S6 STRUCTURES MONITORING Program vs.

XI.M36 EXTERNAL SURFACES MONITORING Program Program

Description:

The NUREG-1801, Revision 1 aging management program XI.M36, External Surfaces Monitoring will not be used at Oyster Creek. The Oyster Creek XI.S6 Structures Monitoring aging management program B.1.31 will be enhanced to include the specifications of NUREG-1801 Rev. 1 XI.M36, Exterior Surfaces Monitoring. The specifications of this new AMP apply to exterior surfaces of mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site that have been determined to be in scope of license renewal and are not covered by other programs.

Exception to NUREG-1801:

The program takes exception to the frequency specified in NUREG-1801 Rev. 1 XI.M36, External Surfaces Monitoring, for monitoring external surfaces of Oyster Creek and FRCT mechanical components. The frequency specified by Oyster Creek Structures Monitoring Program is every 4 years; whereas the frequency specified in XI.M36 is at least once per refueling cycle. Technical basis for this exception is that, based on plant specific operating experience and industry experience, the 4-year frequency is adequate to provide reasonable assurance that aging effects will be detected and corrected before a loss of an intended function. See the discussion of this technical basis in Section 4, Detection of Aging Effects.

The Oyster Creek Structures Monitoring Program implementing procedure will be enhanced to incorporate the specifications of the NUREG-1801 Rev. 1 XI.M36, Exterior Surfaces Monitoring program as follows:

The program will be enhanced to require visual inspection of external surfaces of mechanical steel components that are not covered by other programs for leakage from or onto external surfaces; worn, flaking, or oxide-coated surfaces; corrosion stains on thermal insulation, and protective coating degradation (cracking and flaking). These enhanced requirements are applicable to mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site.

1. Scope of ProQram:

In order to include the specifications of the XI.M36 External Surfaces Monitoring program, the scope of the OC Structures Monitoring Program will be enhanced to include inspection of exterior surfaces of mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site that are not covered by other programs, including exterior surfaces of HVAC ducts, damper housings and duct closure bolting within the scope of license renewal. Components that will be added to scope of the program include piping components, valves, tanks, vessels, etc. located in indoor or outdoor air environments. The scope of the Page 1 of 5

Rev. 1 Attachment 2.2 program is limited to components whose exterior surfaces are not monitored by other programs such as ASME Section XI, ISI Programs and fire protection activities.

Result. This element of the Oyster CreekXl.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XL.M36 External Surfaces Monitoring, with the exception and enhancement identified above.

2. Preventive Actions:

The program specifies no preventive actions. The program is a condition monitoring program that utilizes inspections to identify aging effects prior to loss of intended function.

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

3. Parameters Monitored/inspected:

The enhanced Oyster Creek Structures Monitoring Program contains sufficient detail on parameters monitored or inspected to conclude with reasonable assurance that the XL.M36 External Surfaces Monitoring Program attributes are satisfied. The program will be enhanced to require visual inspection of external surfaces of mechanical components that are not covered by other programs for leakage from or onto external surfaces; worn, flaking, or oxide-coated surfaces; corrosion stains on thermal insulation; and protective coating degradation (cracking and flaking). These enhanced requirements are applicable to mechanical components of Oyster Creek, Forked River Combustion Turbine (FRCT), and the radio communications system located at the meteorological tower site.

Result: This element of the Oyster Creek XL.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring, with the exception and enhancement identified above.

4. Detection of Aging Effects:

The OC Structures Monitoring Program requires monitoring of each structure/aging effects by qualified individuals every 4 years to ensure age related degradations would be detected and quantified before there is a loss of intended function.

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

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Rev. 1 Attachment 2.2 Inspection methods, inspection schedule, and inspector qualification are consistent with industry guidelines and NRC guidance for implementing the requirements of 10 CFR 50.65, the Maintenance Rule. Inspection methods consist of visual inspections conducted on a frequency of every 4 years in accessible areas of the plant. The program contains provisions for more frequent inspections to ensure that observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process. Inaccessible areas, such as buried structures are inspected when they become uncovered. External surfaces of Oyster Creek and FRCT mechanical components, including HVAC ducts, damper housings, and bolting will be inspected on a frequency of every 4 years consistent with inspection frequency for structures. This constitutes an exception to NUREG-1801 Rev. 1 AMP XI.M36, External Surfaces Monitoring, which specifies these inspections be performed at least once per refueling outage. Technical basis for this exception is as follows:

The frequency of 4 years specified for monitoring of exterior surfaces of mechanical components is consistent with the frequency specified for exterior surfaces of supporting structures. The 4-year frequency is consistent with industry guidelines and has proven effective in detecting loss of material due to corrosion, and change in material properties of structural elastomer on exterior surfaces of structures. Consequently this frequency will also be effective for detecting loss of material and change in material properties on exterior surfaces of mechanical components before an intended function is impacted.

Industry and plant-specific operating experience review has not identified any instances of significant loss of material or change in material properties of external surfaces of mechanical components subject to indoor air environment (see section 10 below).

Mechanical components subject to outdoor air are constructed from stainless steel and aluminum, which are not susceptible to accelerated corrosion, or carbon steel components protected by protective coatings such as galvanizing or painting. Plant operating experience indicates that monitoring of exterior surfaces of components made of these materials and protective coatings on a frequency of 4 years provides reasonable assurance that loss of material will be detected before an intended function is affected.

Studies by EPRI provide corrosion rate curve for carbon steels. This curve was constructed from 55 individual tests representing at least five different steels and six different test locations and environments. The curve shows 0.926 mils per year thickness loss during the first 1 1/2 years, decreasing to 0.21 mils per year after 15 1/2 years. EPRI also conducted corrosion tests of ASTM A-36 structural steel at four nuclear plants located in Elma and Richland, Washington; and Midland, Michigan. The tests were conducted for up to 24 months. EPRI concluded that based on the Page 3 of 5

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

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

5. Monitoring and Trending:

Inspection methods, inspection schedule, and inspector qualification are consistent with industry guidelines and NRC guidance for implementing the requirements of 10 CFR 50.65, the Maintenance Rule. Inspection methods consist of visual inspections conducted on a frequency of every 4 years in accessible areas of the plant. The program contains provisions for increased inspection frequency and trending of structures and components, consistent with 10CFR50.65 (a)(1), if the degradation is such that the structure or component may not meet its design basis, or, if allowed to continue uncorrected until the next normally scheduled assessment, may not meet its design basis.

Result: This element of the Oyster CreekXl.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.M36 External Surfaces Monitoring, with the exception and enhancement identified above.

6. Acceptance Criteria:

The enhanced Oyster Creek Structures Monitoring Program requires that identified degradations be assessed and evaluated by qualified engineering personnel, considering the extent of the degradation using design basis codes and standards that include ASME/ANSI. The program implementing procedure provides sufficient details on acceptance criteria for structures and exterior surfaces of mechanical components to ensure that significant degradations are identified and corrected before a loss of an intended function.

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

7. Corrective Actions:

Evaluations are performed for inspection results that do not satisfy established criteria and an Issue Report (IR) is initiated to document the concern in accordance with 10 CFR 50, Appendix B, Corrective Action Program. The corrective action process ensures that the conditions adverse to quality are promptly corrected. If the deficiency is assessed to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude repetition.

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Rev. 1 Attachment 2.2 Result: This element of the Oyster CreekXI.S6 Structures Monitoring Program is consistent with recommendations of the NUREG-1801 Revision I aging management program, Xl. M36 External Surfaces Monitoring.

8. Confirmation Process:

See Item 7, above.

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

9. Administrative Controls:

See Item 7, above.

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

10. Operating Experience:

Searches of Oyster Creek corrective action process (CAP) database identified 217 instances of corrosion cases on exterior surfaces of mechanical components and structures. For 216 cases, engineering evaluation concluded that the observed corrosion is limited to surface rust and does not impact the intended function of the component or structure. For the remaining one case, a unistrut support member for 3/8 " diameter tubing, corrosion was more extensive but the unistrut was evaluated and determined capable of performing its intended function. These examples provide objective evidence that deficiencies are entered into the corrective action process and that engineering evaluations are performed to determine what if any corrective actions need to be taken prior to loss of intended function.

The operating experience of the Oyster Creek Structures Monitoring Program did not show any adverse trend in performance. Problems identified would not cause significant impact to the safe operation of the plant, and adequate corrective actions were taken to prevent recurrence. There is sufficient confidence that the implementation of the Structures Monitoring Program as described in the implementing procedures will effectively manage aging effects through the period of extended operation.

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

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Rev. 1 Attachment 2.',

OC: LRA Use of B.2.04 PERIODIC INSPECTION OF VENTILATION SYSTEMS Program vs. XL.M38 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS Program Program

Description:

The NUREG-1801, Revision 1 aging management program XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components will not be used at the Oyster Creek station, but is used for the Forked River Combustion Turbine site, see note below. The Oyster Creek Periodic Inspection of Ventilation Systems aging management program B.2.04, enhanced to include specific guidance for inspection for loss of material by corrosion, rust, pitting or wear, and for change in material properties by inspecting for cracking, perorations or other damage, will be used to satisfy the specifications of the NUREG-1801 Rev. 1 XI.M38 program. The specifications of this new AMP apply to internal (and external) surfaces of the Oyster Creek Generating Station piping and ducting components that have been determined to be in scope of license renewal and that are not covered by other programs.

Note: The portion of the Oyster Creek License Renewal Application applicable to the Forked River Combustion Turbine (FRCT) was developed in accordance with the September 2005 Revision 1 NUREG-1801 XI.M38 program, and this reconciliation does not apply to that portion of the LRA.

The Oyster Creek Periodic Inspection of Ventilation Systems aging management program preventive maintenance procedures is enhanced to provide specific guidance to inspect for the following aging effects:

. Loss of Material by inspecting for corrosion, rust, pitting or wear, and;

Change in Material Properties by inspecting for cracking, perforations, or other damage.

These enhancements were part of the Oyster Creek LRA submitted in July 2005, and are not due to reconciliation to the September 2005 Revision 1 NUREG-1801.

An exception due to reconciliation with September 2005 Revision I NUREG-1801 is inspection of coatings - the Oyster Creek Periodic Inspection of Ventilation Systems aging management program B.2.04 does not take credit for coatings for internal surfaces, but directly inspects for loss of material.

1. Scone of Program:

September 2005 Revision 1 NUREG-1801 program XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, addresses visual inspections to include internal surfaces of steel piping, piping elements, ducting, and components in an internal environment (such as indoor uncontrolled air, condensation, and steam) that are not included in other aging management programs for loss of material. The Inspections are to be performed when the internal surfaces are accessible during the performance of periodic surveillances, during maintenance activities or during scheduled outages. These specifications are satisfied by the OC Periodic Inspection of Ventilation Systems aging Page 1 of 7

Rev. 1 Attachment 2.

management program, which manages the aging effects of loss of material, reduction of heat transfer, and change in material properties through visual inspections of ventilation systems in the scope of license renewal. The scope of existing inspections includes flexible connections, fan and filter housings, and access door seals. The program is enhanced to include ducts exposed to soil, instrument piping and valves, restricting orifices and flow elements, and thermowells. Inspections of carbon steel fan and filter housings are considered representative of the internal surfaces of the carbon steel damper housings in the system. If aging degradation is identified on the fan or filter housing internal carbon steel surfaces, the condition will be evaluated to determine if the carbon steel damper housings will require internal inspection.

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

2. Preventive Actions:

The OC Periodic Inspection of Ventilation Systems aging management program specifies no preventive actions. The program is a condition monitoring program that utilizes visual inspections to identify aging effects prior to loss of intended function.

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

3. Parameters Monitored/Inspected:

September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, addresses visual inspections of internal surfaces of plant components to be performed during maintenance or surveillance activities. Parameters monitored or inspected include visible evidence of corrosion to indicate possible loss of materials. These specifications are satisfied by the OC Periodic Inspection of Ventilation Systems aging management program, which provides for visual inspections of the ventilation system ductwork and components to determine if penetrating corrosion indicating a loss of material aging degradation is occurring.

Heat transfer surfaces are also inspected for fouling. Flexible connections are inspected to ensure they are free of cracking, damage and loss of material. Door seals are inspected for cracking or damage when the associated access door is opened, or are inspected for leakage when the door in closed and the system is in service. The flexible connections and door seals are evaluated if cracking, damage or leakage is identified. For the Standby Gas Treatment, Reactor Building Ventilation and Control Room Ventilation Systems, the results of the Page 2 of 7

Rev. I Attachment 2.3 inspections are verified by the performance of system leakage tests and filter efficiency tests.

These inspections and tests manage the aging effects that could impact system and component pressure boundary integrity, providing reasonable assurance that ventilation system intended functions will be maintained consistent with the current licensing basis, for the period of extended operation Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M138 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

4. Detection of Aqinq Effects:

September 2005 Revision 1 NUREG-1801 program XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, addresses periodic inspections to provide for detection of aging effects prior to the loss of component function. For painted or coated surfaces, degradation of steel surfaces cannot occur without the degradation of the paint or coating.

Confirmation of the integrity of the paint or coating is an effective method for managing the effects of corrosion on the steel surface. Inspection intervals are established such that they provide timely detection of degradation. The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications as follows:

Ventilation system components are subject to the following aging effects:

at Loss of Material it Change in Material Properties (Elastomer materials)

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

Loss of Material: Inspect for corrosion, rust, pitting or wear

. Change in Material Properties: Inspect for cracking, perforations or other damage Aging effects are detected by periodic visual inspections and system tests.

These inspections and tests are performed on a frequency not to exceed five years, to detect aging prior to loss of system function. The visual inspections are performed by qualified and experienced maintenance personnel.

An exception due to reconciliation with September 2005 Revision 1 NUREG-180 1 is inspection of coatings - the Oyster Creek Periodic Inspection of Ventilation Systems aging management program B.2.04 does not take credit for coatings for internal surfaces, but directly inspects for loss of material.

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Rev. 1 Attachment 2.3 Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.MV138 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. An exception associated with reconciliation to the September 200.5 Re-vision I NUREG-1801 document concerns inspection of coatings; the Oyster Creek Periodic Inspection of Ventilation Systems aging management program B.2. 04 does not take credit for coatings for internal surfaces, but directly inspects for loss of material.

5. Monitoring and Trending:

September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components directs that visual inspection activities are performed and associated personnel are qualified in accordance with site controlled procedures and processes. Maintenance and surveillance activities provide for monitoring and trending of aging degradation.

Inspection intervals are dependent on component material and environment, and take into consideration industry and plant-specific operating experience. Results of the periodic inspections are monitored for indications of various corrosion mechanisms and fouling. The extent and schedule of inspections and testing assure detection of component degradation prior to loss of intended functions.

The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by addressing periodic visual examinations which are used to provide assurance that penetrating corrosion of ventilation system duct and components are not occurring or are occurring at an acceptable rate.

The condition of the elastomers used in ventilation systems are monitored and the results of the inspections are reviewed to assure intended functions are maintained. Flexible connections and access door seals are repaired or replaced if damage or deterioration is detected Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision 1 aging management program, XI.MA438 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

6. Acceptance Criteria:

September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components directs that indications of various corrosion mechanisms or fouling that would impact component intended function are reported and require further evaluation. The acceptance criteria are to be established in the maintenance and surveillance procedures or other established plant procedures. If the results are not acceptable, the corrective action program is implemented to assess the material condition and determine whether the component intended function is affected.

The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by inspecting ventilation duct and components for signs of loss of material. Elastomers are inspected for cracking, damage and Page 4 of 7

Rev. 'i Attachment 2.3 loss of material. Elastomers are repaired or replaced if a degraded condition is found. Heat transfer surfaces are inspected for corrosion and fouling. Identified aging effects are evaluated by engineering to determine a) if penetrating corrosion indicating a loss of material aging is occurring, and if so, b) the rate at which the material is being lost. Engineering evaluations will also c) determine the need for follow-up examinations to monitor the progression of aging degradation, and d) identify appropriate corrective actions to mitigate any excessive rates of degradation discovered.

Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.Mv38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

7. Corrective Actions:

September 2005 Revision 1 NUREG-1801 program XL.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components specifies that the site corrective actions program, quality assurance (QA) procedures, site review and approval process, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions, confirmation process, and administrative controls. The OC Periodic Inspection of Ventilation Systems aging management program satisfies these specifications by requiring that evaluations are performed for inspection results that identify penetrating corrosion or elastomer degradation, or test results that do not satisfy established criteria, and an issue report is initiated to document the concern in accordance with plant administrative procedures and the requirements of 10 CFR Part 50, Appendix B. The corrective actions program ensures that the conditions adverse to quality are promptly corrected. If the deficiency is assessed to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude recurrence.

Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XL.A138 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

8. confirmation Process:

See Item 7, above.

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

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Rev. 1 Attachment 2.3

9. Administrative Controls:

See Item 7, above.

Result: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, X.M138 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

10. Operating Experience:

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

The applicant is to evaluate recent operating experience and provide objective evidence to support the conclusion that the effects of aging are adequately managed.

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

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

Maintenance procedures were revised to include steps to inspect for corrosion of outdoor equipment housings. Periodic preventive maintenance inspections of ventilation system components, including specific guidance to identify applicable aging effects, will effectively monitor the condition of system components such that degradation will continue to be identified prior to loss of intended functions.

(fan housing - CAPs 02001-0162, 01998-0737; elastomers - CAP 02003-1281)

2. A buried section of Standby Gas Treatment system duct failed due to external corrosion of the aluminum duct exposed to a soil environment. The failure occurred after approximately thirty years in service. The failed section was repaired with a sleeve. Periodic inspections of the buried duct section will be performed. (SE-000822-023, CAP 02005-2288)

Page 6 of 7

Rev. I Attachment 2.3 The operating experience of the Periodic Inspection of Ventilation Systems program did not show any adverse trend in performance. Problems identified would not cause significant impact to the safe operation of the plant, and adequate corrective actions were taken to prevent recurrence. There is sufficient:

confidence that the implementation of the Periodic Inspection of Ventilation Systems program will effectively determine loss of material, change in material properties, and reduction of heat transfer, with appropriate guidance for reevaluation, repair or replacement provided for locations where the aging effects occur. Periodic self-assessments of the Periodic Inspection of Ventilation Systems program are performed to identify the areas that need improvement to maintain the quality performance of the program.

Re sult: This element of the enhanced Oyster Creek B.2.4 Periodic Inspection of Ventilation Systems aging management program is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M138 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

Page 7 of 7

Rev. I Attachment 2.A OC: LRA Use of B.2.2 LUBRICATING OIL MONITORING ACTIVITIES Program vs. XL.M39 LUBRICATING OIL ANALYSIS PROGRAM Program

Description:

The NUREG-1801, Revision 1 aging management program XI.M39, Lubricating Oil Analysis Program, will not be used at Oyster Creek. The Oyster Creek Lubricating Oil Monitoring Activities aging management program B.2.2 manages loss of material, cracking, and fouling in lubricating oil coolers, systems and components in the scope of license renewal. These activities include measures to minimize corrosion and to mitigate loss of material and cracking in lubricating oil heat exchangers by monitoring lubricating oil properties. Specifications of the XI.MA39, Lubricating Oil Analysis Program are included through sampling, testing, and trending verify lubricating oil properties and ensure that the intended functions of the coolers are not lost. Oil analysis permits identification of specific wear mechanisms, contamination, and oil degradation within operating machinery and components. The activities manage physical and chemical properties in lubricating oil. The OC Lubricating Monitoring Activities aging management program performs sampling and analysis of lubricating oil for the presence of water, as well as particulates and contaminants for the purpose of detecting the presence of inleakage and corrosion product buildup. This prograrr, is augmented by the One-Time Inspection aging management program, B.1.24, to verify the effectiveness of the Lubricating Oil Monitoring Activities Program, B.2.2.

New exception to NUREG-1 801, required due to incorporation of specifications from September 2005 Revision 1 GALL program XL.M39:

Parameters Monitored/Inspected (Element 3) specifies the flash point be measured for the lubricating oils. Flash Point is not measured for all lubricating oils in service, since this is a quality control measurement when purchasing new oil. lit is not a primary measurement to determine the presence of water or contaminants, which are the parameters for assessing the environment of concern. Measurement of flash point is a measure to detect the contamination of lubricating oils by fuel oil, as is the case for diesel engines lubricating oil.

Therefore, flash point is measured for diesel engine lubricating oils only.

New enhancement to incorporate specification from XL.M39, Lubricating Oil Analysis Program:

The Oyster Creek Lubricating Oil Monitoring Activities aging management program B.2.2 will be enhanced to include sampling for and measurement of Flash Point for diesel engine lubricating oil.

1. Scone of Program:

The Oyster Creek Lubricating Oil Monitoring Activities Program samples lubricating oil from plant components subject to aging management review on a periodic basis.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the Page 1 of 5

Rev. 1 Attachment 2.4 NUREG-1801 Revision 1 aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.

2. Preventive Actions:

The Oyster Creek Lubricating Oil Monitoring Activities Program maintains oil systems contaminants (primarily water and particulates) within acceptable limits.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision I aging management program, XL.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.

3. Parameters Monitored/inspected:

The! Oyster Creek Lubricating Oil Analysis program includes specifications for known oil degradation indicators and degradation characteristics, sampling and analysis frequencies, and corrective actions for control of lubricating oil properties. Lubricating oil physical properties are tested to standard ASTM and ISO methods, for the applicable oil type, to provide accurate quantitative numbers with repeatable results. Samples are taken and analyzed for indications of degraded chemical and physical properties depending on oil type and type of service. Analyses include: chemical parameters and viscosity, total acid number, total base number, rotating pressure vessel oxidation test, water demulsibility, particle count, fuel and combustion byproducts, sediment, water, anti-foaming characteristics, whole particle counting, air release and emission spectrum. Normal, alert, and fault levels for oil chemical and physical properties, wear metals, contaminants, and additives are established for the specific oil type and application.

Exception: The NUREG 1801 Rev. 1 XL.M39 Lubricating Oil Analysis program specifies that flash point be determined. The Oyster Creek Lubricating Oil Monitoring Activities Program does not measure flash point for all lubricating oils in service, since this is a quality control measurement when purchasing new oil. It is not a primary measurement to determine the presence of water or contaminants, which are the parameters for assessing the environment of concern. Measurement of flash point can be a measure to detect the contamination of lubricating oils by fuel oil, as is the case for diesel engine lubricating oil. Therefore, flash point will be measured for diesel engine lubricating oils only.

Enhancement: The Oyster Creek Lubricating Oil Monitoring Activities Program will be enhanced to include sampling for and measurement of Flash Point for diesel engine lubricating oil.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.

Page 2 of 5

Rev. 1 Attachment 2.4

4. Detection of Aging Effects:

Monitoring activities maintain lubricating oil properties within predefined limits to both mitigate and detect the effects of aging. Oil analysis has become an accurate method for identifying specific wear mechanisms, contamination, and oil degradation characteristics within operating machinery. The program includes normal, alert, and fault action levels for oil chemical and physical properties, wear metals, contaminants, and additives, for the specific oil type and application.

Increased impurities and degradation of oil properties indicate degradation of materials in lubricating oil systems. Monitoring of the diagnostic parameters indicates degradation due to aging effects prior to loss of intended function.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.

5. Monitoring and Trending:

Lubricating oil analysis results are monitored and trended to allow for the detection and identification of adverse trends prior to the occurrence of a loss of function event.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.

6. Acceptance Criteria:

Normal, alert, and fault levels have been established for the various chemical and physical properties, wear metals, additives, and contaminant levels based on information from oil manufacturers, equipment manufacturers, and industry guidelines, for the specific oil type and application. The program maintains contaminant and parameter limits within the application-specific limits. Plant procedures outline potential actions to be taken at alert and fault levels, and actions can be chosen based on the level of deviation. Aging effects or unacceptable results are evaluated and appropriate corrective actions are taken.

Particle concentration is determined in accordance with ISO 4406.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-1801 Revision I aging management program, XI.M39 Lubricating Oil Analysis, with the exception and enhancement identified above.

7. Corrective Actions:

Lubricating oil chemical and physical test results or contaminants outside the allowable limits are returned to the acceptable range within reasonable time periods as identified in industry guidelines. Evaluations are performed for test results that do not satisfy established criteria and an Issue Report is initiated to Page 3 of 5

Rev. I Attachment 2.4 document the concern in accordance with plant administrative procedures. The corrective actions program ensures that conditions adverse to quality are promptly corrected. If the deficiency is found to be significantly adverse to quality, the cause of the condition is determined and an action plan is developed to preclude recurrence.

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

8. Confirmation Process:

Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.

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

9. Administrative Controls:

See item 8 above.

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

10. Operating Experience:

The! overall effectiveness of lubricating oil monitoring activities is indicated by the Oyster Creek operating experience. Lubricating oil sampling and analysis have detected particulate or water contamination (or both) in lubricating oil systems. In some cases these events resulted in systems being declared inoperable until repaired, and until the oil was flushed or replaced. Operating experience has produced procedure and program changes, which have improved the effectiveness of lubricating oil testing and inspection activities.

In 2001, a Core Spray Pump oil analysis detected a high ratio of large to small particles after an oil change. Further investigation determined there had been no increase in pump vibration levels for an extended period, and that source of the particles in the changed oil was contamination from the reservoir whern the oil change occurred. The condition did not render the pump inoperable, but continued operation with contaminated oil could have caused accelerated bearing wear, which would be indicated by increasing vibration levels. The reservoir was flushed to remove particles and new oil was added. An increased Page 4 of 5

Rev. 1 Attachment 2.4 oil surveillance frequency was established to confirm oil condition, and vibration data monitoring was performed as part of the scheduled preventive maintenance for the pump.

In 2002, while performing the fire pump operability test, the oil temperature stabilized two degrees higher than the allowed maximum temperature from the procedure. The system manager consulted with the vendor, and it was determined the procedure was too restrictive. The procedure was revised to conform with the vendor specifications.

In 2005, the potential for introducing improper bearing grease during motor refurbishing was recognized. Immediate action included cleaning and re-greasing. Follow-up actions included investigating improved vendor controls and updating of work instructions.

The operating experience of the Lubricating Oil Monitoring Activities program did not show any adverse trend in performance. Problems identified would not cause significant impact to the safe operation of the plant, and adequate corrective actions were taken to prevent recurrence. There is sufficient confidence that the implementation of the Lubricating Oil Monitoring Activities program will effectively maintain oil systems contaminants within acceptable limits, thereby preserving an environment that is not conducive to loss of material, cracking, or reduction of heat transfer. Periodic self-assessments of the Lubricating Oil Monitoring Activities program are performed to identify the areas that need improvement to maintain the quality performance of the program.

The Oyster Creek Lubricating Oil Monitoring Activities aging management program will provide assurance that the oil environment in the mechanical systems is maintained to the required quality. The program will provide reasonable assurance that system intended functions are maintained consistent with the current licensing basis during the period of extended operation.

Result: This element of the Oyster Creek aging management program Lubricating Oil Monitoring Activities is consistent with recommendations of the NUREG-l801 Revision I aging management program, XI.M39 Lubricating Oil Analysis.

Page 5 of 5

Attachment 3 AMR Line Items Used in the Oyster Creek LRA for which "Further Evaluation" changed from "No" to "Yes" in the September 2005 Revision 1 GALL

Rev. ', I Attachment 3 AMR Line Items Used in the Oyster Creek LRA for which "Further Evaluation" changed from "No" to "Yes" EP-34 V.02-10, 3.2.1-24: Two new line items invoking One-Time Inspection for Reduction of Heat Transfer due to fouling will be added to the Oyster Creek LRA as a result of this change to the GALL.

This line item for stainless steel heat exchanger tubes in treated water, addressing reduction of heat transfer due to fouling, invoked the Water Chemistry program with "No" further evaluation required in January 2005 and has been changed in September 2005 to Water Chemistry and One-Time Inspection, with "Yes" for evaluation of aging effects.

There are 2 instances of this line item being used in the Oyster Creek License Renewal Application, both in the Isolation Condenser system, for heat exchanger tubes, internal and external.

In the Oyster Creek LRA, there are 132 line item instances of One-Time Inspection of stainless steel components in a treated water environment. While these instances are applied to aging effects of loss of material or cracking, they provide ample inspection opportunity for the condition of the components - observed conditions that have the potential for impacting an intended function are evaluated and corrected as necessary in accordance with the corrective action process. Since one of the functions of the Water Chemistry program is to prevent or mitigate reduction of heat transfer due to fouling, a detected fouling condition on any of the components inspected for loss of material or cracking would also be identified and entered into the corrective action process. Thus there is high confidence that any instance of the Water Chemistry Program's failure to prevent fouling would be identified during the inspections for loss of material due to corrosion and cracking. However, since the Isolation Condenser tubes specifically will undergo eddy current testing during the first ten years of the period of extended operation, a One-Time Inspection for fouling of the internal surface of the tubes can be performed at that time. The Isolation Condenser shell side components undergo inspection for loss of material under the One-Time Inspection program; an inspection of the external surface of the tubes for reduction of heat transfer due to fouling will also be performed.

AP-:54 VIL.HI-6, 3.3.1-54: There is no change required to the Oyster Creek LRA due to this item change.

This line item for stainless steel piping elements in fuel oil, addressing loss of material due to corrosion, invoked the Fuel Oil Chemistry program with "No" further evaluation required in the January 2005 draft GALL. It has been changed in September 2005 to Fuel Oil Chemistry and One-Time Inspection, with "Yes" for evaluation of detected aging effects, to be consistent with other line items applicable to fuel oil environments. There are (3instances of this line item being used, in the EDG and Auxiliary systems, and in Main F.O. Storage and Transfer system.

In the Oyster Creek LRA, four other Table 1 line items also specify the Fuel Oil Chemistry program to address loss of material due to corrosion in a fuel oil environment:

Page 1 of 8

Rev. 1 I Attachment a;

A-30, 3.3.1-20 (with One-Time), for steel material, 49 instances in the EDG and Aux, Fire Protection, Main F.O. Storage, and SBO systems, Further Evaluation is "Yes" for evaluation of aging effects

AP-44, 3.3.1-26 (with One-Time), for copper alloy material, 6 instances in the EDG and Aux, F.P., and Main F.O. Storage systems, Further Evaluation is "Yes" for evaluation of aging effects

AP-35, 3.3.1-25 (with One-Time), for aluminum material, 6 instances in the EDG and Aux, and SBO systems, Further Evaluation is "Yes" for evaluation of aging effects

A-28, 3.3.1-48 (with Fire Protection), for steel material, 6 instances in the F.P.

and SBO systems, Further Evaluation is "No" Numerous items in the EDG and Aux systems and Main F.O. Storage Systems are already subject to both the F.O. Chemistry and One-Time Inspection requirements for determination of loss of material due to corrosion. The basis for sample size for the One-Time Inspection program would not be significantly affected by the addition of the (comparatively few) AP-54 line items. Evaluations of any detected aging effects from inspections of those components, with observed conditions that have the potential for impacting an intended function evaluated and corrected as necessary in accordance with the corrective action process, provide ample opportunity for verification of the effectiveness of the F.O. Chemistry program with the One-Time Inspection program in these two systems.

AP-62 VIL.J4-4 and VII.E3-6, 3.3.1-69: There is no change required to the Oyster Creek LRA due to this item change.

This line item for stainless steel heat exchanger tubes in treated water, addressing reduction of heat transfer due to fouling, invoked the Water Chemistry program with "No" further evaluation required in January 2005 and has been changed in September 2005 to the Water Chemistry and One-Time Inspection programs, with "Yes" for evaluation of agirg effects. There are 2 instances of this line item being used, applicable to the treated water side of Shutdown Cooling System heat exchanger components evaluated in the Reactor Building Closed Cooling Water System (RBCCW) license renewal system.

Inthe Oyster Creek LRA, there are 229 line item instances of One-Time Inspection of stainless steel components in a treated water environment. While these instances are applied to aging effects of loss of material or cracking, they provide ample inspection opportunity for the condition of the components - observed conditions that have the potential for impacting an intended function are evaluated and corrected as necessary in accordance with the corrective action process. Since one of the functions of the Water Chemistry program is to prevent reduction of heat transfer due to fouling, a noted fouling condition on any of the inspected items would be identified and entered into the corrective action process. Thus there is high confidence that any instance of the Water Chemistry Program's failure to prevent fouling would be identified during the inspections for loss of material due to corrosion and cracking.

Inaddition, for the Shutdown Cooling System heat exchangers invoking this line item, the treated water environment is reactor coolant. The Water Chemistry program Page 2 of 8

Rev. l I Attachment :3 requirements for reactor quality water provide added assurance that an environment conducive to fouling does not exist.

AP-64 VII.C2-5, 3.3.1-38: There is no change required to the Oyster Creek LRA due to this itern change.

This line item for copper alloy piping elements in treated water, addressing loss of ma:erial due to corrosion, invoked the Closed-Cycle Cooling Water System program with "No" further evaluation required in January 2005 and has been changed in September 200C5 to Water Chemistry and One-Time Inspection, with "Yes" for evaluation of detected aging effects. There are 4 instances of this line item being used, in the Condensate Transfer and Reactor Building Closed Cooling Water systems. In the Oyster Creek LRA, these 4 instances already specify the Water Chemistry and One-Time Inspection programs (with a standard "E" note stating that a different aging management program than was specified in January 2005 GALL was credited). Therefore, the Oyster Creek LRA implements the One-Time Inspection program and is consistent with GALL. Since observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process, there is high confidence that the aging effect will be adequately managed.

T-01 3.5.1-21: There is no change required to the Oyster Creek LRA due to this item change.

For Inaccessible areas: As described in the UFSAR Section 3.8.4.6, "Materials, Quality Control and Special Construction Techniques", concrete is designed consistent with ACI 318 requirements to provide workable concrete of homogeneous structure which, when hardened, will have durability, impermeability and the specified strength. Testing of concrete was performed in accordance with ASTM Standards specified in ACI 318 to ensure the desired quality of concrete is furnished. The strength quality of the concrete was established by tests made in advance of the beginning of operations using a maximum slump of four inches. Specimens were tested and cured in accordance with ASTM C39.

The review of design and construction documents indicated that the specified air content is 4 to 6 percent. Water-to-cement ratio was based on the strength required by the design considering the maximum slump of four inches. Curves representing the relation between the water content and the average 28-day compressive strength were established for a range of values including the compressive strengths specified. The curves were established by at least three points, each point represented average values from at least four test specimens. The maximum allowable water content for each class of concrete was determined from the curves and corresponded to a compressive strelgth of 15 percent greater than that specified for that class of concrete. A review of documentation for a sample of class 4LA (4000 psi) concrete cylinder tests shows that the :28-day strength meets or exceeds the specified 4000 psi compressive strength.

Inspections conducted in accordance with the Structures Monitoring Program have identified minor loss of material (spalling, scaling) and cracking which could be attributed to freeze-thaw in accessible areas. Engineering evaluation of the identified loss of material and cracking concluded it is not significant to impact the intended function of the affected structure.

Page 3 of 8

Rev. 1 Attachment :3 Based on above evaluation, we concluded that loss of material and cracking due to freeze-thaw is not significant for inaccessible areas. Thus a plant-specific aging management program is not required.

T-02 3.5.1-23: There is no change required to the Oyster Creek LRA due to this item change.

Further evaluation is only required for inaccessible areas if concrete was not constructed as stated (in accordance with the recommendations in ACI 201.2R). In the Oyster Creek LRA, the uses of this line item are not for inaccessible areas. Accessible areas inspections are performed in accordance with the Structures Monitoring Program, per September 2005 GALL.

T-03 3.5.1-21: There is no change required to the Oyster Creek LRA due to this item change.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program and stated conditions are satisfied for inaccessible areas, to required if not within the scope of the applicant's structures monitoring program, or concrete was not constructed as stated for inaccessible areas.

This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

T- 04 3.5.1-21: There is no change required to the Oyster Creek LRA due to this item change.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

T-013 3.5.1-21: There is no change required to the Oyster Creek LRA due to this item change.

The environment for this item, concrete: interior and above grade exterior, changed from "aggressive environment" to "air - indoor uncontrolled or air - outdoor". The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. Each instance of use of this item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

T-0B 3.5.1 -27: There is no change required to the Oyster Creek LRA due to this item change.

Oyster Creek does not rely on a de-watering system for control of settlement. The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

Page 4 of 8

Rev. 1 Attachment 8 T-1 !

3.5.1-21: There is no change required to the Oyster Creek LRA due to this item change.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

T-1 !,

3.5.1-24: There is no change required to the Oyster Creek LRA due to this item change.

For inaccessible areas: As described in the UFSAR Section 3.8.4.6, "Materials, Quality Control and Special Construction Techniques", concrete is designed consistent with ACI 318 requirements to provide workable concrete of homogeneous structure which, when hardened, will have durability, impermeability and the specified strength. Testing of concrete was performed in accordance with ASTM Standards specified in ACI 318 to ensure the desired quality of concrete is furnished. The strength quality of the concrete was established by tests made in advance of the beginning of operations using a maximum slump of four inches. Specimens were tested and cured in accordance with ASTM C39.

The review of design and construction documents indicated that the specified air content is 4 to 6 percent. Water-to-cement ratio was based on the strength required by the design considering the maximum slump of four inches. Curves representing the relation between the water content and the average 28-day compressive strength were established for a range of values including the compressive strengths specified. The curves were established by at least three points, each point represented average values from at least four test specimens. The maximum allowable water content for each class of concrete was determined from the curves and corresponded to a compressive strength of 15 percent greater than that specified for that class of concrete. A review of documentation for a sample of class 4LA (4000 psi) concrete cylinder tests shows that the 28-day strength meets or exceeds the specified 4000 psi compressive strength.

Inspections conducted in accordance with the Oyster Creek RG. 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants have identified loss of material (spalling, scaling) and cracking which could be attributed to freeze-thaw in accessible areas. Engineering evaluation of the identified loss of material and cracking concluded it is not significant to impact the intended function of the affected structure.

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

T-1 6 3.5.1-24: There is no change required to the Oyster Creek LRA due to this item change.

The Oyster Creek LRA's commitment to perform inspections in accordance with Reg.

Guide 1.127 does not change. This line item is not applied to inaccessible areas; therefore further evaluation is not required.

Page 5 of 8

Rev. ' I Attachment 3 T-1 7 3.5.1-24: There is no change required to the Oyster Creek LRA due to this item change.

As described in the UFSAR Section 3.8.4.6, "Materials, Quality Control and Special Construction Techniques", the cement used for Oyster Creek was an approved brand of Portland Cement conforming to ASTM Specification C-150; Type II, low alkali. Alkali content is limited to 0.6 percent total alkali. The low alkali requirement for the cement was waived provided petrographic tests conducted in accordance with ASTM C295 and C227 demonstrated no potential alkali reactivity for all aggregates proposed for use.

This provides reasonable assurance that aggregates do not react with reinforced concrete.

Additionally, the aggregate used on the project was from approved sources and consisted of clean, hard, durable particles conforming to the requirements of concrete specifications. Tests were performed as necessary to determine that the proposed aggregate would produce concrete of acceptable quality and durability, meeting ACI requirements.

T-113 3.5.1-24: There is no change required to the Oyster Creek LRA due to this item change.

Oyster Creek has committed to inspecting inaccessible areas of structures in the scope of license renewal that are exposed by excavation for any reason, and to sample and test groundwater periodically during the period of extended operation (Ref: AMP-168).

This line item has been invoked for water control structures. Oyster Creek has committed to performing a baseline inspection of submerged water control structures prior to entering the period of extended operation. A second inspection will be performed 6 years after the baseline inspection. A third inspection will be performed 8 years after the second inspection. Following each inspection, the identified degradations will be evaluated to determine if more frequent inspections are warranted or there is a need for corrective actions to ensure that age related degradations are adequately managed (Ref: AMP-077). Inspections will be conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.

The review of design and construction documents indicated that the specified air content is 4 to 6 percent. Water-to-cement ratio was based on the strength required by the design considering the maximum slump of four inches. Curves representing the relation between the water content and the average 28-day compressive strength were established for a range of values including the compressive strengths specified. The curves were established by at least three points, each point represented average values from at least four test specimens. The maximum allowable water content for each class of concrete was determined from the curves and corresponded to a compressive strength of 15 percent greater than that specified for that class of concrete. A review of documentation for a sample of class 4LA (4000 psi) concrete cylinder tests shows that the :28-day strength meets or exceeds the specified 4000 psi compressive strength.

Inspections conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants have identified cracking, change in material properties, and loss of material (spalling, scaling), which could be attributed to corrosion of embedded steel in accessible areas. Engineering evaluation of the Page 6 of 8

Rev. ' I Attachment 3 identified cracking, change in material properties, and loss of material concluded it is not significant to impact the intended function of the affected structure.

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

T-1 9 3.5.1-24: There is no change required to the Oyster Creek LRA due to this item change.

Oyster Creek has committed to inspecting inaccessible areas of structures in the scope of license renewal that are exposed by excavation for any reason, and to sample and test groundwater periodically during the period of extended operation (Ref: AMP-168).

This line item has been invoked for water control structures. Oyster Creek has committed to performing a baseline inspection of submerged water control structures prior to entering the period of extended operation. A second inspection will be perlormed 6 years after the baseline inspection. A third inspection will be performed 8 years after the second inspection. Following each inspection, the identified degradations will be evaluated to determine if more frequent inspections are warranted or there is a need for corrective actions to ensure that age related degradations are adequately managed (Ref: AMP-077). Inspections will be conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.

Inspections conducted in accordance with RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants have identified concrete degradation, which could be attributed to aggressive chemical attack in accessible areas.

Engineering evaluation of the identified identified increase in porosity and permeability, cracking, and loss of material concluded it is not significant to impact the intended function of the affected structure.

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

T-29 3.5.1-33: There is no change required to the Oyster Creek LRA due to this item change.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

T-3C1 3.5.1-33: There is no change required to the Oyster Creek LRA due to this item change.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the Page 7 of 8

Rev. I l Attachment 3 applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

T-31 3.5.1-33: There is no change required to the Oyster Creek LRA due to this item change.

The wording for further evaluation was changed from not required if within the scope of the applicant's structures monitoring program, to required if not within the scope of the applicant's structures monitoring program. This item is within the scope of Oyster Creek's Structures Monitoring Program, therefore further evaluation is not required.

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Attachment 4 AMR Line Items Used in the Oyster Creek LRA which were Deleted from the September 2005 Revision 1 GALL

Rev. I Attachment 4 20 Line Items used in OC LRA Now Deleted from September 2005 Revision 1 GALL Twenty (20) Line Items used in the OCLR LRA have been deleted from September 2005 GA'-L.

Note: In the listings below, following the line item alphanumeric number and number of times the line item appears in the OC LRA, is a shortened description of the line item's content (structure and component description, material, environment, aging effect and mechanism, and GALL recommended program) for information. For the complete description, reference GALL.

1.) R (IV.C1-9; 35 line item occurrences): piping, components, elements > 4NPS; stainless steel; reactor coolant; cracking/SCC/IGSCC; programs: BWR SCC, Water Chemistry 9/05 GALL Master list replacement: R-20 9/05 GALL states that CASS and SS share aging effects and mechanisms with the exception of CASS loss of fracture toughness due to thermal and neutron irradiation embrittlement; therefore CASS only needs to be listed when embrittlement is an issue.

Consequently, 9/05 GALL R-20 deletes "CASS" (evidently intending that "SS" includes it when necessary), and concludes that R-22 is identical to R-20, therefore R-22 was deleted.

OC LRA effect: No changes required. The OC LRA line items using R-22 for SS have the same aging effects and mechanisms, and are covered by the same programs (BWR SCC and Water Chemistry), as R-20.

2.) R (IV.C1-2; 90 line item occurrences): Class 1 piping, branch connections < 4 NPS); SS, steel; reactor coolant; cracking/thermal and mechanical loading; programs:

Section Xl ISI, One-Time Inspection 9/05 GALL Master list replacement: R-03 9/05 GALL states that NRC staff requested that R-03 and R-55 be managed identically.

Consequently, thermal/mechanical loading from R-55 was added to R-03, IGSCC was noted to apply to SS only (implying that SCC still applies to CS, which is not the position taken in the OC LRA, based on input from the peer review), and new program "One-Time Inspection of Class 1 Small-Bore Piping" was added to R-03'sSection XI ISI and Water Chemistry, in lieu of a "plant specific" (for which the OC LRA uses One-Time Inspection as an equivalent inspection program).

OC LRA effect: No changes required. For SS piping, the OC LRA invoked R-03 and R-55 together, so for SS, the OC LRA is in compliance with the 9/05 GALL changes. For CS piping, the OC LRA invoked R-55 for cracking due to thermal and mechanical loading, but did not call out R-03, based on the peer review information that the January draf: of GALL would be changed to not specify SCC to be considered for CS (and Page 1 of 7

Rev. 'I Attachment i chrome-moly). SCC was not deleted from CS material in the 9/05 GALL; therefore 9/05 GALL would specify Water Chemistry to be invoked via R-03 to manage stress corrosion cracking for CS (and chrome-moly) piping. However, in the OC LRA, for each environment of each component listing of piping, fittings, and valves where R-55 was invoked for cracking in CS and chrome-moly material, the Water Chemistry program is also invoked, to manage loss of material. Therefore, the programs specified by 9/05 GAL'L to manage SCC are invoked, and the OC LRA is equivalent to the specifications of C/05 GALL.

3.) RP (IV.E-1; 9 line item occurrences): piping, components, elements; CASS; air indoor uncontrolled; None-None 9/05 GALL Master list replacement: No recommendation OC LRA effect: No changes required. 9/05 GALL says nothing specifically about the deletion of RP-02, but does say elsewhere (in R-20) that CASS and SS are to be treated equivalently except where thermal or neutron irradiation embrittlement is an issue. RP-04 is identical to RP-02 but lists only SS, not specifically CASS. As in the discussion in R-20, GALL apparently expects RP-04 to cover CASS as well as SS, and eliminated RPR-02 as redundant. The OC LRA is equivalent.

4.) E (V.D2-22; 4 line item occurrences): piping, components, elements; SS, treated water; cumulative fatigue; TLAA 9/05 GALL Master list replacement: E-10 9/05i GALL states that E-10 "is identical to E-16, so E-16 was deleted." However, E-10 is for "steel", E-16 was for "stainless steel."

OC LRA effect: No changes required. The OC LRA use of E-16 for SS invokes TLAA, just as E-10 does for "steel". The OC LRA is equivalent.

5.) E (V.C-8; 2 line item occurrences): Containment isolation piping and component internal surfaces; steel; untreated water; loss of material/corrosion/MIC; plant specific program 9/05 GALL Master list replacement: E-22 9/05 GALL states that changing E-32's "untreated water' to "raw water" made it a duplicate of E-22; therefore GALL deleted E-32. E-22's program is Open-Cycle Cooling Water, which GALL says manages steel in a raw water environment. The OC LRA used One-Time Inspection for E-32's "plant specific" program.

OC LRA effect: No changes required. The One-Time Inspection program the OC LRA invoked corresponds to inspections applied through the use of Open-Cycle Cooling.

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

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Rev. 1 Attachment 4 6.) EP (V.F-18; 1 occurrence - Service Water system): piping, piping components, and piping elements; SS; lubricating oil; None-none 9/05 GALL Master list replacement: EP-51 9/05 GALL states that GALL now assumes water pooling in lubricating oil, which would create a potential for a plausible aging effect in SS. GALL now calls out the new Lubricating Oil Analysis program and One-Time Inspection for this line item.

OC LRA effect: No change required. The OC LRA's only use of this line item is in the lubricating oil system for the service water pumps, which are in continuous use -

therefore pooling of any contamination water in the lubricating oil system is not credible, and a pooled water aging effect on the SS piping is not postulated to occur.

7.) A (VII.F3-6; 19 occurrences): ducting/piping internal surfaces; steel; air indoor uncontrolled; loss of material/corrosion; plant specific program 9/05 GALL Master list replacement: A-08 9/05 GALL states that changing the environment of A-08 from "air indoor uncontrolled" to "condensation internal", adding MIC to the aging mechanisms, and adding the new program "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" to this line item in lieu of the "plant specific" program made it a duplicate of A-1 1,so A-1 I was deleted.

OC LRA effect: No change required. The OC LRA used A-1 1 in 7 different systems, with 5 different plant specific programs depending on the application, including: None; Fire Protection; Fire Water; One-Time; Periodic Inspection; and Appendix J. The various inspections resulting from these programs provide a corresponding level of scrutiny as the new program. The "None" instances where no OC program was applied were for the Containment Inerting System and the Reactor Building Ventilation System, where past precedence was cited that said loss of material due to corrosion of carbon steel in a containment environment was not a credible aging effect due to the negligible amounts of free oxygen in a containment nitrogen environment.

8.) A (VII.F3-5; 15 occurrences): ducting, piping, component internal surfaces; SS; condensation internal; loss of material/corrosion; plant specific program 9/05 GALL Master list replacement: A-09 9/05 GALL states that removing "external" from the structure/component description and environment of A-09 made it a duplicate of A-12, so GALL deleted A-12.

OC LRA effect: No change required. The OC LRA used One-Time Inspection as the plant specific program which would be no different had it invoked A-09. The OC LRA is equivalent.

9.) A (VII.F3-3,1 occurrence; VII.F4-3, 2 occurrences): ducting/piping internal surfaces; steel; condensation internal; loss of material/corrosion and MIC; plant specific program Page 3 of 7

Rev. 1 Attachment 4 9/05 GALL Master list replacement: A-08 9/05 GALL stated that changing the environment of A-08 from "air indoor uncontrolled" tc "condensation internal", adding MIC to the aging mechanisms, and adding the new program "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" to this vs. "plant specific" program made it a duplicate of A-1 3, so A-1 3 was deleted.

OC LRA effect: No change required. The OC LRA used A-13 in 2 different systems, with periodic inspection called out as the plant specific program. The periodic inspection is equivalent to the inspections of opportunity described in the new GALL program.

10.) A (VII.C3-10; 2 occurrences); piping, components, elements; steel; raw water; loss of material/corrosion and MIC; open-cycle cooling 9/05 GALL Master list replacement: A-38 9/05 GALL states that A-38 encompasses A-31 and therefore A-31 is not needed. A-38 also applies to lined or unlined piping, and includes fouling and lining degradation.

OC LRA effect: No change required. The OC LRA's two instances of A-31 both used an "E" alternate program (Structures Monitoring for the intake structure, and One-Time Inspection, in conjunction with the Selective Leaching of Materials program for the Raw Water-Fresh Water environment in Sanitary Waste). These programs' inspections correspond to those of the Open-Cycle Cooling Water program, and are more appropriate for these two applications. The OC LRA is equivalent.

11.) A (VII.C1-18; 28 occurrences); piping, components, elements; steel; raw water; loss of material/corrosion, fouling, and MIC; open-cycle cooling 9/05 GALL Master list replacement: A-38 9/05 GALL states that A-38 encompasses A-32 and therefore A-32 is not needed. A-38 also applies to lined or unlined piping, and includes lining degradation.

OC LRA effect: No change required. The OC LRA's instances of invoking A-32 either use Open-Cycle Cooling, or they use One-Time Inspection (to confirm absence of aging effects in pooled or stagnant areas of drain piping) or Periodic Inspections with an "E" standard note and plant specific note. Their use is justified for the application and envi onment, and results in equivalent scrutiny.

12. A (VII.F2-7, 6 occurrences; VII.F3-7, 4 occurrences; VII.Fl-8, 3 occurrences):

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

hardening - loss of strength/degradation; plant specific program 9/05 GALL Master list replacement: A-17 9/05 GALL changed the environment of A-17 to be both internal and external, therefore A-36 was redundant and deleted.

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Rev. 1 Attachment 4 OC LRA effect: No change required. The OC LRA invokes various plant specific programs depending on the application and they remain valid. The OC LRA is equivalent.

13. A (VII.E4-18; 1 line item occurrence): piping, components, elements; steel, treated water; cumulative fatigue; TLAA 9/05 GALL Master list replacement: A-62 9/05 GALL states that A-62 is the same as A-37, so A-37 was deleted. However, A-62 is for "stainless steel", A-37 was for "steel."

OC LRA effect: No changes required. The OC LRA's use of A-37 for steel invokes TLAA, just as A-62 does for "stainless steel". The OC LRA is equivalent.

14. AP (VII.G-14, 6 occurrences; VII.C1-12, 1 occurrence): piping, components, elements; gray C.I.; untreated water; loss of material/selective leaching; Selective Leaching 9/05 GALL Master list replacement: A-51 9/05 GALL changed "untreated water" to "raw water"; AP-29 was a duplicate to A-51 after this change so AP-29 was deleted.

OC LRA effect: No changes required. The OC LRA invokes Selective Leaching for AP-29, so it is equivalent to A-51.

15. AP (VII.K-7, 12 occurrences; VII.E3-17, 46 occurrences): piping, components, elements; SS; treated water; loss of material/corrosion; plant specific program 9/05 GALL Master list replacement: A-58 9/05 GALL states that AP-57 was modified to transfer Related Item "E3" to A-58, however 9/05 GALL deleted AP-57 entirely, apparently intending that A-58 be used.

OC LRA effect: No change required. The OC LRA's use of AP-57 invokes water Chemistry and One-Time inspection as the plant specific programs in every case except one, where Generator Stator Water Chemistry is used equivalently to Water Chemistry.

The actions for AP-57 are equivalent to those of A-58.

16. AP (VII.K-5, 20 line item occurrences): piping, components, elements; steel; treated water; loss of material/corrosion; plant specific program 9/05 GALL Master list replacement: No recommendation OC LRA effect: No changes required. GALL items A-35, S-09, and E-08 are all similar, and each specifies Water Chemistry and One-Time Inspection programs. The OC LRA's only use of AP-69 is in the Main Generator and Auxiliaries system, and the programs specified are Generator Stator Water Chemistry and One-Time Inspection.

These supply equivalent inspection requirements.

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Rev. 1 Attachment 4

17. AP (VII.J-3, 1 line item occurrence): piping, components, elements; CASS; air indoor uncontrolled (external); None-none 9/05 GALL Master list replacement: No recommendation OC LRA effect: No changes required. 9/05 GALL says nothing specifically about the deletion of AP-7, but does say elsewhere (in R-20) that CASS and SS are to be treated equivalently except where thermal or neutron irradiation embrittlement is an issue. AP-17 is identical to AP-7 but lists only SS, not specifically CASS. As in the discussion in R-20, GALL apparently expects AP-17 to cover CASS as well as SS, and eliminated AP-7 as redundant. The action taken is equivalent.

18. AP (VII.K-1, 11 line item occurrences): piping, components, elements; copper alloy, treated water, loss of material/corrosion; plant specific program 9/05 GALL Master list replacement: AP-32 9/05 GALL states that AP-32 is a "counter-part to AP-70"; AP-70 has been deleted from GALL.

OC LRA effect: No change required. AP-32 is not a replacement for AP-70. AP-32 addresses loss of material through selective leaching by invoking Selective Leaching for cop:)er alloys with > 15% zinc. AP-70 addresses loss of material through pitting and crevice corrosion for copper alloys by invoking a "plant specific" program. The OC LRA's use of AP-70 invoked One-Time Inspection and, where applicable, Water Chemistry, and also specified AP-32 for each instance where the copper alloy was subject to selective leaching. The OC LRA is therefore in compliance with GALL.

19. SP (VIII.J-2, 20 line item occurrences): piping, components, elements; steel; raw water; loss of material/general, pitting, crevice corrosion and MIC; plant specific program 9/05 GALL Master list replacement: No recommendation OC LRA effect: No changes required. No GALL explanation is given for deletion of SP-

51. Similar GALL line items (all address steel in raw water) include A-31, A-32, A-33, A-38, and E-22, which specify Open Cycle Cooling, Fire Water System, or plant specific programs. All instances of line item SP-51's use in the OC LRA are in floor drain systems, and the OC LRA specifies the One-Time Inspection program as the plant specific program for detecting the loss of material aging effect due to corrosion (to confirm absence of aging effects in pooled or stagnant areas of drain piping). The One-Time Inspection program provides an equivalent level of scrutiny as the programs used in the similar line items listed above.

20. SP (VIII.J-1, 13 line item occurrences): piping, components, elements; SS; raw water; loss of material/pitting and crevice corrosion; plant specific program 9/05 GALL Master list replacement: No recommendation OC LRA effect: No changes required. No GALL explanation is given for deletion of SP-

52. Similar GALL line items (all address SS in raw water) include A-53, A-54, A-55, AP-Page 6 of 7

Rev. 1 Attachment 4 55, and SP-36, which specify Open Cycle Cooling or Fire Water System programs. All instances of line item SP-52's use in the OC LRA are in floor drain systems, and the OC LRA specifies the One-Time Inspection program as the plant specific program for detecting the loss of material aging effect due to corrosion (to confirm absence of aging effects in pooled or stagnant areas of drain piping). The One-Time Inspection program provides an equivalent level of scrutiny as the programs used in the similar line items listed above.

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Attachment 5 AMR Line Items used in the Oyster Creek LRA for which Changes in the September 2005 Revision 1 GALL were not solely Administrative

Rev. 1 Attachment 5 "Non-Administrative" Changes to Line Items from January 2005 Draft GALL to September 2005 Revision I GALL (Items Not Previously Identified by Further Evaluation Changing from No to Yes)

1. A-104: Program was Plant Specific, now Bolting Integrity (VII.El-1, 1 occurrence)

OC LRA effect: None - OC LRA used Bolting Integrity for this occurrence of A-1 04

2. A-50: Programs were Closed Cycle Cooling Water and Selective Leaching; now just Selective Leaching (CCCW removed) (VI.C2-7, 14 occurrences)

OC LFRA effect: None - OC LRA is conservative in specifying both CCCW and SL

3. A-63: Galvanic Corrosion added as aging mechanism to general, pitting, and crevice corrosion for steel heat exchanger components (VII.C2-1, 15 occurrences)

OC LFRA effect: None - CCCW is used for A-63 to identify corrosion as recommended by GALL and would identify the effects of galvanic corrosion

4. A-64: Galvanic Corrosion added as aging mechanism to general, pitting, crevice corrosion, and MIC for steel heat exchanger components (VII.C2-3, 2 occurrences)

OC LFRA effect: None - OCCW is used for A-64 to identify corrosion as recommended by GALL and would identify the effects of galvanic corrosion

5. A-65: Galvanic Corrosion added as aging mechanism to pitting and crevice corrosion, MIC, and fouling for copper alloy heat exchanger components (VII.CI-1, 2 occurrences)

OC LFtA effect: None - The Fire Water System program is used for A-65 to identify corrosion and would identify the effects of galvanic corrosion

6. AP-30: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VII.E4-17, 24 occurrences; H2-20, 30 occurrences.; C2-13, 4 occurrences.; G-20, 4 occurrences.; F4-14, 1 occurrence.)

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

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

OC LRA effect: None - OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs. This is in compliance with September 2005 GALL.

8. AP-47: Deleted Galvanic Corrosion aging mechanism; program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VI .H2-10, 10 occurrences; C1-6, 6 occurrences)

OC LFA effect: None - OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs. This is in compliance with September 2005 GALL.

9. AP-59: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VII.H2-17, 14 occurrences)

OC LFA effect: None - OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs. This is in compliance with September 2005 GALL.

10. C-12: Programs were ASME Section Xl IWE, Appendix J, and Protective Coating Monitoring and Maintenance if credited, now Protective Coating program is deleted (II.B4-1, 19 occurrences)

Page 1 of 5

Rev. 1 Attachment 5 OC LRA effect: None - OC LRA uses IWE and Appendix J programs in each occurrence, and the Protective Coatings program where credited; this matches the September 2005 GALL and use of the Protective Coatings program is conservative

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

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

12. C-16: Programs were ASME Section Xl IWE, Appendix J, and Protective Coating Monitoring and Maintenance if credited, now Protective Coating program is deleted (11.B4-5, 10 occurrences)

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

13. C-19: Programs were ASME Section XI IWE, Appendix J, and Protective Coating Monitoring and Maintenance if credited, now Protective Coating program is deleted (l1.B1.1-2, 62 occurrences)

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

14. C-22: Not a significant change (wording clarification in GALL AMP recommendation) (IBI.1.1-5, 12 occurrences)

OC LRA effect: None - OC LRA applications of this line item use the aging management programs specified by September 2005 GALL (ASME Section Xl, Subsection IWE and Appendix J).

15. C-23: Graphite plate deleted from applicable material, steel remains (II.B1.1-1, 1 occurrence)

OC LRA effect: None - OC LRA only used this item for steel

16. E-33: Program was Plant Specific, now Water Chemistry augmented by One-Time Inspection (V.C-4, 4 occurrences)

OC LRA effect: None - OC LRA uses the Water Chemistry program augmented by the One-Time Inspection program

17. E-42: Added "with or without coating or wrapping" to steel pipe material, and added MIC aging mechanism (V.B-8, 1 occurrence)

OC LRA effect: None - OC LRA uses Buried Pipe Inspection per GALL to manage this aging effect of loss of material

18. EP-24: Not a significant change (replaces stress relaxation with thermal effects, gasket crEep, and self-loosening to mechanisms)

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

OC LRA effect: None - OC LRA uses the Water Chemistry program augmented by the One-Time Inspection program

20. LP-01: Change to name of GALL recommended program (VI.A-8, 1 occurrence)

OC LRA effect: None - OC LRA states that fuse holders (not part of a larger assembly) do not experience the aging effects identified in NUREG-1 801 due to their location and environment. See OC LRA Subsection 3.6.2.3.1 for additional information.

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

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Rev. I Attachment 5 OC LRA effect: None - OC LRA states that FRCT phase busses are coated to prevent oxidation, and connections are taped. Heating caused by corrosion or loosening of bolted connections would cause degradation of the tape covering detectable during a visual inspection.

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

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

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

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

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

CASS only needs to be identified when thermal or neutron embrittlement is an issue) (IV.A.1-6, 23 occurrences; IV.C1-11, 61 occurrences)

OC LRA effect: None - OC LRA uses the TLAA AMP in accordance with September 2005 GALL to manage this aging effect. September 2005 GALL added line item R-220 to address the piping, piping components and piping elements removed from R-04; the material, environment, aging effect'mechanism, and program (TLAA) for R-220 are the same as those invoked by the 00 LRA.

25. R-1 5: Deleted steel as a material from Isolation condenser components, SS remains as material.

No change to programs (IV.C1-5, 2 occurrences)

OC LRA effect: None - both occurrences in the OC LRA are for the isolation condenser system and are for SS components, in accordance with September 2005 GALL.

26. R-1 6: In the January 2005 Draft GALL, programs were ASME Section Xl IWB/C/D for Class 1 components and Water Chemistry, with augmentation consisting of isolation condenser shell water temperature and radiation monitoring, and eddy current testing of tubes, and verification of effectiveness of the program; in the September 2005 Rev. 1 GALL, programs specified are Water Chemistry and One-Time Inspection (IV.C1-6, 2 occurrences)

OC LRA effect: None - OC LRA credits inspections under Section Xl ISI in lieu of September 2005 GALL's One-Time Inspection; Water Chemistry is also specified. In addition, OC has committed to isolation condenser shell water temperature and radiation monitoring, and eddy current tes:ing of tubes, and verification of effectiveness of the program (as continues to be specified by GAL.L for the cracking aging effect under line item R-15), and these programs in conjunction with the large number of existing samples of components subject to the Water Chemistry and One-Time Inspection programs support the conclusion that the programs adequately manage the subject aging e ffect of loss o Fmaterial.

27. R-27: Deletes "High-Strength" qualifier from the material, adds thermal effects, gasket creep, and self-loDsening to mechanisms (IV.C1-12, 1 occurrence)

OC LRA effect: None - OC LRA uses the Bolting Integrity program in accordance with GAL.L to manage the loss of preload aging effect

28. R-53: Deletes CASS from material, presumably for the reasons listed for R-20 (SS and CASS share aging effects and mechanisms - CASS only needs to be identified when thermal or neutron embrittlement is an issue) (IV.B1-14, 20 occurrences)

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Rev. 1 Attachment 5 OC LRA effect: None - SS, CASS, and nickel alloy material components in the OC LRA identify this line item for cumulative fatigue, specifying the TLAA program, and continue to be in compliance with GALL.

29. R-98: Adds inspection specifications for top guides if fluence exceeds the IASCC threshold amount (IV.B1-16, 2 occurrences)

OC LRA effect: None - OC has top guides that have exceeded the IASCC threshold - the use of the R-98 line item in the LRA includes a plant specific note identifying that enhanced inspections are to be performed, and these inspections are discussed in Appendix B for B.1.9 (BWR Vessel Internals program). The September GALL specifications are incorporated.

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

OC LRA effect: None

31. S-13: Adds steel to SS for material of tanks (VIII.E-32, 2 occurrences)

OC LRA effect: None

32. S-18: Deletes "shell side" or "tube side" specificity for heat exchangers (VIII.E-3, 14 occurrences)

OC LRA effect: None - Water Chemistry and One-Time Inspection programs are used as specified by September 2005 GALL

33. S-21: Deletes "shell side" or "tube side" specificity for heat exchangers (VIII.E-2, 8 occurrences)

OC LRA effect: None - Water Chemistry and One-Time Inspection programs are used as specified by September 2005 GALL

34. S-23: Deletes "shell side" or "tube side" specificity for heat exchangers, adds galvanic corrosion to aging mechanism (VIII.E-6, 4 occurrences)

OC LRA effect: None - Closed Cycle Cooling Water program is used as specified by September 2005 GALL

35. S-25: Deletes "shell side" or "tube side" specificity for heat exchangers (VIIl.E4, I occurrence)

OC LRA effect: None - Closed Cycle Cooling Water program is used as specified by September 2005 GALL

36. S-33: Adds thermal effects, gasket creep, and self-loosening to mechanisms (VIII.H-5, 10 occurrences)

OC LRA effect: None - Bolting Integrity program is used as specified by September 2005 GALL

37. SP-16: September 2005 Revision 1 GALL deleted the PWR qualifier (VIII.D24, 44 occurrences)

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

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

OC LRA effect: None - OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs. This is in compliance with September 2005 GALL.

39. SP-38: Program was Plant Specific, now Lubricating Oil Analysis augmented by One-Time Inspection (VIII.A-2, 12 occurrences)

OC LRA effect: None - OC LRA uses the corresponding Lubricating Oil Monitoring and One-Time Inspection programs. This is in compliance with September 2005 GALL.

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Rev. 1 Attachment 5

40. TP-8: Galvanized steel removed from material, now only aluminum; aging effect/mechanism was loss of material/galvanic corrosion, now None; program was Structures Monitoring, now Ncne (111.B5-2, 1 occurrence; lll.B1.2-3, 2 occurrences; 1ll.B2-4, 26 occurrences)

OC LRA effect: None - OC LRA uses this item for galvanized steel material components with no aging effect and no program specified, explained with an "I" standard note. This is in conformance with September 2005 GALL, in which new line item TP-1 1 has been added to address the galvanized steel material removed from TP-8, and lists aging effect and program of None - None.

41. T-14: Aging Management Program Description continues to specify Water Chemistry prog-ram and monitoring of the spent fuel pool water level, and adds clarification of "in accordance with technical specifications and leakage from the leak chase channels" (III.A5-13, 2 occurrences)

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

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

Page 5 of 5

Attachment 6 AMOR Line Items used in the Oyster Creek LRA which invoke Plant-Specific Programs Requiring Further Evaluation in both the January 2005 Draft and September 2005 Revision 1 SRP

Rev. 1 Attachment 6 AMR Line Items used in the Oyster Creek LRA which invoke Plant-Specific Programs Requiring Further Evaluation in both the January 2005 Draft and September 2(105 Revision I SRP Line Further Item January 05 Draft SRP September 05 Revision 1 Evaluation NIt. section SRP section Significant 1_A09_.32.210._33.22.1.5Change 2 A-19 3.3.2.2.10.2 3.3.2.2.10.5 No 2 A-16 3.3.2.2.5.2 3.3.2.2.5.2 No 3 A-17 3.3.2.2.5.1 3.3.2.2.5.1 No 4 A-1 8 3.3.2.2.13 3.3.2.2.13 No 5 A-2:7 3.3.2.2.7.3 3.3.2.2.7.3 No 6 A-46 3.3.2.2.10.2 3.3.2.2.10.3 No 7 A-71 3.3.2.2.3.2 3.3.2.2.3.2 No 8 A-73 3.3.2.2.13 3.3.2.2.13 No 9 A-85 3.3.2.2.3.2 3.3.2.2.3.2 No 10 A-89 3.3.2.2.14 3.3.2.2.6 No 11 AP-:33 3.3.2.2.3.2 3.3.2.2.3.3 No 12 E-06 3.2.2.2.5 3.2.2.2.5 No 13 LP-07 3.6.2.2.5 3.6.2.2.2 No 14 LP-08 3.6.2.2.6 3.6.2.2.3 No 15 LP-1 1 3.6.2.2.5 3.6.2.2.2 No 16 R-61 3.1.2.2.4.2 3.1.2.2.4.1 No 17 RP- 8 3.1.2.2.11 3.1.2.2.11 No 18 SP-37 3.4.2.2.7.2 3.4.2.2.7.2 No Page 1 of 1

Attachment 7 Evaluation of Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL)

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL)

Rev. 1 Attachment 7 September 2005 Revision III _ Oyster Creek LRA Item II Material I

Environment

[ Aging Management II I Structure I IF __e- IA -:I- .I Copnent Effect Item andlor Material Environment Comments roamC pnetEffect Program AP-73 Piping, piping Stainless Sodium Loss of Chapter Xl.M2. 'Water A-58 Piping and fittings. Stainless Sodium Loss of Water Chemistry program Line Item A-58 is for treated components, and piping sleel pentaborate material/ Chemistry." for BWR tanks, steel pentaborate material (B.1.2) and the One-Time water environment but was elements solution pitting and walerThe AMP is to be thermowells, and Inspection program applied to sodium pentaborate.

crevice augmented by verifying valve bodies (B.1.24) to verify the The AMR included plant specific corrosion the effectiveness of effectiveness of water note: The Aging Management water chemistry chemistry control. Programs for the aging effect of control. See Chapter 'Loss of Malerial in the Treated XI.M32, One-Time Water environment identified in Inspection,' forthe referenced NUREG-1801 acceptable verification Volume 2 Item column were program. applied to the Sodium Pentaborate environment since Sodium Pentaborate approximates Treated Water in aggressivify as identified in NUREG-1801 Volume 2 Chapter IX.

AP-74 Piping, piping Aluminum Condensation Loss of A plant-specific aging N/A N/A N/A N/A N/A N/A The material and environment components, and piping material/ management program combination of aluminum and elements pitting and is to be evaluated, condensation is not applicable.

crevice corrosion __ .

AP-75 Elastomer seals and Elastomers Raw water Hardening Chapter XI.M20 *Open N/A Expansion joints Elastomer Raw water -fresh Change in Periodic Inspection The plant specific Periodic components and loss of Cycle Cooling Water waler and raw material Program (B.2.5) Inspection Program provides for strengthl System' waer - salt water properties the identification of cracking.

elastomer hardening. or tears in elastomer degradation expansion joints in raw water.-

salt water and raw water - fresh water environments.

AP-76 Elastomer seals and Elastomers Raw water Loss of Chapter XI.M20. Open N/A N/A N/A N/A N/A N/A Oyster Creel LRA Table 3.04 for components material/erosi Cycle Cooling Waler elastomers defines change in on System' material properties as increased hardness, shrinkage and loss of strength due to weathering and hardening and loss of strength due to elastomer degradation.

Change in material properties ds not inude loss of material dueto erosion. Table 3.0-4 does not define loss of material for elastomera (non-metallics). The periodic inspections performed fo'change in material properties" would identify the toss of material.

AP-77 Heat exchanger tubes Steel Closed cycle Reduction of Chapter XI.M21, N/A Coolers and heat Carbon steel Closed Cooling Reduction Closed-Cycle Cooling None.

cooling water heat transfer/ Closed-Cycle Cooling exchanger tubes and cast iron Water of Heat Water System (B.1.14)

I Itouling IWater System" J I I I ITransfer I page 1 of 40

Evaluation of AMR Une Items Added by the September 2005 Revision 1GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 _ Oyster Creek LRA l I I _ _ - J__- I I I~ _ I Aging l Structure __ __ s__ D_ I Matera l EnvironmentIF Management Item and/or Material Environment E p .....

ffect Comments Effect Program Componn Effect Program AP-78 Piping, piping Copper Condensation Loss of A plant-specific aging NA N/A N/A N/A N/A N/A The material and environment components, and piping alloy (Internal) ateria management program combination of copper alloy and elements pitting and is to be evaluated. condensation is not applicable.

crevice corrosion AP.79 Piping, piping Stainless Treated borated Loss of Chapter Xt.M2, 'Water N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

components, and piping Steel; Steel water material/ Chemistry, for PWR elements with pitting and primary water stainless crevice steel corrosion cladding _ _ _ _ _ _ _ _ _ _ _ _ ___

AP-80 Heat exchanger tubes Copper Closed cycle Reduction of Chapter Xl.M21, N/A Shutdown Cooling Copper Closed Cooling Reduction Closed-Cycle Cooling Addressed with a non-GALL item Alloy cooling water heat transfer/ 'Closed-Cycle Cooling Pumps seal Water of Heat Water System (B.1.14) invoking CCCW for SDC pump fouling Water System' coolers (RBCCW Transfer seal coolers in OC LRA.

LR System) The Emergency Diesel Generator and Auxiliary System brass lube oil cooler and radiator tubes exposed to a closed cooling water environment do not include the Reduction of Heat Transfer aging effect based on EPRI Mechanical Tools Apnix G. InEPRI Mechanical Tools Appendix G, fouling is not identified as a significant aging effect for copper alloy heat ecagers in a closed cooling water environment. Addition of this tine item to the Emergency Diesel Generator and Auxiliary System AMR is required.

page 2 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision I l l Oyster Creek LRA m--

_ _ _ l Item

-MateIa Comnponentn l

IF EManagement gn Item I Structure and/or IIIMaterial Environment Efct I ;. .iCm gComments et

__________ Effect_ Program Component EffctProra AP1 Piping, piping Stainless Condensation Loss of Chapter XI.M24, A-12 Drain traps, drip Stainless Condensation Loss of One-Time Inspection The stainless steel components components, and piping steel material/ Compressed Air legs, filter steel material (B.1.24) in the Hydrogen & Oxygen elements pitting and Monitoring housings, flow Monitoring (H202) System and crevice elements, heat the Nitrogen Supply (N2) System corrosion exchanger coils, subject to condensation moisture nvironments are associated separators, piping with moisture removal portions of and fittings, pump the systems and are not casings, tanks, associated with compressed air valve bodies, and systems. In the H202 System, waler separators moisture is removed from the containment atmosphere, which is inerted with nitrogen, prior to entering the H202 monitoring equipmenL In the N2 System.

moisture is removed from the containment atmosphere, which is inerted with nitrogen, prior to entering TIP nitrogen purge instrumentation. Inboth cases.

impurities and oxygen content are low, thus, significant aging effects on stainless steel are not anticipated. The One-Time Inspection aging management program will be used to provide additional assurance that aging that has not yet manifested itself is not occurring, or that the evidence of aging shows that the aging is so insignificant that an aging management program is

__ .not_ warranted.

AP-82 Piping, piping Stainless Treated borated Cracking/ Chapter Xl.M2, Water N/A N/A N/A N/A N/A N/A Applicable to PWR s only.

components, piping steel water >60-C stress Chemistry, for PWR elements, and tanks (>140'F) corosion primary water cracking AP-83 Piping, piping Aluminum Raw water Loss of Chapter XI.M26, 'Fire N/A Water Motor Alarm Aluminum Raw water - fresh Loss of Fire Water System (B.1.20) The Oyster Creek Fire Water components, and piping materiaV Protection water material System (B.1.20) aging elements pitting and management program applies to crevice water-based fire protection corrosion systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes. water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and standards or approved Fire Protection Program

_ _. commitments.

page 3 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision I GALL (Items not previously included inthe JanuarY 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 l l Oyster Creek LRA l Item I # *-I II.;-

Material Environment I Aging II I Structure [IMaterial A_1_ I A aM1.-- ... -4

. Management Item and/or Environment CompnentEffctPgrComponent ... Comments AP-85 Effect Program Pump Casings Steel with Treated borated Loss of A plant-specific aging N/A N/A N/A N/A N/A Applicable to PWRs only.

stainless water materiaV management program steel cladding is to be cladding breach evaluated.Reference NRC Information Notice 94-63, Boric Acid Corrosion of Charging Pump Casings Caused by Cladding Cracks.'

C-25 Concrete:Basemat Concrete Ground water/soil Increase in Chapter Xl.52, *ASMVE N/A N/A N/A NA N/A N/A Concrete containment -not porosity and Section Xl, Subsection applicable to Oyster Creek.

permeabilityiWL'Accessible cracking, Areas:lnspections loss of performed in material accordance with IWL (spatting, will indicate the gy psence of increase aggressive in porosity and chemical permeability, surface attack cracking, or loss of material (spalling.

scaling) due to aggressive chemical attack.Inaccessible Areas:For plants With non-aggressive ground water/soil; i.e., pH >

5.5, chlorides < 500 ppm, or sulfates <1500 ppm, as aminimum, consider (1)

Examination of the exposed portions of the below grade concrete, when excavated for any reason, and(2)

Periodic monitoring of below-grade water chemistry, including page4of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 L September 2005 Revision 1 Su r Oyster Creek LRA l Material Environment . ffManagement Item and/or Material Environment ....... Comments CmoetEffect Program _ __ Component Effect Program consideration of potential seasonal variations.For plants with aggressive groundwaterlsoil, and/or where the concrete structural elements have expenenced degradation, a plant specific AMP accounting for the extent of the degradation experienced should be implemented to manage the concrete aging during the period of extended operation.

C-26 Concrete:Containment; Concrete Ground water/soil Increase in Chapter XI.S2, ASME N/A N/A N/A N/A N/A N/A Concrete containment -not wall; basemat or air-indoor porosity and Section Xi. Subsection applicable to Oyster Creek.

uncontrolled or air- permeability, IWLAccessible outdoor cracking, Areas:lnspections loss of performed in mateal accordance with IWL (spalling, wilt indicate the scalingy presence of increase aggressive in porosity and chemical permeability, surface attack cracking, or loss of material (spalling.

scaling) due to aggressive chemical attack.inaccessible Areas:For plants with non-aggressive ground water/soil; i.e., pH >

5.5, chlorides < 500 ppm, or sulfates <1500 ppm, as a minimum, consider (1)

Examination of the exposed portions of the below grade concrete, when excavated for any reason. and(2)

Periodic monitoring of below-grade water chemistry, including

__ _ j

_ _ _ _ _ _ J _ _ _ II I_ __ . ~i _ .

_ _ l__ _ l _ _ _ I _ .__

_I_

page 5 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 l l Oyster Creek LRA l

[ 1.Inei/!1 1 1 Antnn l Aging i i i Structure 1 1

1 l I _A .1.. l Com onent Material Environmen ct Management Item and/or Material EnvironmentaComments Copnn fet Program Componn fec rga consideration of potential seasonal vanations.For plants with aggressive groundwater/soil, and/or where the concrete structural elements have experienced degradation, a plant specific AMP accounting for the extent of the degradation experienced should be implemented to manage the concrete ging during the period of extended operation.

C-27 Concrete:Dome; wall: Concrete Ground water/soil Increase in Chapter XI.S2, *ASME N/A N/A N/A N/A N/A N/A Concrete containment - not basemat or air-indoor porosity and Section Xl, Subsection applicable to Oyster Creek.

uncontrolled or air- permeability, IWLAccessible outdoor cracking. Areas:lnspections loss of performed in material accordance with IWL (spalling, will indicate the scalingy presence of increase aggressive in porosity and chemical permeability, surface attack cracking, or loss of material (spalling, scaling) due to aggressive chemical attack.Inaccessible res:For plants with non-aggressive ground water/soil; i.e., pH >

5.5, chlorides < 500 ppm, or sulfates <1500 ppm, as a minimum, consider (1)

Examination of the exposed portions of the below grade concrete, when excavated for any reason, and(2)

Periodic monitoring of below-grade water chemistry, including I __ _ __ _ _ _ I _ _ _ I _ _ _ _ _ _ _ . _ _ _ I _ _ il_ _ _ _ _ _ l _ _ _ _ _ I__

page 6 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. I Attachment 7 September 2005 Revision II l Oyster Creek LRA I I I +^ 7.

_F . ..y Aging lllA'- l llStructure I I l _- I I I Item Material Environment E fec Management Item and/or Material Environment "Ag':;V . ' . .. Comments Component Effect Program Component Effect Program consideration of potential seasonal variations.For plants with aggressive groundwater/soil, .

and/or where the concrete structural elements have experienced egradation, aplant specific AMP accounting for lire extent of the degradation experienced should be ipeented to manage the concrete aging during the period of extended operation.

C-28 Concrete:Basemat Concrete Air - outdoor Loss of Chapter Xl.S2, ASMIE N/A N/A N/A N/A N/A N/A Concrete containment -not material Section XlI Subsection applicable to Oyster Creek.

(spalling, IWLAccessible scaling) and areas:Inspections cracking/ performed in freeze-thaw accordance with IWL will indicate the presence of loss of material (spalling.

scaling) and surface cracking due to freeze-thaw.Inaccessible Areas:Evaluation is needed for plants that are located in moderate to severe weathering conditions (weathering index

>100 day-inch/yr)

(NUREG-1557).

Documented evidence confirms that where the existing concrete had air content of 3%to 6%. subsequent inspection did not exhibit degradation related to freeze-thaw.

_ __ __ ____ __ _ _ __ __ __ _ ___ _ __ _ _ _ _ __ _ _.__ . J...........l__ __ _ _ _ _ __ _ _ J _l__ _ _ _ _ .. _ __ _ _ i _ _l__ _ _ _ _ _ __ I _ _ _ _ _I__ _ _ _ _ _

page 7 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously inctuded in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 1l _ Oyster Creek LRA Item C I I Material Environment I _ _

Af'e" I Aging Management H Item Structure and/or I

Material I I __, l ,, . I Environment "U&"'9 l~"l "yi'141OUV"B' l Comments Component Effect Program Component Effect Program Such inspections should be considered a part of the evaluation.The weathering index for the continental US is shown in ASTM C33-90, Fig. 1.

C-29 Concrete:Dome; wall; Concrete Air - outdoor Loss of Chapter Xl.S2, ASME N/A N/A N/A N/A N/A N/A Concrete containment - not basemat material Section Xl, Subsection applicable to Oyster Creek.

(spalling, IWLAccessible scaling) and areas:lnspections cracking/ performed in freeze-thaw accordance with IWL will indicate the presence of loss of material (spalting.

scaling) and surface cracking due to freeze-thaw.lnaccessible Areas:Evaluation is needed for plants that are located in moderate to severe weathering conditions (weathering index

>100 day-inch/yr)

(NUREG-1557).

Documented evidence confrims that where the existing concrete had air content of 3% to 6%. subsequent inspection did not exhibit degradation related to freeze-thaw.

Such inspections should be considered a part of the evaluation.The weathering index for the continental US is shown in ASTM C33-90, Fig 1. _

page 8 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 I I Oyster Creek LRA l II II I Ag ing I I structure I.-I. I I A Item .

S ,' Material Environment c I~" Management Item and/or Material Environment fect Program Comments Co pnetEfet Program Component Efc rga C-30 Concrete:Basemat Concrete Water - flowing Increase in Chapter XL.S2, *ASME N/A N/A N/A N/A N/A N/A Concrete containment -not porosity, Section Xl, Subsection applicable to Oyster Creek.

permeability/ IWLAccessible leaching of areas:lnspections calcium performed in hydroxide accordance with IWL will indicate the presence of increase in porosity, and permeability due to leaching of calcium hydroxide.Inaccessible Areas; An aging management program is not necessary, even if reinforced concrete is exposed to flowing water, if there is documented evidence that confirms the in-place concrete was constructed in accordance with the recommendations in ACt 201.2R.

C-31 Concrete:Containment; Concrete Water- flowing increase in Chapter XL.S2,'ASME N/A N/A N/A N/A N/A N/A Concrete containment - not wall; basemat porosity. Section Xl, Subsection applicable to Oyster Creek.

permeability/ IWLAccessible leaching of areas:lnspections calcium performed in hydroxide accordance with IWL will indicate the presence of increase in porosity, and permeability due to leaching of calcium hydroxide.lnaccessible Areas An aging management program is not necessary, even if reinforced concrete is exposed to flowing water, if there is documented evidence that confirms the in-place concrete was constructed in l______ _______l l ____ _ l __ JACI accordance with the recommendations in 201.2R-77. l l I l l l I l l page 9 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September2005Revision 1 A Su r Oyster Creek LRA tr-t-ilom Itm Component 1 I MaeiI al I Material Environment I

Effect I Aging Management Progra I I Item I Structure andlor Component Material Environment Effect I A"'-" RA - T Comments

____ EfetProgram C-32 Concete:Dome; wall, Concrete Water -flowing Increase in Chapter XI.S2, 'ASME N/A N/A N/A N/A N/A N/A Concrete containment - not basemat porosity, Section Xl, Subsection applicable to Oyster Creek.

permeability/ IWLAccessible leaching of areas:lnspections calcium performed in hydroxide accordance with IWL will indicate the presence of increase in porosily, and permeability due to leaching of calcium hydroxide.Inaccessible Aras:An aging management program is not necessary, even if reinforced concrete is exposed to flowing water, if there is documented evidence that confirms the in-place concrete was construcded in accordance with the recommendations in ACI 201.2R-77.

page 10 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision I l l Oyster Creek LRA ___

I C#-# -r; 1 I- I I I Aging Structure l I l IcR Item l Material Environment Effect Management Item and/or Material Environment Ef.fect 1 n I Pogram Comments I___I___Program I_____

C-33 Concrete:Dome; wall; Concrete Air- indoor Reduction of Plant-specific aging N/A N/A N/A NI/A N/A N/A Concrete containment -not basemat uncontrolled or air strength and management applicable to Oyster Creek.

outdoor modulus/ programThe elevated implementation of 10 temperature CFR 50.55a and

(>150F ASME Section Xl, general; Subsection IWL would

>200'F local) not be able to identify the reduction of strength and modulus due to elevated temperature. Thus, for any portions of concrete containment that exceed specified temperature limits, further evaluations are warranted. Subsection CC-3400 of ASME Section III, Division 2, specifies the concrete temperature limits for normal operation or any other long-term period. The temperatures shall not exceed 150'F except for local areas, such as around penetrations, which are not allowed to exceed 200'F.

If significant equipment loads are supported by concrete at temperatures exceeding 150'F, an evaluation of the ability to withstand the postulated design loads is to be made.Higher temperatures than given above may be allowed in the concrete if tests and/or calcutations are provided to evaluate the reduction in strength and this reduction is applied to thedesign allowables. _ _ l l J l ll l __

page 11 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously inctuded in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 l l Oyster Creek LRA Item I

Matra Environment En n ent

_,__., I Aging

-MaterialManagement I

Item I

I Structure and/or Material

[IEnvironment .

in anagement Comments l

Cmoetfet Program ICompon t .Effect Program C-34 Concrete:Basemat Concrete Air - indoor Reduction of Plant-specific aging N/A N/AN/A N/A N/A Concrete containment - not uncontrolled or air strength and management applicable to Oyster Creek.

outdoor modulus/ programThe elevated implementation of 10 temperature CFR 50.55a and

(>150'F ASME Section Xl, general; Subsection IWL would

'200'F local) not be able to identify the reduction of strength and modulus due to elevated temperature. Thus, for any portions of concrete containment that exceed specified temperature limits, further evaluations are warranted. Subsection CC-3400 of ASME Section 1I1,Division 2, specifies the concrete temperature limits for normal operation or any other long-term period. The temperatures shall not exceed 150'F except for local areas, such as around penetrations, which are not allowed to exceed 200'F.

I1significant equipment loads are supported by concrete at temperatures exceeding 150'F, an evaluation of the ability to withstand the postulated design loads is to be made.Higher temperatures than given above may be allowed in the concrete if tests and/or calculations are provided to evaluate the reduction in strength and this reduction is applied to the design a llowables.w __l l page 12 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 I _I Oyster Creek LRA l I I ,,,,, I I I I ging Structure 1 1 [

I ---

Item Material Environment a - Management Item and/or Material Environment l " ea Cmponent Comments Effect Program ComponntEffect Program C-35 Concrete:Containment; Concrete Air- indoor Reduction of Plant-specific aging N/A N/A N/A N/A N/A N/A Concrete containment - not wall; basemat uncontrolled or air strength and management applicable to Oyster Creek.

outdoor modulus/ programThe elevated implementation of 10 temperature CFR 50.55a and

(>150'F ASME Section Xl, general; Subsection IWL would 200-F local) not be able to identify the reduction of strength and modulus due to elevated temperature. Thus, for any portions of concrete containment that exceed specified temperature limits, further evaluations are warranted. Subsection CC-3400 of ASME Section 1II, Division 2, specifies the concrete temperature limits for normal operation or any other long-term period. The temperatures shall not exceed 150F except for lcal areas, such as around penetrations, which are not allowed to exceed 200'F.

If significant equipment loads are supported by concrete at temperatures exceeding 150'F, an evaluation of the ability to withstand the postulated design loads is to be made.Higher temperatures than given above may be allowed in the concrete if tests and/or calculations are provided to evaluate the reduction in strength and this reduction is applied to the design allowablesJ.. l l l page 13 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 I 1 Oyster Creek LRA Item I f-- -l I I V gn I structure I Material 1 Environment I1.. I1. .

Material Environment i Management Item andlor "11OU A i 1 dy IR Comments Component Effect Program Component Effect Program C-36 Concrete:Basemat Concrete Soil Cracks and Chapter XI.S6, N/A N/A N/A N/A N/A N/A This item is for PWR steel distortion due 'Structures Monitoring containments or BWR Mk II to increased Program If a de- concrete containment - not stress levels watering system is applicable to Oyster Creek. The from relied upon for control Oyster Creek LRA uses line item settlement of settlement, then the T-08 for analogous containment licensee is to ensure . components.

proper functioning of the de-watering system through the period of extended operation.

C-37 Concrete:Dome; wall; Concrete Soil Cracks and Chapter XI.S6, N/A N/A N/A N/A N/A N/A This item isfor PWR concrete basemat; ring girders; distortion due 'Structures Monitoring containments - not applicable to buttresses to increased Program if a de- Oyster Creek.

stress levels watering system is from relied upon for control settlement of settlement, then the licensee is to ensure proper functioning of the de-watering system through the period of extended operation.

page 14 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 l l Oyster Creek LRA l I ~_ I Aging I II I stucur I _ I _ I _ -. I__ _ I_

Item .Material Environment . I Management Item and/or Material Environment - .......; " Comments Component EfctI Progra ____ Component Effect Program C-38 Concrete:Basemat Concrete Any Cracking due Chapter XL.S2, 'ASME N/A N/A N/A N/A N/A N/A Concrete containment - not to expansiord Section Xl, Subsection applicable to Oyster Creek.

reaction with IWL.Accessible aggregates Areas:Inspections performed in accordance with tWL will indicate the presence of surface cacking due to reaction with aggregates.inaccessibl e Areas:As described in NUREG-1557, investigations, tests, and petrographic examinations of aggregates performed in accordance with ASTIM C295-54 or ASTM C227-50 can demonstrate that those aggregates do not react within reinforced concrete. For potentially reactive aggregates, aggregate-reinforced concrete reaction is not significant if the concrete was constructed in accordance with ACI 201.2R.Therefore, if these conditions are satisfied, aging management is not necessary.

page 15 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision II I _ _._. _ .Oyster Creek LRA l I Irtr I A.1- Aging Structure I Aninn A.ninn Mn-,rn-*

item - Material Environment.. Management Item and/or Material Environment -i2!e' P r Component o g r a m .l Comments Efect Program Componn fec rga C-39 Concrete:Containment; Concrete Any Cracking due Chapter XI.S2, ASME N/A N/A N/A N/A N/A N/A Concrete containment - not wall; basemat to expansion/ Section Xl. Subsection applicable to Oyster Creek.

reaction with iWLAccessible aggregates Areas:lnspections performed in accordance with IWL will indicate the presence of surface cracking due to reaction with aggregates.inaccessibl e Areas:As described in NUREG-1557, investigations, tests, and petrographic examinations of aggregates performed in accordance with ASTM C295-54 or ASTM C227-50 can demonstrate that those aggregates do not react within reinforced concrete. For potentially reactive aggregates, aggregate-reinforced concrete reaction is not significant if the concrete was constructed in accordance with ACI 201.2R. Therefore, if these conditions are safsied, aging management isnot necesSary .

page 16of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 Item I

Component nIb.I September 2005 Revision Material I

Environment III IAnIn,.

Effc ct I

Aging Management ro amC ll II Item r _

structure and/or pnetEffect Material

[ Environment Oyster Creek LRA I

I .. .~. I,~

M ....... U" ;"Comments Program l

I C40 Concrete:Dome; wall; Concrete Any Cracking due Chapter XI.S2., ASMIE N/A N/A N/A Concrete containment -not basemat to expansion/ Section Xl, Subsection applicable to Oyster Creek.

reaction with IWLAccessible aggregates Areas:lnspections performed in accordance with IWL will indicate the presence of surface cracking due to reaction with aggregates.Inaccessibl e Areas:As described in NUREG-1557, investigations, tests, and petrographic examinations of aggregates performed in accordance with ASTM C295-54 or ASTM C227-50 can demonstrate that those aggregates do not react within reinforced concrete. For potentially reactive aggregates, aggregate-reinforced concrete reaction is not significant if the concrete was constructed in accordance with ACI 201.2R.Therefore, if these conditions are satisfied, aging management is not necessary. _.

page 17 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. I Attachment 7 September 2005 Revision 1 1l Oyster Creek LRA Item Q# #- -f I I T .- I ln Aging I Structure I I I ^-4'w I . - .I Material Environmen.t Management Item and/or Material Environment u "'%' Comments Component Effect Program Componn Effect Program C41 Concrete:Basemat; Concrete; Air - indoor Cracking, Chapter XI.S2, *ASME N/A N/A N/A N/A N/A N/A Concrete containment -not reinforcing steel steel uncontrolled or air loss of bond, Section Xl, Subsection applicable to Oyster Creek.

outdoor and loss of IWL.Accessible material Areas:lnspections (spalling, performed in scalingy accordance with IWL corrosion of will indicate the embedded presence of surfaca steel cracking, loss of bond.

and loss of material (spalling. scaling) due to corrosion of embedded steel.Inaccessible Areas:For plants with on-aggressive ground water/soil; i.e., pH >

5.5, chlorides < 500 ppm, or sutfates <1500 ppm, as a minimum, consider (1)

Examination of the exposed portions of the below grade concrete, when xcavated for any reason. and(2)

Periodic monitoring of below-grade water chemistry, including consideration of potential seasonal variations.For plants Nithaggressive

roundwater/soil, and/or where the

oncrete structural elements have experienced Jegradation, a plant specific AMP accounting for the extent of the degradation experienced should be implemented to manage the concrete aging during the period of extended operation.

page 18 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 l Oyster Creek LRA l Item Material Environment A~2 IAgng II I Structure Management Item and/or Material Environment l '" e. l .... Comments Compnenfect__ Program _ __ Component Effect Program C42 Concrete:Dome; wall; Concrete; Air - indoor Cracking, Chapter XI.S2, ASME N/A N/A N/A N/A N/A N/A Concrete containment - not basemat; reinforcing steel uncontrolled or air loss of bond, Section Xl, Subsection applicable to Oyster Creek.

steel outdoor and loss of IWLAccessible material Areas:tnspections (spalling, performed in scalingy accordance with IWL corrosion of will indicate the embedded presence of surface steel cracking. loss of bond, and loss of material (spalling, scaling) due to corrosion of embedded steel.Inaccessible Axeas:For plants with non-aggressive ground water/soil; i.e., pH >

5.5, chlorides < 500 ppm, or sulfates <1500 ppm, as a minimum, consider (1)

Examination of the exposed portions of the below grade concrete, when excavated for any reason. and(2)

Periodic monitoring of below-grade water chemistry, including consideration of potential seasonal variations.For plants with aggressive groundwater/soil, and/or where the concrete structural elements have experienced degradation, a plant specific AMP accounting for the extent of the degradation experienced should be implemented to manage the concrete aging during the period of extended operation.

page 19 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision II II Oyster Creek LRA Item I I I .. I Aging Structure .

Ite Copoen Effert Management Item and/or Material Environment " ...g -u"'u Comments

_______Efect Program Component Effect Program C-43 Concrete:Basemat; Concrete; Air - indoor Cracking. Chapter XI.S2. ASME N/A N/A N/A N/A N/A N/A Concrete containment - not reinforcing steel steel uncontrolled or air loss of bond, Section Xl, Subsection applicable to Oyster Creek.

outdoor and loss of IWL'Accessible material Areas:lnspections (spalling, performed in scalingy accordance with IWL corrosion of will indicate the embedded presence of surface steel cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of embedded steel.tnaccessible Areas:For plants with non-aggressive ground water/soil; i.e., pH >

5.5, chlorides < 500 ppm, or sulfates <1500 ppm, as a minimum, consider (1)

Examination of the exposed portions of the below grade conrete, when excavated for any reason, and(2)

Periodic monitoring of below-grade water chemistry, including consideration of nn----ia:-- - - --- - --

variations.For plants with aggressive 3roundwater/soil, and/or where the

oncrete structural elements have experienced Degradation, a plant specific AMP accounting for the extent of the Jegradation experienced should be mplemented to mnanage the concrete aging during the period Dfextended operation.

A.

_ _ ___ _ _ _ _ L __ _ _ . __ _ __ _ __ J _ _ _ _ _ .. _ __I page 20 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7

_ September 2005 Revision 1 A n 1 C Oyster Creek LRA l Item .mMaterial Environment E c management Item and/or Material Environment Effect gI........ Comments C44 Suppression pool shelt; Sleet; Air -indoor Cracking/ Chapter XI.SI, ASME N/A N/A N/A N/A N/A N/A Oyster Creek has a CLB fatigue unbraced downcomers stainless uncontrolled cyclic Section Xl. Subsection analysis - this line item is not steel; loading(CLB [WE' and Chapter applicable to Oyster Creek.

dissimilar fatigue Xl.S4. 10 CFR Part metal welds analysis 50, Appendix does not JEvaluation of 10 exist) CFR 50.55a/ASME Section Xl, Subsection IWE is to be supplemented to consider the following:(4) Detection of Aging Effects: Vr-3 visual inspection may not detect fine cracks.

C45 Suppression pool shell; Steel; Air -indoor Cumulative Fatigue isa time- C-13 Steel Steet Air - indoor Cumulative TLAA evaluated in Oyster Creek has braced unbraced downcomers stainless uncontrolled fatigue limited aging analysis (supp. elements:vent uncontrolled fatigue accordance with 10 CFR downcomers. Oyster Creek has steel; damage/ (TLAA) to be evaluated pool shell header, drywell damage 54.21(c) a CLB fatigue analysis.

dissimilar fatigue(Only for the period of penetatio head, torus, Penetrations in the suppression metal welds if CLO fatigue extended operation. ns) downcomers,pool Pool shell are evaluated with line analysis See the Standard shell item C-13 in the Oyster Creek exists) Review Plan, Section LRA.

4.6. tContainment Liner Plate and Penetration Fatigue naysis' for acceptable methods frmeeting the reuirements of 10

_ _____ _ _ ___ ____ _ _ _ _ _ __ __ __ _ __ __ __ _ _ _ F 5 .2 (c (1 ._ _ _ _ __ _ _ _ _ __ __ __ _ _ __ _ _ __ __ _ _ _ _ __F_ _ _ __ __ __ __ __ _ __ __ __ __ _ _ _ __ __ __ _

page 21 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7

_eptember 2005 Revision 1 I _ . Oyster Creek LRA l r Mat-fert' ia Item i a Aging e I I Structure I T I A!n__ 1 ArIl .I Comments and/or Material Environment Effat Pro m Comments Component Effect Program Componentt rora C-46 Steel elements: Steel Air- indoor Loss of Chapter XI.S1, 'ASME C-19 Steel elements: Steel Air - indoor Loss of ASME Section Xl, The Oyster Creek LRA evaluated Suppression chamber uncontrolled or material/ Section Xl, Subsection liner plate, uncontrolled material Subsection [WE, B.1.27. analogous items with C-19.

drywell liner; drywell treated water general, IWE'For inaccessible containment shell due to and 10 CFR Part 50, head; embedded shell; pitting, and areas (embedded downcomers. general, Appendix J. B.1.29 sand pocket region; crevice containment steel shell drywell support pitting and support skirt; downcomer corrosion or liner), loss of skirt. ECCS crevice pipes; region shielded by material due to suction header corrosion in diaphragm floor (as corrosion is not accessible applicable)NOTE: significant if the and Inspection of containment following conditions inaccessibi supports is addressed by are aatisfied:Concrete e areas ASME Section Xl. meeting the Subsection IWF (see specifications of ACI ll.B1.3) 318 or 349 and the guidance of 201.2R ws used for the containment concrete in contact with the embedded containment shell or liner. The concrete is monitored to ensure that it is free of penetrating cracks that provide a path for water seepage to the surface of the containment shell or liner. The moisture barier, at the junction where the shell or liner becomes embedded, is subject to aging management activities in accordance with ASME Section Xl, Subsection IWE requirements. Water ponding on the containment concrete floor are not common and when detected are ceaned up in a timely mannerIf any of the above conditions cannot be satisfied, then a plant-specific aging management program for corrosion is necessary.Chapter XI.S4. '10 CFl-t Part 50, Appendix J' _

page 22 of 40

Evaluation of AMR Une Items Added by the September 2005 Revision 1 GALL (Items not previously included inthe January 2005 Draft GALL) Rev. 1 Attachment 7 Spebr20ReiinIIIOyster Creek LR~Al If-f I-41-ter tm 1 1 1 Ig_ Aging I I I Structure I I I lI Il item jo ....... Material Environment Management Item and/or Material Environment ^ g,..Z ....... Comments rnoet~f-e ct Program I___ I Component Effect Program C-47 Steel elements:Vent Stainless Air -indoor Cracking/ Chapter XI.S 1, ASME N/A N/A NVA NIA N/A N/A Oyster Creek has a CLB fatigue header;Downcomers steel; steel uncontrolled cyclic Section XlI Subsection analysis - this line item is not loading(CLB IWE" and Chapter applicable to Oyster Creek.

fatigue XI.S4, 10 CFR Part analysis 50. Appendix does not J"Evaluation of 10 exist) CFR 50.55a/ASME Section Xl, Subsection WE is augmented as foflows:(4) Detection of Aging Effects: VT-3 visual inspection may not detect fine cracks.

C-48 Steel elements:Vent Stainless Air -indoor Cumulative Fatigue is a time- N/ A N/A N/A N/A N/A This item is for a Mark II header;Downcomers steel; steel uncontrolled or fatigue limited aging analysis containment and not applicable treated water damage/ (TLAA) to be evaluated to Oyster Creek. The Oyster fatigue(Only for the period of Creek LRA evaluated analogous if CLB fatigue extended operation. items with C-21.

analysis See the Standard exists) Review Plan, Section 4.6. 'Containment Liner Plate and Penetration Fatigue Analysis' for acceptable methods for meeting the requirements of 10 CFR 54.21(c)(1).

C-49 Steel Stainless Air - indoor Loss of Chapter XI.S1

ASME N/A N/A N/A NAN/ NA This is applicable to a concrete elements:Suppression steel; steel uncontrolled or materiali Section XlI Subsection containment with a steel liner -

chamber liner (interior treated water general, IWE' and Chapter not applicable to Oyster Creek.

surface) pitting, and XI.S4, "10 CFR Part crevice 50. Appendix J" corrosion page 23 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 I_ September 2005 Revision II _ _ _ Oyster Creek LRA Item I f et-itn In4~

Material I

Environment I .~.

.Management I Aging II Item I structure and/or I

Material I

Environment I . . I . I.1

-a" -' ...; Comments Component E lt Progra Component Effect Program C-50 Concrete:Basemat, Concrete Air- indoor Reduction of Plant-specific aging N/A N/A N/A N/A N/A N/A This isapplicable to a Mk.lll concrete fill-in annulus uncontrolled or air strength and management concrete containment -not outdoor modulus/ programThe applicable to Oyster Creek.

elevated implementation of 10 temperature CFR 50.55a and

(>150-F ASME Section Xl.

general; Subsection IWL would

'200-F local) not be able to identify the reduction of strength and modulus due to elevated temperature. Thus, for any portions of concrete containment that exceed specified temperature limits, further evaluations are waranted. Subsection CC-3400 of ASME Section Ill. Division 2, specifies the concrete temperature limits for normal operation or any other long-term period. The temperatures shalt not exceed 150'F except for local areas, such as around penetrations, which are not allowed to exceed 200'F.

Ifsignificant equipment loads are supported by concrete at temperatures exceeding 150F, an evaluation of the ability to withstand the postulated design loads is to be made.Higher temperatures than given above may be allowed in the concrete if tests and/or calculations are provided to evaluate the reduction in strength and this reduction is applied to tne allowables.

w I_ 1esign page 24 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 II ---_ __ ____ Oyster Creek LRA Item Component -

I Material Environment I E 1.Management Aging IJI Item I stutueIJ and/or Material Environment Effect Pogernt

-Co pnetE'e It Progra Component ________ ________

C-51 Concrete:Basemat. Concrete Any Cracking due Chapter XL.S2. ASME N/A N/A N/A NIA N/A N/A This is applicable to a Mk.lIt concrete fill-in annulus to expansion/ Section Xl, Subsection concrete containment -not reaction with IWLAccessible applicable to Oyster Creek.

aggregates Areas:lnspections performed in accordance with IWL will indicate the presence of surface cracking due to reaction with aggregates.lnaccessibl e Areas:As described in NUREG-1557, investigations, tests, and petrographic aggregates performed in accordance with ASTM C295-54 or ASTM C227-50 can demonstrate that those aggregates do not reac within reinforced concrete. For potentially reactive aggregates, aggregate-reinforced concrete reaction is not significant if the concrete was constructed in accordance with ACI 201.2R.Therefore. if these conditions are satisfied, aging management is not necessary.

EP-39 Heat exchanger tubes Copper Closed cycle Reduction of Chapter XI.M21 N N/A N/A N/A N/A N/A The material and enviroment alloy cooling water heat transfer/ Closed-Cycle Cooling combination of copper alloy and fouling Water System CCCW is not applicable to Oyster Creek ESF systems.

Reduction of heat transfer in copper alloy heat exchanger tubes is managed by the CCCW program in non-ESF systems in

_ _ _ ___ _ __ _ _ _ __ _ __ _ _ __ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ the DCIRA.

page 25 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7

[ September 2005 Revision 1 A l Oyster Creek LRA l Stinsr an rI IIA - Aig II I Srcue III A1_ I Item Comonent atea Environment e t Management and/or Material vironment f g m CopnntEfc Comments Progra Component EfetPrga EP40 Heat exchanger tubes Steel Lubricating oil Reduction of Chapter XL.M39, N/A N/AN/ NMA N/A N/A The material and environment heat transfer/ "Lubricating Oil combination of steel heat fouling Analysis'The AMP is to exchanger tubes in lubricating oil be augmented by isnot applicable to Oyster Creek verifying the ESF systems.

effectiveness of the The Lubricating Oil Monitoring lubricating oil analysis Activities program is used to program. See Chapter manage reduction of heat XI.M32, 'One-Time transfer in heat exchanger tubes Inspection,' for an in lubricating oil in non-ESF acceptable verification systems in the OC LRA.

program.

EP41 Piping, piping Stainless Treated borated Loss of Chapter XI.M2, 'Water N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

components, piping steel water materiatl Chemistry,' for PWR elements, and tanks pitting and primary water crevice corrosion EP42 Encapsulation Steel Air - indoor Loss of Chapter XL.M38. N/A N/A N/A N/A N/A N/A This component is not applicable Components uncontrolled maleriatl 'Inspection of Internal to Oyster Creek ESF systems (Internal) general, Surfaces in and is not included in the LRA.

pitting, and Miscellaneous Piping crevice and Ducting corrosion Components' _

EP43 Encapsulation Steel Air with borated Loss of Chapter XI.M38, N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

Components water leakage materiall 'Inspection of Intemal (Internal) general, Surfaces in pitting, Miscellaneous Piping crevice and and Ducting boric acid Components' corrosion EP44 Piping, piping Stainless Closed cycle Cracking/ Chapter XI.M21. N/A N/A N/A N/A N/A N/A There is no Closed Cycle components, and piping steel cooling water stress "Closed-Cycle Cooling Cooling Water greater than 140 elements >60'C (>140'F) corrosion Water System' degrees F environment at Oyster cracking Creek; this item is rnotapplicable cracking to the OC LRA.

EP45 Piping, piping Copper Lubricating oil Loss of Chapter XI.M39, N/A N/A N/A N/A N/A N/A The material and environment components, and piping alloy malerial/ "Lubricating Oil combination of copper alloy and elements pitting and Analysis"The AMP is to lubricating oil is not applicable to crevice be augmented by ESF systems at Oyster Creek, corrosion verifying the therefore this item is not effectiveness of the applicable to the OC LRA. Non-lubricating oil analysis ESF systems at Oyster creek program. See Chapter address loss of material in XI.M32, One-Time copper alloy material with a Inspection,' for an lubricating oil environment with acceptable verification line item AP47 using Lubricating program. Monitoring Activities and One-Time Inspection programs.

page 26 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously Included in tihe January 2005 Draft GALL) Rev. 1 Attachment 7 l September 2005 Revision 1I I __F____ Oyster Creek LRA l_________

I em II I AigJ Structure Comments~..

Ite tnCotmrp CopnetEfetnd!on t Material Environment. . Management Program Item and/or Component Material Environment ffe" Efec A

Poga Comments EP46 Piping, piping Steel Lubricating oil Loss of Chapter Xt.M39, N/A N/A N/A N/A N/A N/A The material and environment components, and piping materiall "Lubricating Oil combination of steel and elements general, AnalysisThe AMP Is to lubricating oil is not applicable to pitting, and be augmented by ESF systems at Oyster Creek, crevice verifying the therefore this item is not corrosion effectiveness of the applicable to the OC LRA. Non-lubricating oil analysis ESF systems at Oyster creek program. See Chapter address loss of material in steel XI.M32, 'One-Time material with a lubricating oil Inspection,' for an environment with line items AP-acceptable verification 30 and SP-25 using Lubricating program. Oil Monitoring Activities and One-Time Inspection programs.

EP-47 Heat eschanger tubes Copper Lubricating oil Reduction of Chapter XI.M39, N/A N/A N/A N/A N/A N/A The material and enviroment alloy heat transfer/ "Lubricating Oil combination of copper alloy heat fouling AnalysisThe AMP is to exchanger tubes in lubricating oil be augmented by is not applicable to Oyster Creek verifying the ESF systems. The Lubricating effectiveness of the Oil Monitoring Activities program lubricating oil analysis is used to manage reduction of program. See Chapter heat transfer in heat exchanger Xl.M32, 'One-Time tubes in lubricating oil in non-Inspection, for an ESF systems in the OC LRA.

acceptable verification program.

EP48 Piping, piping Steel Closed cycle Loss of ChapterXI.M21, N/A N/A N/A N/A N/A N/A The material and enviroment components, and piping cooling water malerial/ 'Closed-Cycle Cooling combination of steel piping, elements general, Water System' piping components, and piping pitting, and elements in closed cycle cooling crevice water is not applicable to Oyster corrosion Creek ESF aystems. The Closed Cycle Cooling Water program is used to manage loss of material in steel piping with items A-25 adA-63 in non-ESF systems in the OC LRA.

EP-49 Pump Casings Steel with Treated borated Loss of A plant-specific aging N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

stainless water material management program steel cladding is to be cladding breach evaluated.Reference NRC Information Notice 94-63, 'Boric Acid Corrosion of Charging Pump Casings Caused by Cladding Cracks.' _

page 27 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously inctuded in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 _ I OYster Creek LRA Iem Rtrinfairp ant lnr [ I TAn I Aging IuI I structure 1 1 I AI, I A- . .--

Itm Componen Material Environment E ffcManagement Item and/or Material Environment Effect ir rog am Comments Efect Program Component EfetProgram EP-50 Heat excatnger tubes Stainless Lubricating oil Reduction of Chapter Xt.M39. N/A N/A N/A N/A N/A N/A The material and enviroment steel heat transfer/ Lubricating Oil combination of stainless steel fouling AnalysisThe AMP is to heat exchanger tubes in be augmented by lubricating oil is not applicable to verifying the Oyster Creek systems.

effectiveness of the lubricating oil analysis program. See Chapter Xl.M32, 'One-Time Inspection,' for an acceptable verification program.

EP-51 Piping, piping Stainless Lubricating oil Loss of Chapter XL.M39, N/A N/A N/A N/A NIA N/A The material and environment components, and piping steel material/ 'Lubricating Oil combination of stainless steel elements pitting and Analysis'The AMP ist1 and lubricating oil is not crevice be augmented by applicable to ESF systems at corrosion verifying the Oyster Creek, therefore this item effectiveness of the is not applicable to the OC LRA.

lubricating oil analysis Non-ESF systems at Oyster program. See Chapter creek address loss of material in XI.M32, 'One-Time stainless steel material with a Inspection,' for an lubricating oil environment with acceptable verification line items AP-59 and SP-38 program. using Lubricating Oil Monitoring Atvtes and One-Time Inspection programs.

EP-52 Piping. piping Gray cast Closed cycle Loss of Chapter Xl.M33, N/A N/A N/A N/A N/A N/A The material and environment components, piping iron cooling water materialV Selective Leaching of combination of grey cast iron and elements selective Materials' dosed cooling water is not leaching applicable to ESF systems at Oyster Creek, therefore this item is not applicable to the OC LRA.

Non-ESF systems at Oyster creek address loss of material due to selective teaching in cast iron material with aclosed cooling water environment with line item A-5O using Selective Leaching of materials program.

page 28 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 I Il Oyster Creek LRA l item -- - -

tmarln Matlerial Environmet ~i.O I AigStructure Management Item

[t and/or 1Material I Environment I ._,A-d1 [

I .a..

e ....

I..

Comments I

Itm Component 'Effet Progra ____ component Eff"e'cut Program EP-53 Piping, piping Stainless Condensation Loss of A plant-specific aging NA N/A N/A NIA N/A N/A The material and environment components, piping steel (Internal) materal management program combination of stainless steel elements internal pitting and is to be evaluated. and condensation is not surfaces, and tanks crevice applicable to ESF systems at corrosion Oyster Creek, therefore this item is not applicable to the OC LRA.

Non-ESF systems at Oyster creek address loss of material due to pitting and crevice corrosion in stainless steel material with a condensation environment with line item A-12 using the One-Time Inspection

___________ ________________ program.

EP-54 Piping, piping Gray cast Soil Loss of Chapter XL.M33, N/A N/A N/A N/A N/A N/A The material and environment components, and piping iron material/ 'Selective Leaching of combination of grey cast iron and elements selective Materials' soil is not applicable to ESF leaching systems at Oyster Creek, therefore this item is not applicable to the OC LRA. Non-ESF systems at Oyster creek address loss of material due to selective leaching in cast iron material with a soil environment with lne item A-02 using Selective Leaching of Materials programand A-01 using the Buried Piping Inspection

_ _program. ._

EP-55 Piping, piping Stainless Raw water Loss of ChapterXI.M20, Oper N/A N/A N/A N/A N/A The material and environment components, and piping steel material/ Cycle Cooling Water combination of stainless steel elements pitting, System' and Raw Water (salt water) is crevice, and not applicable to ESF systems at microbiologic Oyster Creek, therefore this item ally is not applicable to the OC LRA.

influenced Non-ESF systems at Oyster corrosion creek address loss of material due to piting. crevice, and mic corrosion in stainless steel material with a raw water - salt water environment with line item A-54 using the Open-Cycle Cooling Water or Periodic Inspection programs.

page 29 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision I l l Oyster Creek LRA l Item -. Material Environment I Aging Management Item Structure and/or l

Material Environment I A4T_.

-"**'l I

`- t......

I Comments I_

ItemComponEnviroment Effect Program Component Effect '%0"u Program _ _ _ _ _ _

R-219 Reactor vessel Steel; Reactor coolant Cumulative Fatigue isa time- N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

components:Flanges;Noz stainless fatigue limited aging analysis zles;PeneLrations;Pressu steel; steel damage/ (TLAA) tobe re housings;Safe with nickel- fatigue performed for the ends:Thermal alloy or period of extended sleeves;Vessel shells, stainless operation, and, for heads and welds steel Class 1components, cladding; environmental effects nickel-alloy on fatigue are to be addressed. See the Standard Review Plan.

Section 4.3 'Metal Fatigue,' for acceptable methods for meeting the requirements of 10 CFR 54.21(c)(1).

R-220 Reactor coolant pressure Steel; Reactor coolant Cumulative Fatigue is a time- R-04 Piping, piping Steel, Reactor coolant Cumulative TLAA, evaluated in This material and environment boundary stainless fatigue limited aging analysis components, and stainless fatigue accordance with 10 CFR combination Is addressed in components:Piping. steel; steel damage/ (TLAA) to be piping elements; steel, cast damage/fati 54.21(c) and environmental Oyster Creek reactor coolant piping components, and with nickel- fatigue performed for the flanges; heater austenitic gue effects are to be addressed systems with line item R-04.

piping elements alloy or period of extended sheaths and stainless for Class 1 components stainless operation, and for sleeves; steel, carbon steel Class 1components, penetrations; steel with cladding; environmental effects pressure nickel-alloy nickel-alloy on fatigue are to be housings; pump or stainless addressed. See the casing/cover; steel Standard Review Plan, spray head; cladding.

Section 4.3 'Metal thermal sleeves; nickel-alloy Fatigue, for vessel shell heads acceptable methods and welds for meeting the requirements of 10 CFR 54.21(c)(1).

R-221 Recirculating steam Steel; Reactor coolant Cumulative Fatigue is a time- N/A N/A N/A NiA N/A N/A Applicable to PWRs only.

generator stainless fatigue limited aging analysis components:Flanges; steel; steel damage/ (TLAA) to be Penetrations; with nickel- fatigue performed for the Nozzles;Safe ends, lower alloy or period of extended heads and welds stainless operation, end, for steel Class 1components, cladding; environmental effects nickel-alloy on fatigue are to be addressed. See the Standard Review Plan, Section 4.3 Metal Fatigue.' for acceptable methods for meeting the requirements of 10 CFR 54. 21(c)(1) page 30 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision III _ _ _ Oyster Creek LRA Item St,--1 I II . . I Aging II T structure II I A-$- I A l Material EnvironManagement Item and/or Material Environment ... I" _, ...... Comments

_- Cm~pnen 'E t Pogr ompnen Efect Program R-222 Once-through steam Steel; Reactor coolant Cumulative Fatigue is a time- N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

generator stainless fatigue limited aging analysis components:Pdmary side steel; steel damage/ (TLAA) to be nozzlesSafe ends and with nickel- fatigue performed for the welds alloy or period of extended stainless operation, and, for steel Class 1 components, cadding; environmental effects nickel-alloy on fatigue are to be addressed. See the Standard Review Plan, Section 4.3 'Metal Fatigue." for acceptable methods for meeting the requirements of 10 CFR 54.21(c)(1).

R-223 Reactor coolant pressure Steel; Reactor coolant Cumulative Fatigue is a time- N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

boundary stainless fatigue limited aging analysis components:Piping. steel; steel damage/ (TLAA) to be piping components, and with nickel- fatigue performed for the piping alloy or period of extended elements;Flanges;Nozzle stainless operation, and, for s and sate steel Class 1 components, ends;Pressurizer vessel cladding; environmental effects shell heads and nickel-alloy on fatigue are to be welds;Healer sheaths addressed. See the and Standard Review Plan, sleeves;Penetrations; Section 4.3 'Metal andThermal sleeves Fatigue,' for acceptable methods for meeting the requirements of 10

___ ___ ___ __ ___ ___ CFR 54.21(c)(1).

R-224 Steam generator Steel Secondary Loss of Chapter X5M2, 'Water N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

componentsShell feedwater/ steam material/ Chemistry,' for PWR assembly general, secondary waterThe pitting, and AMP is to be crevice augmented by verifying corrosion the effectiveness of water chemistry control. See Chapter XL.M32, 'One-Time Inspection,- for an acceptable verification program.

page 31 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 Item I Rtresrti Comrponent

.w..T September 2005 Revision IIII_---

Material I

Environment .

i._ I Aging Maaement EffectComonntEffect Ii l l Item 1 Structure and/or Material I

Environment Oyster Creek LRA I AMi- 1AM-n MzA- - -+rt Program Comments l

R-225 Isolation condenser Stainless Reactor coolant Cracking/ Chapter Xl.M1, ASME R-15 Isolation Stainless Reactor coolant Cracking/ Chapter XL.M1, *ASME The Oyster Creek LRA credits components steel; steel cyclic loading Section Xl Inservice condenser tube steel, steel stress Section Xl Inservice the ASME Section Xl Inservice Inspection, side components corrosion Inspection, Subsections Inspection, Subsections IWB, Subsections IWB. cracking IWB. IWC, and IWD,' for IWC. and IWO program B.1.1 IWC, and IWD, for and Class 1 components and and Water Chemistry program Class 1 intergranula Chapter XL.M2, 'Water B.1.2 as augmented by GALL for componenIsThe AMP r stress Chemistry,- for BWR water managing cracks in the isolation in Chapter XL.M1is to corrosion in BWRVIP-29 (EPRI TR- condenser tube side be augmented to cracking 103515). The AMP in components. Cracks due to detect cracking due to Chapter XI.M 1 isto be cyctic loading are managed in cyclic loading and augmented to detect the same manner.

verification of the crcigdue to stress program's corsion cracking and effectiveness is cyclic Loading or loss of necessary to ensure material due to pitting and that significant crevice corrosion, and degradation is not verification of the occurring and the effectiveness of the component intended program is necessary to function will be ensure that significant maintained during the egradation isnot exe d dperiod of o c rigand the operation. An component intended acceptable verification function will be maintained program is to include during the extended period temperature and of operation. An acceptable radioactivity monitoring verification program is to of the shell side water, incude temperature and and radioactivity monitoring of the shell side water, and eddy current testing of

_ _ _ _ _ _ _ __ _ _ _ __ _ _ _ _ _ _ _ _ _ _ __ _ __ u bes.

R-226 Tubes Nickel alloy Secondary Denting/ Chapter XL.M19, N/A N/A N/A N/A N/A Applicable to PWRs only.

feedwater/ steam corrosion of Steam Generator carbon steel Tubing Integrity' tube support andChapter XL.M2.

plate Water Chemistry,' for PWR secondary water.

RP-23 Piping, piping Steel with Reactor coolant Loss of Chapter XI.M2, Water N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

components, and piping stainless material/ Chemistry, for PWR elements; flanges; heater steel or pitting and primary water sheaths and sleeves; nickel alloy crevice penetrations; thermal cladding; corrosion sleeves; vessel shell stainless heads and welds steel; nickel

,alloy RP-24 Reactor vessel intemals Stainless Reactor coolant Loss of Chapter XI.M2, Water N/A N/A N/A N N/A N/A N/A Applicable to PWRs only.

components steel; nickel material/ Chemistry,' for PWR alloy pitting and primary water I__

I_____________________________

I1 ,__ I cevice I I___

I ,_____

__________ I ,___ I I_____ _ [

page 32 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision I GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 I_ September 2005 Revision I _ __ _ Oyster Creek LRA Item e StriComponent Material Environment I Management Man.Prgagmentpoen Cor Itm Material Environment he Effet ei *t Progam; Comments RP-25 Reactor Vessel:Flanges, Stainless Reactor Coolant Loss of Chapter XI.M2, 'Water This new The specifications of new line nozzles; penetrations; steel; steel materiali Chemistry,' for BWR line item item RP-25 will be addressed as safe ends; vessel shells, with nickel- pitting and waterThe AMP is to be was not follows:

heads and welds alloy or crevice augmented by verifying addressed The aging effect of loss of stainless corrosion the effectiveness of in the material due to pitting and steel water chemistry Oyster crevice corrosion in reactor cladding; control. See Chapter Creek vessel Ranges, nozzles, nickel-alloy XI.M32, 'One-Time LRA penetrations, safe ends, vessel Inspection,' for an shell, heads and welds will be acceptable verification ged though the use of the program. Water Chemistry and One-Time Inspection programs. The selection of susceptible locations for one-time inspection will be based on severity of conditions.

tim of service, and lowest design margin.

RP-26 Reactor vessel internals Stainless Reactor coolant Loss of ChapterXI.Ml.'ASME This new The specifications of new line components steel; nickel material/ Section XI Inservice line item item RP-26 will be addressed as alloy pitting and Inspection, was not follows:

crevice Subsections IWv, addressed The BWR Vessel Internals corrosion IWC, and IWD,' for in the program (0.1.9) ia used in the Class I components Oyster Oyster Creek LRA for aging and Chapter XL.M2. Creek management of the reactor sater Chem.iste a for RA ssel internals components.

BWR water The Oyster Creek LRA credits this program for managing cracking initiation and growth in reactor internal components.

RP-27 Reactor coolant pressure Steel with Reactor coolant Loss of Chapter XI.M2, 'Water EP-32 Piping, piping Stainless Treated water Loss of Water Chemistry program For piping. piping components, boundary components stainless material Chemistry,' for BWR A-58 components, and steel materialf (B.1.2) and the One-Time and piping elements in RCPB steel or pitting and waterThe AMP is to be AP-57 piping elements pitting and Inspection program systems and systems with RCPB nickel alloy crevice augmented by verifying crevice (81.24)10 verify the interface, the Oyster Creek LRA cladding; corrosion the effectiveness of corrosion effectiveness of water used line items EP-32. A-58, and stainless water chemistry chemistry control. AP-57 for loss of material due to steel; nickel control. See Chapter pitting and crevice corrosion of aioy XI.M32, 'One-Time stainless steel in treated waler Inspection,' for an (including reactor coolant). using acceptable verification the Water Chemistry and One-poram. Time Inspection programs. This is in conformance with the September 2005 Revision I of GALL.

RP-28 Flanges; nozzles; Stainless Reactor Coolant Loss of Chapter XI.M2, 'Water N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

penetrations; pressure steel; steel materialif Chemnistry, for PWR housings: safe ends; with nickel- pitting and primary wter vessel shells, heads and alloy or crevice welds stainless corrosion cladding;

_nickel-allov . _

page 33 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision I GALL (Items not previously included in the January 2005 Draft GALL) Rev. I Attachment 7

.. ,1,.

September 2005 Revision 1 I Material I1 Aging fl Structure i1A Oyster Creek LRA T Item Component Environment A-1_- AN Comments Management Item and/or Material Environment e P am" Comments Effect Program Componentt rora RP-31 Piping, piping Nickel alloy Reactor coolantl Crarking/ Chapter XI.M1,ASME N/A N/A N/A N/A N/A N/A Applicable to PWRs only.

components, and piping steam primary water Section Xl Inservice elements stress Inspection.

corrosion Subsections IWB, cracking IWC, and IWD' for Class 1components, andChapter XI.M2,

'Water Chemistry' for PWR primary water andComply with applicable NRC Orders and provide a commitment in the FSAR supplement to implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.

SP-53 Heat exchanger tubes Copper Lubricating oil Reduction of Chapter XL.M39, N/A Emergency Diesel Brass and Lubricating Oil Reduction Lubricating Oil Monitoring The Lubricating Oil Monitoring alloy heat 'Lubricating Oil Generator and copper alloy of heat Activities (B.2.2) Activities (B.2.2) plant specific transfer/fouli AnalysisThe AMP is to Auxiliary System transfer program provides for monitoring ng be augmented by and Fire and control of oil impurities and verifying the Protection System properties to mitigate loss of heat effectiveness of the heat exchanger transfer (fouling) in lubricating oil lubricating oil analysis tubes systems by preserving an program. See Chapter environment that is not XL.M32, 'One-Time conducive to heat transfer aging Inspection.' for an effects. Itdoes not include acceptable verification verification by one-time program. inspection.

SP-54 Piping, piping Stainless Closed cycle Cracking/stre Chapter XL.M21. N/A N/A N/A N/A N/A N/A There is no stainless steel components, and piping steel cooling water ss corrosion 'Closed-Cycle Cooling exposed to a dosed cooling elements >60'C (>140'F) cracking Water System- water environment > 140 deg F.

SP-55 Piping, piping Copper Treated water Loss of Chapter XI.M33, AP-32 Valve bodies and Brass, Treated water Loss of Selective Leaching of None.

components, and piping alloy >15% material/ *Selective Leaching of heat exchanger bronze, material Materials (B.1.25) elements Zn selective Materials' tube sheets copper alloy, leaching aluminum bronze SP-56 Heat exchanger tubes Copper Raw water Reduction of Chapter XI.M20, Open N/A . N/A N/A N/A N/ A There are no copper alloy alloy heat Cycle Cooling Water components exposed to a raw transfer/fouli System' water - salt water environment ng with a heat transfer intended

_ __ __ ___ _ _ _ _ _ _ _ _ _ _ _ __ _ _ __ _ _ _ I__ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _function.

page 34 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 ttemn September 2005 Revision Material Environment I

Effct A! Aging Management fiStructure l l _

Item and/or 111 Material Environment Oyster Creek LRA Efe 1

a t ints cs cycle Component___ ___________ Program Componentt rora SP-57 Heat exchanger tubes Copper Closed cycle Reduction of ChapterXI.M21,. N/A N/A N/A N/A N/A N/A The material and environment alloy cooling water heat 'Closed-Cycle Cooling combination of copper alloy heat transfer/fouli Water System' exchanger tubes in closed cycle ng cooling water is not applicable to Oyster Creek Steam and Power Conversion Systems. For applications of this material and environment combination in Auxiliary Systems, see new GALL item AP-80.

SP-58 Heat exchanger tubes Copper Treated water Reduction of Chapter XI.M2, 'Water N/A Shutdown Cooling Copper Treated water Reduction Water Chemistry (B.1.2) Does not include verification via alloy heat ChemisWryThe AMP is Pumps seal of Heat one-time inspection. The treated Iransfer/fouli to be augmented by coolers (RBCCW Transfer water environment for the SDC ng verifying the LR System) pumps seal coolers is reactor effectiveness of water coolant. The Water Chemistry chemistry control. See program requirements for reactor Chapter XI.M32, 'One- quality water provide added Time Inspection,- for assurance that an environment an acceptable conducive to fouling does not verification program. exist.

SP-59 Piping, piping Steel Air - outdoor Loss of Chapter XI.M38, N/A N/A N/A N/A N/A N/A There are no steel piping, piping components, and piping (Internal) material/ Inspection of Intemal components. and piping elements general, Surfaces in elements exposed to an air -

pittng, and Miscellaneous Piping outdoor (Internal) environment.

crevice and Ducting Ventilalion components would corrosion Components' typically fall in this category. For the Oyster Creek LRA, the intemnal environment was considered air -indoor as soon SP-60 Piping, piping Steel Condensation Loss of Chapter XI.M38, A-13 Drain traps, piping Cast iron Condensation Loss of Periodic Inspection Ts itdsc thestemnProgram components, and piping (Internal) material/ Inspection of Intemal and fittings, and and carbon Material Program (8.2.5) (B.2.5) provides for planned elements general, Surfaces in valve bodies steel periodic internal inspections.

pitting, and Miscellaneous Piping The inspections provided by crevice and Ducting XI.M38, 'inspection of Intemal corrosion Components' Surfaces in Miscellaneous Piping and Ducting Components are performed system andduring the periodic component surveillances or during the performance of maintenance activities when the surfaces are made accessible for visual inspection. These 2 programs provide equivalent aging managmenti page 35 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (items not previously included in the January 2005 Draft GALL)

Rev. 1 Attachment 7 September 2005 Revision 1 l J Oyster Creek LRA Item itm tructureanrial Component Stucue IIn/o t

ann Avom Ain Maging I

Item IStructure and/or Material Environment I AM 1~n M ........ t Comments 6e" PrManagmen IComponent IEffect Program SP-61 Piping, piping Copper Treated water Loss of Chapter XL.M2, 'Water AP-64 Coolers and Aluminum Treated water Loss of Water Chemistry (B.1.2) AP-64 in the Draft January GALL components, and piping alloy material/ Chemistry'The AMP is AP-70 valves bronze, material and One-Time Inspection mistakenly invoked Chapter elements pitting and to be augmented by brass, (8.1.24) XI.M21, 'Closed-Cycle Cooling crevice verifying the copper, and Water System' for managing corrosion effectiveness of water copper alloy LOM in a treated water chemistry control. See environment. AP-70 in the Draft Chapter XI.M32. 'One- January GALL invoked a 'plant-Time Inspection,' for specific' aging management nacceptable program. The OC LRA used the verification program. Water Chemistry and One-Time Inspection aging management programs for both AP-64 and AP-70.

SP-62 Heat exchanger tubes Stainless Lubricating oil Reduction of Chapter XI.M39, NIA N/A NIA N/A N/A N/A There are no stainless steel heat steel heat 'Lubricating Oil exchanger components exposed transfer/fouli Analysis'The AMP is to to a lubricating oil environment ng be augmented by with a heat transfer intended verifying the function.

effectiveness of the lubricating oil analysis program. See Chapter XI.M32, 'One-Time Inspection,' for an acceptable verification program.

SP-63 Heat exchanger tubes Steel Lubricating oil Reduction of Chapter Xl.M39, N/A Shutdown Cooling Cast iron Lubricating oil Reduction Lubricating Oil Monitoring The Lubricating Oil Monitoring heat 'Lubricating Oil Pumps bearing of heat Activities (B.2.2) Activities (8.2.2) plant specific transfer/fouli Analysis'The AMP is to housing coolers transfer program provides for monitoring ng be augmented by (R8CCW LR and control of oil impurities and verifying the System) properties to mitigate loss of heat effectiveness of the transfer (fouling) in lubricating oil lubricating oil analysis systems by preserving an program. See Chapter environment that is not XL.M32. 'One-Time conducive to heat transfer aging Inspection,' for an effects. It does not include acceptable verification rification by one-time program. inspection.

SP-64 Heat exchanger tubes Steel Closed cycle Reduction of Chapter XI.M21, N/A Fuel Pool Cooling Carbon steel Closed Cooling Reduction Closed-Cycle Cooling None.

cooling water heat 'Closed-Cycle Cooling heat exchangers and cast iron Water of heat Water System (B.1.14) transfer/fouli Water System' and Shutdown transfer ng Cooling Pumps bearing housing coolers (RBCCW

___ __ ___ __ __ ___ ___ __ __ RS st m m))__ ___ __ __ ___ __ ___ ___ __ ___ __ __ ___ __Syste __

page 36 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (items not previously included in the January 2005 Draft GALL)

Rev. 1 Attachment 7 September 2005 Revision 1 A Oyster Creek LRA l Item Strlltiire :nrtlnr Material Environment Management Item andlor Material Environment ... ^ n.Comments Im CmoetEffec Program ____ Component Effect Program T-32 Sliding surfaces LubriteQ Air - indoor Loss of ChapterXL.S3, ASME T-28 Supports for Lubrite Indoor Air Loss of ASME Section Xl. None.

uncontrolled or air mechanical Section Xl. Subsection ASME Class MC Mechanical Subsection IWF (B.1.28) outdoor functioni IWF' Components Function corrosion, (guides, stops, distortion, sliding surfaces, dirt, design clearances) overload, fatigue due to vibratory and cyclic thermal toads T-33 Vibration isolation Non- Air -indoor Reduction or Chapter XI.S3. ASME T-31 Supports for Elastomer Indoor air and Reduction Structures Monitoring The requirements in T-31 are elements metallic uncontrolled or air loss of Section Xl, Subsection HVAC outdoor air orLossof Program (B.1.31) unchanged from the January (e.g.. outdoor isolation IWF- Components Isolation draft to the final September Rubber) function/ (vibration isolation Function GALL version. T-31 in the Final radiation elements) September version of the GALL hardening. is identical to T-33 with the temperature. esception that T.31 invokes the humidity, Structures Monitoring Program.

sustained The Oyster Creek LRA is in vibratory accordance with T-31 for this loading material, environment, and aging effect combination.

TP-10 Support members; welds; Stainless Treated Water < Loss of Chapter XI.M2. 'Water A-35. Supports for Carbon steel Treated Water < Loss of Waler Chemistry (B.1.2) Both A-35 and A-58 invoke the bolted connections; steel; steel 6OC (<140 F) materiall Chemistry,' for BWR A58 ASME Class 2 and and stainless 140F maeIa and ASME Section XI. Water Chemistry program and a support anchorage to general, wtr. andChapter 3 Piping and steel Subsection IWF (83.11.28)venficetion program such as One building structure pitting, and XLS3, 'ASME Section Components Time Inspection. The Oyster crevice XI, Subsection IWF' (support members, Creek LRA used the ASME corrosion welds, bolted Section Xi, Subsection IWF connections. program for verification. This support anchorage aligns with TP-10 of the final to building GALL.

structure) and Supports for AME Class MC Components (support members, welds, bolted connections.

support anchorage to building structure) page 37 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision 1 GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1 _ I_ _I _ _ Oyster Creek LRA l item Component Material Environment Management Item and/or Material Environment l E - Comments

_____________Progra Component IfetPrga TP-11 Support members; welds; Galvanized Air- indoor None None T-26, Supports for Galvanized IndoorAir None None T-26 identifies an aging effect of bolted connections: steel uncontrolled TP-8 ASME Class 1 Steel cumulative fatigue damage. TP-support anchorage to Piping and 8 identifies an aging effect of building structure Components loss of material. Both of these (support members, aging effects were determined to welds, bolted not be applicable to Oyster connections, Creek. See plant specific notes support anchorage 2and 4 of the Component to building Supports Commodity Group structure), AMR.

Supports for Cable Trays (support members, welds, blted connections.

support anchorage to building structure).

Supports for conduits (support members, welds, bolted connections.

support anchorage to building structure).

Supports for HVAC Components, and Ohr page 38 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision I GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision 1_ 1 Oyster Creek LRA Item Item n l r.--e

.rComponent - -

I aeia lI Environment I

lagnge I Item l Structure I I [ I I Management Item and/or Material Copnn Effec Program j Component I I Environment Effect11I

.Effect I M Program.....

Prog~ Comments Miscellaneous Mechanical Equipment

[support members, welds, bolted connections, support anchorage to building structure),

Supports for HVAC ducts (support members, welds. bolted connections, support anchorage to building structure),

Supports for Masonry Walls (support members, welds, bolted connections, support anchorage to building structure),

Supports for Non-ASME Piping and Components (support page 39 of 40

Evaluation of AMR Line Items Added by the September 2005 Revision I GALL (Items not previously included in the January 2005 Draft GALL) Rev. 1 Attachment 7 September 2005 Revision I _ _ Oyster Creek LRA l item Sfrlnrt I Material I

ronment l I, _r_1I Aging Management IStructure II I [ . . . II Item and/or Material Environment l B* MEffectIerdgaml9tIL Comments Component Effect Program ____ Compon t Effect Program members, welds, bolted connections, support anchorage to building structure),

Supports for Panels and Enclosures, Racks (support members, welds, bolted connections, support anchorage to building structure), and Supports for Tube Track and Instrument Tubing (support Members, Welds, Bolted Connections, support anchorage to building structure)

TP-9 High strength bolting for Low alloy Air -indoor Loss of ChapterXI.M18, N/A N/A N/A N/A N/A N/A Oyster Creek does not utilize NSSS component steel, yield uncontrolled material Bolting Integrity' high strength bolting for NSSS supports strength general component supports.

>150 ksi corrosion .

page 40 of 40

v t e Letter Sequence Draft Other
TAC:MC7624, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance Meeting, Meeting, Meeting, Meeting, Meeting Questions 24 February 2006 28 December 2005 5 January 2006 10 March 2006 20 March 2006 10 March 2006 20 March 2006 20 March 2006 30 March 2006 30 March 2006 30 March 2006 20 April 2006 5 June 2006 11 August 2006 Answers 9 December 2005 26 January 2006 3 February 2006 7 April 2006 7 April 2006 18 April 2006 18 April 2006 18 April 2006 26 April 2006 28 April 2006 1 May 2006 3 May 2006 9 May 2006 15 May 2006 2 May 2006 18 April 2006 18 April 2006 26 April 2006 18 April 2006 12 June 2006 7 April 2006 1 May 2008 5 May 2008 Results Approval Other: ML052690388, ML052850300, ML060200084, ML060320211, ML060370508, ML060410649, ML060600122, ML060660177, ML060690026, ML060690130, ML060830564, ML060830567, ML060870126, ML060870147, ML060890080, ML060930255, ML060940146, ML060950408, ML060960563, ML060960568, ML060960602, ML061010639, ML061010644, ML061010646, ML061020614, ML061020616, ML061020638, ML061030419, ML061070304, ML061070306, ML061070307, ML061070309, ML061070310, ML061070319, ML061070321, ML061070329, ML061070395, ML061070398, ML061070399, ML061070403, ML061070429, ML061070430, ML061070432, ML061150320, ML061150330, ML061160161, ML061380647, ML061420086, ML061420088, ML061420089... further results
MONTHYEAR2002-05-15 [Table View]

ML060870132

Text

SUMMARY

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